Compliance Compliance For NORD/LB and its employees, ethical behaviour with integrity is highly valued. The bank's compliance department is committed to protecting applicable laws and complying with market-specific guidelines. Responsible actions play an important role here, which is part of the bank's self-image. Living integrity: Compliance management at NORD/LB At NORD/LB, we view compliance as an essential component of responsible corporate governance. Our Compliance Management System (CMS) supports adherence to applicable legal and regulatory requirements as well as internal standards and contributes to the effective management of compliance risks. It is based on the basic elements of an effective CMS in accordance with IDW PS 980: compliance culture, objectives, risk analysis, programme, organisation, communication and monitoring. NORD/LB's CMS includes binding requirements such as the Code of Conduct and the Corporate Compliance Policy, which apply to all employees. These documents provide the framework for policies, procedures and processes designed to support a clear structure and consistent standards across the organization. Implementation takes place along the lines of defence: the first line is responsible for operational compliance, while the second line – Compliance & Security – ensures monitoring and further development. In addition, training, regular inspections and reports to the Board of Management and other bodies of the Bank ensure transparency and effectiveness. .A key principle of our CMS is its anchoring at the highest level of the organization: as a general rule, all policies and guidelines are approved by NORD/LB's Management Board. This governance framework is intended to support adherence to legal requirements and ethical principles across business processes, thereby contributing to the Bank's long-term success and helping to maintain the trust of our customers and business partners. NORD/LB’s ethical standards and business conduct principles are defined in its Code of Conduct. Compliance with these standards is subject to ongoing monitoring and periodic review. This includes assessing the effectiveness of employee awareness and training measures, reviewing control and monitoring mechanisms, investigating reported misconduct cases, and evaluating the adequacy of corrective and remedial actions undertaken. Lessons learned from these activities are systematically integrated into the continuous improvement of NORD/LB’s governance and compliance framework, helping to ensure the effective and consistent application of the ethical principles set out in the Code of Conduct. The ethical standards and principles of conduct codified in the Code of Conduct apply across all business areas and at all NORD/LB locations. Subsidiaries within the NORD/LB Group are encouraged to align their own codes of conduct with these principles. Compliance with the established standards is monitored across all business areas and locations through regular, risk-based compliance reviews and audit activities. These reviews assess, in particular, the adequacy and effectiveness of measures and controls, adherence to relevant requirements, and the management of ethics-related incidents. The resulting findings are reported to the relevant governance bodies and are incorporated into the continuous enhancement of NORD/LB’s Compliance Management System. Values and Goals As part of our business activities, we seek to contribute to a sustainable and livable future and to support our customers on this journey as a financial partner. Our strategy and self-understanding are founded on responsible, transparent and trustworthy collaboration with our customers, shareholders, investors, other business partners and the wider public. Our values: Ambitious, Sustainable and Human are an integral part of our vision and guide us in carrying out our daily responsibilities. Our Code of Conduct The principles of conduct laid down in our Code of Conduct are intended to provide guidance for our daily actions. With consistent observance, mandatory training (WBT) and regular adaptation of the Code of Conduct we contribute to combining our standards of compliance with law and order with ethically correct behaviour and thus linking entrepreneurial success with social responsibility. This applies to the Management Board as well as to all managers and employees of the NORD/LB Group. Conflicts of interest and political influence NORD/LB has a comprehensive policy on conflict of interest management that applies to all employees, managers and members of the Management Board and Supervisory Board. The aim is to avoid situations in which personal or political interests could collide with the interests of the bank – or even the appearance of such a conflict arises. This also includes political relationships and influence: If elected officials or related persons are appointed to or hold political office, specific disclosure and reporting obligations as well as internal control mechanisms apply. Compliance advisory services, organizational measures and transparency are intended to support adherence to legal and regulatory requirements. In this way, NORD/LB seeks to promote independent decision-making that is guided solely by the interests of our customers and the Bank. NORD/LB has implemented measures to prevent corruption and manage conflicts of interest. The effectiveness of these measures is subject to regular monitoring and assessment. This includes the review of controls, the validation of monitoring mechanisms, the assessment of compliance with internal anti-corruption requirements, and the evaluation of remedial actions arising from identified incidents, misconduct reports, or audit findings. The outcomes of these reviews are incorporated into the continuous development and enhancement of NORD/LB’s Compliance Management System, thereby supporting its ongoing effectiveness and integrity. Summary of the Conflict of Interest Management Policy of NORD/LB AöR Data protection Data protection is an integral part of our corporate governance. We have clear governance structures in place to ensure responsible governance and monitoring of all data protection