Compliance

Integrity, Manifesto and bankers' oath

Integrity is also the foundation for de Volksbank’s Manifesto, which has four core themes to give it substance: sustainability, a people-oriented approach, benefit rather profit and financial resilience. Integrity has been translated into rules of conduct that apply to all our staff.

The banking sector introduced the bankers’ oath to bring about a cultural change in the financial sector with the aim to contribute to restoring the confidence of consumers and society in the banking sector. De Volksbank views the bankers’ oath as a confirmation of its Manifesto. De Volksbank, therefore, considers it self-evident that all staff take the bankers’ oath thus subjecting themselves to the disciplinary banking law. By taking the oath, employees are personally responsible for compliance with the sector-wide rules of conduct of the Dutch Banking Association, with which our Common Sense, Clear Conscience Code of Conduct is in line.

Common sense as a guideline

Integrity, however, cannot always be guaranteed by rules and procedures. New dilemmas will always arise. De Volksbank therefore expects its employees to let common sense guide their daily activities. In doing so, the bank strives for an open culture in which there is plenty of room for open discussions on integrity dilemmas.

Compliance as part of three lines of defence

The first line of defence, de Volksbank’s brands and business units, is responsible for integrity in our business operations. The Board of Directors of de Volksbank is ultimately responsible. Issues that cross brands with respect to non-financial risks are dealt with by the Operational Risk Committee, a committee especially set up for this purpose.

From its second line of defence responsibility, the Compliance department is committed to compliance with and the promotion of integrity in our business operations. This department thus develops and lays down integrity frameworks, monitors compliance with these frameworks and provides advice on integrity issues, while making a distinction based on four pillars of integrity:

• Employees
• Products and services
• Customers
• Cooperative working arrangements

The Compliance department carries out its activities independently. In other words, it is independent of the brands and business units of de Volksbank and will consider the interests of all stakeholders in its judgements. Compliance officers hierarchically report to the Director of Compliance, who, in turn, hierarchically reports to the CRO, has a functional reporting line to the CEO and has the ability to escalate issues to the Chairman of the Supervisory Board of de Volksbank. Audit constitutes the third line of defence.