CODE OF CONDUCT 2021 - DVB Bank
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CODE OF CONDUCT
2021
DVB BANK GROUP
CODE OF CONDUCT
INTRODUCTION
Our core values define how we operate and where we With the implementation of this Code, you will be able
place our priorities. They are centred on the clients, the to relate applicable policies and procedures ensuring our
strength and expertise of our staff and the high standards values are respected in your daily work.
we deliver against these values to achieve them. Further-
more they support and help define our culture within DVB DVB’s Board of Managing Directors is responsible for
Bank Group (DVB). They remain hollow, however, if they approving and issuing this Code of Conduct. The Code
are not implemented into our daily processes. Our exist- is periodically reviewed by GCO (Group Compliance
ing policies and procedures help to ensure that we not Office) to determine whether revisions may be necessary
only comply with applicable rules and regulations, they due to changes of the laws/legislations or changes
also underscore how the core values are implemented within the Group.
into the Bank. They ensure that we are able to build a
sustainable business in the environment we operate. This The Code applies to all employees, managers, officers
Code of Conduct (The Code) provides you with an over- and the Board of Managing Directors. It is our responsibil-
view of some of the key policies/procedures which apply ity to live up to the standards and culture outlined in the
to DVB globally. It is your responsibility to familiarise Code. It is the responsibility of all managers of the Group
yourself with those that apply to your specific role and to ensure that their staff members are aware of the Code,
responsibility. receive appropriate training and know to whom any is-
sues can be escalated to.
The core values are:
It is the responsibility of all staff members to properly
/ We offer our clients professional expertise on trans- understand the requirements we must comply with in our
port markets and transport assets – throughout all daily work. Many of the policies which are being referred
market cycles. to in this document are based upon laws and some also
have criminal penalties if we do not comply with them.
/ We support our clients around the world with Failure to comply with these policies/procedures summa-
tailor-made financial solutions and a broad range of rised in this Code and detailed in the respective manuals
services. Our products meet all relevant legal and may result in disciplinary action (e.g. letter of reprimand)
ethical standards. up to and including termination of employment (e.g. when
in breach of a criminal law such as money laundering
/ Entrepreneurial vision and strength guides our every prevention). Therefore, make it part of your routine to regu-
thought and action. larly review the applicable policies/procedures that apply
to your area of expertise and stop by at the Compliance
/ We create a working environment for all DVB staff pages on DVB Inside. Training sessions that GCO offers
that promotes knowledge, creativity, dedication, will also help each one of us keep the information fresh.
teamwork and diversity.
/ We are committed to the principle of sustainability
and a sustainable development of the Bank as well
as to our role as ethically responsible corporate
citizens.
2
O B L I G AT I O N S O B L I G AT I O N S T O T H E O B L I G AT I O N S
INTRODUCTION TO THE CLIENT B R A N D A N D S TA K E H O L D E R S T O T H E S TA F F S U S TA I N A B I L I T Y
Violations of this Code and applicable policies/procedures If you have concerns or doubts when being asked to
may also constitute violations of the law (e.g. money perform tasks or take a specific action you should ask
laundering prevention, insider dealing or data protection). yourself following questions:
In such cases the employee is personally liable and as
such may be subject to civil or even criminal penalties. / Is it legal? If in doubt ask your local compliance
Likewise your actions may lead to additional fines and officer, legal staff or GHR.
penalties for your manager and DVB. Needleless to say,
the violation of such policies/procedures may also cause / Does it follow our core values or culture? If not speak
a serious damage of our reputation. Please also note that to GHR or Compliance.
there may be legal requirements to have locally specific
Codes, you will be informed of such, as appropriate. / What does my instinct tell me? Do I feel comfortable
with this decision or action? If not – why not?