activities. The Board of Directors receives regular formalized reports on the relevant data protection issues. All employees also undergo mandatory data protection training and are sensitized to the secure handling of personal data through regular internal awareness campaigns. In addition, we continuously conduct data protection impact assessments, risk analyses, and internal audits and reviews to ensure the effectiveness of our measures. At NORD/LB, we have established a process for reporting and dealing with possible data breaches in order to ensure transparency and a rapid response. To ensure transparency, we provide the essential principles and structures in a compact summary: Data protection framework policy of the NORD/LB Group Extract Data protection notice of NORD/LB Money laundering One of the central tasks of NORD/LB's compliance function is compliance with legal and regulatory requirements for the prevention and combating of money laundering and terrorist financing. In doing so, we take into account not only national laws and regulatory requirements, but also internationally recognized standards. These include, in particular, the recommendations of the Financial Action Task Force (FATF) and the Wolfsberg Anti-Money Laundering Principles , which serve as authoritative guidelines for effective and responsible action. Declaration on combating money laundering / USA Patriot Act Embargoes and sanctions NORD/LB is committed to strict compliance with all applicable legal and regulatory requirements in the area of embargoes and sanctions. We ensure that our business activities do not violate national or international sanctions lists, embargo regulations or other restrictive measures. To this end, we use comprehensive review processes and control mechanisms to identify risks at an early stage and act in accordance with the rules. Fraud / Bribery / Corruption NORD/LB is committed to acting with integrity and responsibility in all its business activities. The prevention and mitigation of bribery and corruption is a key element of this approach. We are strongly committed to identifying risks at an early stage and consistently preventing violations. Our actions are based on the applicable legal and regulatory requirements as well as internal guidelines that set strict standards for transparency and fairness. . In addition, we align our activities with internationally recognized standards and best practices, as we seek to meet high compliance standards across our business activities. Compliance with regulatory requirements and internal policies is monitored through regular, risk-based compliance reviews and audit activities. These reviews assess, in particular, the adequacy and effectiveness of measures and controls, as well as adherence to relevant regulatory and internal requirements. With these measures, NORD/LB underlines its clear commitment to integrity and adherence to ethical principles – for the trust of our customers, business partners and the public. Submitting a note/complaint to NORD/LB Whistleblowing / whistleblowing system Compliance with legal regulations, regulatory requirements and internal guidelines is a top priority for NORD/LB. Only through consistent compliance with the rules can we minimize risks and avert damage to our company, our employees and business partners. Misconduct must be detected at an early stage, dealt with and remedied immediately. That is why we operate an independent and confidential whistleblower system that is open to all employees and external partners. Information can be submitted at any time and in any language. The system guarantees the greatest possible protection for whistleblowers and those affected. Investigations are only carried out after careful examination and in compliance with the highest confidentiality in a fair and transparent process. We also offer the option of anonymous reporting and ensure that whistleblowers who do not abuse the system will not be disadvantaged. The presumption of innocence applies to all parties involved until a violation is proven. Potential violations of our Code of Conduct, including serious risks or human rights and environmental violations in the supply chain, can also be reported through the whistleblowing system. In this way, we ensure that necessary measures to end or minimise risks are taken immediately. Submitting a note/complaint to NORD/LB Cybersecurity / Information Security With the increasing digital networking of business and society, cyber security and resilience against cyber risks are becoming increasingly important. As part of the critical infrastructure, NORD/LB has a special responsibility to protect not only its own information, systems and premises, but also the data of our customers and partners. Cyber security is a key trust factor for us and thus an essential part of our competitiveness. Cyber and information security risks are managed within clearly defined governance structures and are the responsibility of the Chief Information Security Officer (CISO). Regular formal reports to the Board of Directors ensure that cyber risks are assessed and managed at the highest level. To promote a high level of security awareness, we conduct mandatory cybersecurity training for all employees and check the effectiveness of our measures through regular internal audits. For dealing with security incidents, NORD/LB has a binding incident management guideline as well as clearly defined processes that ensure a quick and effective response. In addition, external audits and audits ensure compliance with the highest regulatory and industry-specific standards (in this case, the reference to ISO27001). A comprehensive disaster recovery plan guarantees that we can recover our systems and data in a timely manner in the event of an emergency. Our management systems thus underscore our commitment to robust and future-proof information security. Get more information Sustainability Read more FATCA Read more Submitting a note/complaint Read more Diversity Read more Contact Olaf Brüggemann Chief Compliance Officer Phone: Call Olaf Brüggemann +49 (0) 0511 361-2228 Hannover send an e-mail...
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