Governance for Responsible Corporate Governance and Success
We align our corporate management with defined legal requirements, regulatory requirements and internal guidelines. This framework transparently defines responsibilities, decision-making processes and control mechanisms and is firmly implemented in our business and risk strategy. Through transparent reporting and traceable documentation, we ensure that decisions are made responsibly, with integrity and sustainably. In this way, we create trust – and fulfil our claim as a public bank and as a bank for the energy transition.
Anti-greenwashing at NORD/LB
Sustainability is a central claim for NORD/LB – and transparent, complete and comprehensible communication of our ESG policies is just as important. NORD/LB sees greenwashing as a risk that ESG-related statements will be perceived as misleading by stakeholders – for example, due to unclear, selective or unverifiable statements.
Our internal anti-greenwashing governance sets binding guidelines and a clear level of ambition and emphasises transparency and openness in sustainability communication. In addition, anti-greenwashing aspects are implemented in processes such as customer surveys (including an additional greenwashing question). Governance is reviewed annually and adapted to new regulatory developments as needed.
All employees have a responsibility to proactively avoid greenwashing risks – supported by mandatory annual training and clear communication guidelines (e.g. AntiGreenwashing Communication Policy and Fair Advertising Policy for truthful, transparent ESG communication). Suspected cases must be escalated via the designated and defined reporting channels (fraud prevention management or compliance).
The Corporate Governance Framework of NORD/LB
Our governance framework for the benefit of our stakeholders.
We have a robust corporate governance based on clear responsibilities, transparent decision-making processes and effective control mechanisms. As a public bank, we meet legal and regulatory requirements and ensure responsible and sustainable corporate governance through reliable structures. The basis for this is clearly defined bodies and committees (Owners' Meeting, Supervisory Board, Managing Board), clearly defined responsibilities and a robust and supervisory policy and control landscape (including in accordance with the German Banking Act (KWG), MaRisk and the EBA guidelines).
The following description summarises the essential provisions of the State Treaty, the Articles of Association and the Rules of Procedure and explains that the requirements for sound internal governance are met at all times in accordance with the requirements of European and national supervision.
The following core areas of corporate governance:
- Internal management governance:
Strengthening of organisational structures and decision-making mechanisms for the proper overall management of NORD/LB. - Position Governance:
Transparent roles and consistent responsibilities; accountability along clear authorisations and qualifications in the Managing Board and Supervisory Board that are based on competence and interests. - Governance (Board, Branch & Committees):
Proper establishment, functioning and documentation of decision-making bodies with a focus on individual responsibility. - Policy Governance:
Maintaining an appropriate policy landscape to support the control framework (e.g. Supervisory Board Rules of Procedure, Managing Board Rules of Procedure, Committee Rules of Procedure). - Legal entity management:
Supervision of significant changes to the structure/shareholdings (e.g. reservations of principle and approval in the Owners' Meeting/Supervisory Board)
Normative governance framework:
- State Treaty
- Statutes of NORD/LB
- Rules of Procedure: Supervisory Board (GO AR), Presidential& Nomination Committee (GO PNA), Remuneration Control Committee (GO VKA), Risk Committee (GO RisikoA), AuditCommittee (GO PrüfA), Managing Board (GO Board)
- Essential legal regulations:
- German Banking Act (KWG), in particular §§ 25a–25d
- MaRisk (BaFin Circular 06/2024)
- EBAL Guidelines on Internal Governance and Fitness Assessment
Declaration on the German Corporate Governance Code (CGC) of NORD/LB
The German Corporate Governance Code sets recognised standards for good and trustworthy corporate governance and thus strengthens the trust of investors, customers, employees and the public in the management and supervision of a company. For us at NORD/LB, the Code is not legally binding due to our legal form. Nevertheless, we see transparency and reliable corporate governance as a central claim and voluntarily follow the recommendations and suggestions of the Code – insofar as this is possible and appropriate within our legal form and sponsoring structure.
ESG firmly embedded - The ESG Governance of NORD/LB
As a bank, we have a special responsibility to actively shape the sustainable transformation of the economy. With the ESG Governance Framework, NORD/LB creates transparency about the existing structures, roles, processes and instruments that embeds ESG in NORD/LB. It serves as an orientation for internal and external stakeholders and as a management tool for the continuous development of the ESG organisation at NORD/LB. It is an expression of our aspiration not only to manage sustainability, but to shape it – in a spirit of partnership, transparency and with a view to the future.
Our Commitment & Memberships
By recognising the UN Global Compact and establishing its principles in the Bank's internal guidelines, NORD/LB implements responsible action with regard to ecological, economic and social impacts in the context of its business and operational activities.