We take all reports of possible violations seriously and
they will be promptly reviewed. These assessments will If you have concerns about any of your answers above,
include reviewing appropriate documentation and speak- consider discussing this with a colleague, your manage-
ing with staff members to fully understand the issue and ment, GCO, our Workers Council or GHR. These are all
recommending actions to address the issue and resolve value assets which may help clarify your position.
the concern. We will endeavour to keep all such reports Remember – we are all accountable to ensure that we
confidential to the extent this is possible. Additionally we comply with the Code thus also ensuring that we have
will inform the employee/s involved of the status of the a sustainable business model.
investigation – as far as it is possible. Where it is permis-
sible we will allow involved employees to review the infor- In the following text you will find a summary of the core
mation and to suggest any correction of the information. policies/procedures that you need to be aware of. Details
to each of these topics can be found in the respective
This Code cannot anticipate every situation we may en- policy or procedure. It is important you become familiar
counter in our daily work nor can it provide answers to all with these, as they apply to your specific function. If you
questions we may have. Each one of us has to rely on our have any further questions, please contact your Manager,
common sense and good judgment when encountering GHR or GCO.
situations which may not be addressed in the Code. If you
have any questions about this Code or any activity you
may see, contact GCO.
3
DVB BANK GROUP
CODE OF CONDUCT
OBLIGATIONS TO THE CLIENT
In order for each one of us to be able to deliver on this Conflicts of interest
promise, we must ensure that we interact with our clients
openly, fairly and transparently. While there are many DVB requires that employees always act in the best inter-
aspects to delivering on this value, many of which are not est of clients. During the course of business it may hap-
subject to regulation, others have been addressed by our pen that an employee finds themselves in a potential
regulators in order to ensure that we all operate on level conflict situation. Such situations may arise when an
ground with our competitors. Clients therefore can expect employee finds their personal interest and those of DVB
fair and transparent competition, thus being able to pur- in conflict or where the employee is aware of sensitive
chase the best services or products. The summary below information and consequently is then in a situation where
outlines the key responsibilities to achieve this goal. such information is of material interest. Likewise a con-
flict may occur if the staff member has previously worked
for the client and has only shortly joined DVB. In case
Correct and transparent such situations occur, you need to inform DVB immediate-
information ly and recuse yourself from the transaction.
DVB mandates that correct and transparent information is Information is shared on a true “need to know” not a
provided to all clients. Employees therefore should pro- “nice to know” basis. To guide employees, DVB has issued
vide factual and complete product or service information. a Conflict of Interest Policy. A core part of this policy is
We will deal fairly and ethically with all our clients, ven- dedicated to identify and mitigate possible conflict situa-
dors and competitors. Employees are prohibited from tions which may arise when a client is requesting DVB to
gaining an unfair advantage by misusing client informa- provide multiple products.
tion they have nor should they conceal any information
that could be considered material. DVB will not discrimi- To address such identified situations, DVB has implemented
nate against clients and will act in accordance with any a reporting process by which such conflicts must be report-
applicable laws or regulations, e.g. fair lending or trans- ed and documented to GCO. GCO will determine the best
parency laws. course of action and endeavour to mitigate such issues. We
however encourage you to speak pro-actively with GCO if
DVB is an active market participant and welcomes open you believe that a potential conflict may have arisen.
and fair competition. In order to ensure the integrity of
the market and enable clients to benefit from the best Employees also are required to participate in training
product and the most competitive price, DVB prohibits which appropriately addresses this information.
price fixing and market manipulation of any nature. In the
markets in which we are established, laws that address
unethical behaviour in this respect have been implement- Data protection/data privacy
ed. Generally these are known as anti-competition, mo-
nopoly or antitrust laws. They carry a severe penalty both Personal and critical business data is a key asset for any
for the individuals and for the institution. business in today’s world. In order for DVB to provide the
services and the products our clients have chosen, such
data may have to be processed, stored or transferred. If
required, clients are informed in advance of such action
and have the opportunity to request more detailed infor-
mation how such data is used. Should you receive such a
request, you must escalate to GCO quickly. Such requests
must be dealt with within pre-defined time periods.
