In order to reverse the loss of trust in the aftermath of the financial crisis, we have initiated a change in our corporate culture and strengthened our emphasis on sustainable corporate governance: Responsibility is the focus of our actions. Performance appraisals of our employees are based on the long-term orientation of their decisions.
We place great value on a positive compliance culture: We expect our employees to conduct themselves responsibly, honestly and with integrity. Our code of conduct and ethics describes our values and our minimum requirements for ethical business conduct. The Codes apply to dealings among colleagues as well as contacts with clients, business partners, competitors, authorities and shareholders. The Code of Ethics also forms the core of our policies that set out how employees and senior managers must behave in order to comply with applicable laws and regulations.
It goes without saying that any and every type of corrupt behaviour on the part of our employees is prohibited. They are not permitted to accept, pay or approve any type of bribes. Our policy on prevention of corruption identifies our key principles. The measures for implementing our policies encompass: collection of information about gifts, providing a global hotline for information about breaches of the rules, risk-based checks by independent third parties and appropriate training measures for our staff.
In 2012 we expanded our mandatory compliance training substantially. Our external consultants, contract partners, and staff with temporary employment contracts are also obligated to absolve the training measures. We are devoting special attention to strengthening our risk culture and have incorporated special measures in our training catalog. A new, automated registration process ensures that all business divisions of the bank are integrated into our training program on compliance and risk culture. Furthermore, new employees are systematically offered introductory instruction that covers local issues and content relevant to the department as well as group-wide topics.
We have developed a sustainability policy to support our sustainability mission statement. It serves as the foundation that anchors and drives sustainable practices in institutions such as the Sustainability Boards of our business units or the Responsible Banking Committee of our Private and Business Client division.
By means of specifications such as our ESG Guidelines, we ensure that environmental criteria, social criteria, and sustainable corporate governance criteria (Environmental, Social, Governance, ESG) are taken into account in our core business.
We undertake to adhere to strict guidelines for the prevention of money laundering (Anti-Money Laundering, AML). They include the instructions of the Financial Action Task Force, for example. Our senior managers and employees are admonished to strictly adhere to those standards and prevent any utilisation of our products and services for the purpose of money laundering. Our AML standards correspond with the German anti-money laundering law and the guidelines of the German supervisory authority, Bundesanstalt für Finanzdienstleistungsaufsicht (BaFin). They apply to all units and locations of the bank. We regularly review our anti-money laundering approach and the related goals and measures to ensure that they are up-to-date.
Our “Know Your Customer” (KYC) process contributes towards complying with the statutory and regulatory provisions on prevention of money laundering and protecting the bank against activities involving money laundering, financing of terrorism, and other economic crimes. Our KYC policy sets out how to examine risks that may arise from new or existing customer relationships. That also includes review and escalation processes with reference to individuals who are politically exposed.
Since 1999 we have had a group-wide environmental management system that is certified to the international ISO 14001 standard and integrates social and governance elements. In 2012 we were recertified for another three years.
Our sustainability measures are coordinated by the Group Sustainability Officer together with the sustainability officers of our business divisions and infrastructure units around the world. The Group Sustainability Officer is also co-chair of the interdivisional Environmental Steering Committee (ESC) and is responsible for sustainability issues in the Group Reputational Risk Committee.
In addition, our business units have their own specific governance structures. For instance, in 2012, our private client business division set up a Responsible Business Committee; in the same year our asset management business division established a European ESG Steering Committee.
With the aid of the various measures, we are strengthening responsible and sustainable corporate governance and thus fulfilling our obligation as a globally active corporate group.