4
O B L I G AT I O N S O B L I G AT I O N S T O T H E O B L I G AT I O N S
INTRODUCTION TO THE CLIENT B R A N D A N D S TA K E H O L D E R S T O T H E S TA F F S U S TA I N A B I L I T Y
In addition to ensuring that all data is kept confidential, is not restricted to government officials, but includes any
DVB is equally committed to respecting the requirements situation where an unfair advantage is sought by bribing
under the applicable data protection/data privacy laws. another individual. An example of a quasi-government
We will use the data for the purpose for which it was official would be – manager of an airline which is govern-
obtained or for other reasons as defined by law on a strict ment owned; an example of bribing for an unfair advan-
need to know basis. A breach of applicable laws can lead tage – bribing an employee of a competitor to obtain
to criminal charges being raised, personal liability, and information which is not public information.
reputational loss.
It is important for you to be aware that in some countries
Any new use of data or storage of data needs to be report- in which we operate the application of the anti-bribery/
ed to GCO for a review. This will ensure that we can live corruption legislation is extra-territorial. This means, if
up to the high standards that our customers, colleagues you do not conduct yourself in the proper manner, even if
and stakeholders expect from us. DVB is active in many it is not in your country of residence/employment, you
markets and therefore must adhere to the purposes for nonetheless are liable for such actions, irrespective of
which the data is registered. If a change to the purpose is where such action is taken. Such actions also carry per-
needed, we must follow a certain course of action. sonal liability and several penalties. For example, this is
the case of the law in the United States of America and
We will share data only on a need to know basis within the United Kingdom.
DVB Bank Group or for specific legal purposes, as are
permissible. DVB will ensure that the data is appropriate- Employees must also be careful when interacting with
ly protected by use of systems and technology. Such agents or consultants. Transparency of all payments or
systems will be reviewed and updated on a regular basis. agreements is essential in order to ensure that payments
All employees will receive information and/or training on are being made for actual services rendered. If it is not
a regular basis to ensure they are fully aware of their clear for which services the payment to a vendor is being
obligations. Please also consult our Data Protection sec- made, you should question it. If in doubt escalate the issue.
tion on DVB inside.
It is never acceptable to use funds of DVB for any purpose
Please also note that, depending on your personal role in which is not properly documented and approved by the
the organisation, you may have additional obligations to relevant managers. Always be fully aware of to whom
be aware of. Specifically colleagues working in GHR or any funds are being transmitted and the purposes for
our IT Administration will have to be even more vigilant in which they are to be used.
ensuring they are aware of their personal obligations in
their day to day responsibilities. Please contact your You may entertain clients within the parameters of the
manager or GCO should you have additional questions. approved guidelines. It is not permissible to offer any
cash gifts to clients nor for you to accept such from a
client or vendor.
Anti-bribery and corruption
Please refer to the anti-bribery and corruption guidelines.
In the spirit of free and open trade, most countries have
passed anti-corruption legislation. This is an additional
milestone to complement legislation such as antitrust/
anti-competition. Our Board of Managing Directors will
not condone any conduct which does not comply with the
requirements set forth in the applicable policies. Employ-
ees must ensure that they do not attempt to obtain an
unfair advantage by offering a bribe to a government
official. It is legally prohibited to provide a bribe to any
government official or to individuals who are associated
with a quasi-government office. In many countries bribery
5DVB BANK GROUP
CODE OF CONDUCT
OBLIGATIONS TO THE
BRAND AND STAKEHOLDERS
The value of a brand should not be underestimated. It It is never acceptable to take any part in any activity that
takes years to build and establish but only days or even involves fraud, theft, embezzlement or misappropriation
hours to destroy. There are numerous examples of brand of property. You may not participate in concealment,
destruction which have been alarming. If we think back to falsification or omission of any information in our records.
the recent financial crisis, big brand names have disap- You must avoid any conduct that may create the appear-
peared, while the reputation of others have been severely ance of fraud. If in doubt escalate to your management,
damaged. A brand can only be attractive to potential GHR or GCO.
investors (as for clients) if it can demonstrate solid perfor-
mance and ethical integrity in the market space. We You must not devise structures which have/will be imple-
therefore have the obligation to our stakeholders to mented to circumvent tax laws. We will not assist our
ensure we can continue to deliver on our promise. Our clients to avoid paying taxes that they owe. If you are
Board of Managing Directors holds themselves to a high unsure of what your obligations are, please contact GL
standard and expects all staff to do likewise. (Group Legal) and/or GCO for further guidance. In many
countries tax laws, anti-money laws have been or are
Many, if not all, of our clients operate globally. It is there- being changed to ensure that tax evasion is a crime.
fore of critical importance to our clients that we can To facilitate or enable such activities will carry personal
deliver our products and services to our clients to all parts liability and severe penalties. Our Board of Managing
of the world. If we were to run afoul of our regulatory or Directors will not condone such conduct.
legal obligations in any manner, we might jeopardise our
capability to be able to deliver on one of our core values – Furthermore, if you are entering into any agreement on
delivering tailor-made financial services globally in a behalf of DVB, you must ensure that you have the proper
compliant end ethical manner. The DVB Bank Group has authority to do so.
developed key policies to address the diverse require-
ments we have to be aware of, in recognition of the We provide our stakeholders, regulators, employees and
various and demanding requirements of the markets in our Board of Managing Directors with information that is
which we operate, additionally compounded by the com- accurate, complete, objective and timely. In some markets
plexity of having to comply with all requirements accord- this obligation goes beyond financial records and may
ing to German regulations. It is the responsibility of every include documentation of financial records utilised in
employee to comply with these policies and procedures. negotiations. Should you have reason to believe that any
The key areas are summarised below. of DVB’s books and records does not reflect this high
standard, you are required to report this to your manager.
Accurate books and records
Maintaining the highest level of financial integrity is a
key driver in respect to having complete and accurate
books and records. In order to achieve this goal we strive
to ensure full, timely, and accurate financial records.
All entries must correctly reflect the transaction and are
reported according to the locally applicable regulations.
Books and records should include all documentation need-
ed for our financial reporting. Failure to do so may result
in criminal prosecution for both DVB and the individual.
6O B L I G AT I O N S O B L I G AT I O N S T O T H E O B L I G AT I O N S
INTRODUCTION TO THE CLIENT B R A N D A N D S TA K E H O L D E R S T O T H E S TA F F S U S TA I N A B I L I T Y
Relationship with Please familiarise yourself with the secure methods for
our regulators communication. You will find this information in the IT-
Security section on DVB Inside. Here you will also be
Having offices in many different locations around the informed how to classify data and consequently how this
globe entails also maintaining excellent relationships governs the method for communication that may be used.
with the regulators in those jurisdictions in which we are
established. The Bank is committed to interact openly and Utilise secure sites for communication. DVB has identified
transparently with the respective regulators. The respon- a product where you can set up secure data rooms, these
sibility and accountability for these relationships lies with are to be used wherever possible. If it is not possible –
our Board of Managing Directors who may appoint senior e.g. another site has been mandated by the client – then
staff to act on their behalf. If you have been contacted by you must inform GCO of this site. This is to ensure that
a regulator, you should contact your manager or the our data is kept secure.
appropriate compliance officer who will advise you in the
next steps to take. Do not respond directly to the regula- You may not represent yourself on the internet or in blogs,
tors unless you have been cleared to do so. on twitter or other chat rooms as a spokesperson for DVB.
On the other side, wherever you refer to your job in the
public (e.g. by using social media sites) your job and title
Protecting our assets has to be mentioned accurately as they are on your busi-
ness cards. Any new social media sites you may wish
Communications – for DVB to appear in/on must be cleared with GCDC-CC
Physical and electronic (Group Corporate Development & Communications –
When preparing documents – in hardcopy or electronic Corporate Communications).
form – you need to consider the content and language
that you are using. As a general guideline a professional All records must be maintained in compliance with DVB´s
standard needs to always be maintained. This standard Group Data Retention Policy. Please bear in mind that you
applies regardless of whether the document is intended must retain all existing documents that are relevant to
only for internal use or if it is also to be sent to third ongoing litigation, investigation or subpoena requests
parties. Remember that in the future this document needs that DVB may be subjected to, irrespective of the reten-
to be self-sufficient; it needs to be able to be interpreted tion policy.
solely as it is without secondary input. Please note that a
given document may well be viewed out of context or
without any possibility to explain the circumstances. This Business continuity –
also holds true when participating in chats online or on Business c ontingency plans
twitter. You may not disclose any DVB internal informa- DVB has business continuity plans in place both on a local
tion on such forums nor may you conduct yourself improp- as well as on a Group level. These plans ensure that in
erly. Please refrain from speculating in e-mails or making case of emergency situations, crisis, pandemic or natural
a judgement call without full information of the facts. You disasters we remain in operation and available to our
should state what you know directly and then escalate to clients. The plans are updated and tested on a regular
the next level, as appropriate. basis. You will find the plan that applies to you on DVB
Inside under your respective location. Please take some
Remember to keep confidential data truly confidential. Do time to familiarise yourself with this plan.
not leave copies of documentation in conference rooms or
on airplanes. Likewise passwords are to be kept confiden-
tial. When travelling be aware of your surroundings –
screens can be photographed or read by unrelated third
parties.
7DVB BANK GROUP
CODE OF CONDUCT
IT and its importance to the Bank What types of information are covered? Examples in-
DVB strives to maintain a state of the art IT environment. clude: non-public information of clients, correspondence
Most of our key assets – data – is stored on various with clients, financial information of clients; non-public
devices or servers. It is therefore critical that we ensure documents of your former employer or of DVB such as
that all devices and our network are kept secure. There strategy papers, system information or generally any
are extensive policies which will help you understand information which would give another entity or person an
your obligations. These can be found in the IT-Security unfair competitive advantage. If you have any questions
section on DVB Inside. about this, please feel free to contact GCO for further
information.
Please keep all other mobile devices safe. Hacking of
mobile devices has become somewhat commonplace, You must also protect such information according to the
therefore do not open documents or attachments if you do DVB’s Personal Data Protection Policy. Written documents
not know the sender. All mobile devices may not be containing sensitive/confidential information must be
checked in with luggage. stored or destroyed in a secure manner. You should try to
minimise the risk of theft or misuse of such information.
We carefully use all equipment or other assets of DVB Always be sensitive to your surroundings. In most locations
only for the purposes for which they were intended and we share the premises with other companies. Remember
for which we received them. Employees have to receive to not discuss sensitive/confidential information in the
permission for any non-DVB proprietary software they elevators or in other public areas.
would like to store on DVB computer equipment and
maintain the appropriate licenses for such. You will find policies and procedures addressing issues
around confidentiality and protection of data on DVB
Please see the above section on communication in refer- Inside.
ence to online communication as well.
Insider dealing
DVB’s confidential information
During and after your employment with DVB, all bank Insider dealing has become a very important area that
non-public information should continue to be confidential. regulators are actively monitoring. This is due to promi-
You may not bring confidential information with you to nent cases of insider dealing in recent years. Such unlaw-
DVB from former employers without their consent nor ful activity is to the detriment of the general public as
may you take confidential information with you when you they expect to invest at the same playing level as all
leave the Bank to pursue your career elsewhere, unless others. Therefore dealing with insider information is
you have obtained the consent of DVB to do so. There considered to be defrauding the general public. Insider
may be exceptions to this rule; however, you need to dealing comes with hefty fines – up to and including
inquire about such exceptions in advance of your arrival/ criminal convictions, strict fines for DVB and reputational
departure and in any case you need the approval of such loss. We therefore must treat this very seriously.
exceptions in writing.
8O B L I G AT I O N S O B L I G AT I O N S T O T H E O B L I G AT I O N S
INTRODUCTION TO THE CLIENT B R A N D A N D S TA K E H O L D E R S T O T H E S TA F F S U S TA I N A B I L I T Y
Price sensitive, non-public or confidential business data
Accepting and receiving
may only be shared on a need to know basis. If you have gifts and gratuities
or believe you have such information, you must inform
GCO. Likewise, you may not make personal use of such Accepting invitations to business meals, small gifts or
data to buy, purchase or sell securities or otherwise pass other items of appreciation has become a routine part of
such information on to third parties. You also may not our business. As employees of DVB we are required to
share such sensitive information with any third party or consider our local customs, possible regulatory restric-
include such information in e-mails accessible to a larger tions and internal guidelines when considering whether
group of individuals. to accept such items or not. The Policy Gifts and Gratui-
ties provide an outline of what is acceptable and the
If you believe this information must be shared, you must internal rules when accepting or giving a gift.
contact GCO for clearance prior to sending such communi-
cation. Persons with this information are logged and Any gifts you may accept may not place you in a conflict
followed-up. It is a legal requirement to do so, especially of interest. You need to reflect on the gift and determine
if the information can be deemed to be price sensitive. if is appropriate. If you have doubts, contact GCO. You
must log any gifts you receive or you make on behalf of
Part of the general requirements is also the obligation to DVB. GCO reviews the gift log on a regular basis.
not provide advice on purchasing/selling any security
based upon your insider information. This includes mem- It is not allowed to accept or give cash. Likewise the gift
bers of your family or any other person. may not be made to your partner in order to avoid a re-
porting requirement. It is also obvious that you may not
DVB has implemented the Information Handling Policy accept a gift which could be considered a bribe.
governing inside information and instructed employees on
how to deal with specific situations. You will also receive You also need to be aware of local legal requirements, as
appropriate training to ensure that you are aware of the these may be more restrictive than those which govern
regulations governing behaviour in connection with inside our policy. In most countries acceptance or making of gifts
information. are also governed by relevant tax laws. It is your obliga-
tion to ensure that any reporting to tax authorities is
made appropriately.
Personal trading reporting
To avoid any suspicions insider dealing you have to dis-
close your personal trades to GCO immediately.
This is a legal requirement in many markets in which we
are established and with which we must comply with,
GCO permanently monitors this process.
9DVB BANK GROUP
CODE OF CONDUCT
Money laundering/ Likewise, payments to and from clients/third parties are
closely reviewed. As in the case of identification docu-
terrorist financing mentation, you may be called upon to provide additional
prevention compliance information. DVB relies on you to do so.
The misuse of the financial system has major impact on DVB offers regular training to all staff in order to ensure
each and every one of us. For this reason we collectively we are able to comply with applicable regulations.
must ensure that the financial system can operate with
the utmost integrity. Every employee has a role in ensur-
ing that money cannot be laundered by converting illegal Embargos/sanctions
proceeds into funds that appear to be legitimate. To
achieve this, money laundering prevention legislation has Embargos or sanctions are implemented by countries,
been passed globally. DVB has extensive policies/proce- international organisations, e.g. United Nations or
dures and systems to ensure the standards which apply to multi-country organisations, against countries or organi-
all employees and business units. You can find these on sations that threaten local or international security, or
DVB Inside: Financial Crime/Sanctions section. which fail to follow accepted standards of behaviour, e.g.
by engaging in terrorism, drug trafficking or human rights
In order to achieve compliance with these regulations we violations. DVB is committed to fully comply with applica-
must ensure that we obtain all needed documentation to ble restrictions as they apply to our business. In some
ensure that we are transacting with a bona fide client. cases sanctions may apply across borders. For this reason
Such documentation is being requested by all financial you must become familiar with the general regulations
institutions globally. The types of documentation may that apply to your business unit and area. In case you are
differ, however DVB has developed a process to ensure requested to approve a transaction/business with a coun-
that we comply with all applicable legislations. try that is sanctioned, you must contact GCO prior to
committing to the business. Failure to do so carries large
Likewise it is your obligation to escalate any transaction fines and personal liability.
or information which you consider to be suspicious.
Guidelines on how to identify these can be found in the Additionally, DVB must ensure that we have no business
Group AML & CTF Policy. dealings with any individuals, entities, organisations or
groups that have been identified as associated with
Failure to comply with money laundering/terrorist financ- terrorist activities or narcotic trafficking. To ensure com-
ing legislation has personal liability and can lead to pliance, we screen all clients prior to establishing, and
severe penalties or criminal conviction. Please escalate during the term of the relationship.
any concern you may have to GCO. Any concerns you
may have will be addressed promptly and treated with
urgency.
During the course of the relationship with a client, the
documentation obtained from the client is reviewed on
regular basis to ensure that it is still up-to-date. You may
be called upon to support this effort.
10O B L I G AT I O N S O B L I G AT I O N S T O T H E O B L I G AT I O N S
INTRODUCTION TO THE CLIENT B R A N D A N D S TA K E H O L D E R S T O T H E S TA F F S U S TA I N A B I L I T Y
OBLIGATIONS TO THE STAFF
The next of our core values is fostering knowledge, dedi-
Diversity and treating
cation, teamwork and diversity for all employees. A busi- each other fairly
ness will be successful, with the right people and cultural
mix to ensure that the business goals are achieved. Only DVB respects the individual and their right to privacy. We
with the right teams will it be possible to accomplish our employ individuals from many different countries, with
previously mentioned values. differing ethnic backgrounds, religions, ages, sexual
identities, gender and cultures. DVB’s Board of Managing
DVB fosters teamwork across all markets and ensures Directors will not accept any behaviour that does not
that each employee is afforded equal opportunities to support this diversity. Any concerns around diversity
develop themselves. In order to accomplish this goal and should be escalated and/or addressed in a sensitive but
to ensure we comply with legal and regulatory require- prompt manner.
ments, there are key issues we need to be aware of. Not
all areas can be addressed here, for these you need to A balanced work life is encouraged, vacation times and
refer to your local policies, as they will be driven by local personal time off is respected. We do not tolerate any
labour law requirements. form of discrimination or sexual harassment. DVB fosters
a climate of respect for the individual. DVB offers equal
opportunities to all individuals to further their development
Privacy of employee data and careers. We strongly encourage you to voice any con-
cerns in the workplace that you may have. GHR is always
In the same manner that we afford the data of our clients available for discussion, alternatively you may also esca-
the highest level of security, we do the same for the data late these to the Board of Managing Directors or GCO.
of the employees. In all of the markets in which we are
established, employee data is afforded the highest level In all markets in which DVB is established legislation has
of security due to the nature of this data. DVB ensures been passed that requires strict compliance.
this standard by training of the employees who have
interaction with this data, maintaining strict data security
and ensuring that appropriate security measures are
taken to keep physical data safe.
You may not keep a shadow file in an accessible area as
this would circumvent the strict requirements.
Employees have a right to access their data, which pro-
cess governs this access is defined on a market level,
depending on the legal requirements for this market.
11DVB BANK GROUP
CODE OF CONDUCT
Training Outside business interest
DVB will enable employees to attend appropriate training DVB encourages its employees to actively participate in
courses. The scope of the training opportunities will cover their communities. While some outside positions – e.g.
business related information or may include soft-skills, member of the school board or sports club, religious activi-
e.g. presentation skills, management skills. Additionally, ties or political involvement – will generally be acceptable,
DVB will require employees to attend legally required certain other positions, mainly business related, may give
training courses, e.g. money laundering prevention or rise to a potential conflict of interest. Positions in trade
market abuse training. associations or industry associations are acceptable. You
should however also consider if the objectives of the
Any identified needs of staff are to be discussed, at association are in close proximity to the objectives of DVB.
minimum, during the annual appraisal. Actions are to Please also bear in mind, that outside positions may also
be agreed upon between manager and staff member. require excessive amounts of your time.
If this is not the case, you should escalate to your GHR
representative. For the foregoing reasons, all mandates which are busi-
ness related must be disclosed prior to acceptance. GHR
as well as GCO must be informed in advance.
DVB has also determined that it is not permissible to
enter into a business relationship with the Bank outside
of the employee-employer relationship. Specifically – you
may not offer products and services to the Bank for which
you issue an invoice to the Bank and expect remuneration.
12O B L I G AT I O N S O B L I G AT I O N S T O T H E O B L I G AT I O N S
INTRODUCTION TO THE CLIENT B R A N D A N D S TA K E H O L D E R S T O T H E S TA F F S U S TA I N A B I L I T Y
SUSTAINABILITY
Sustainability has become an integral part of economic DVB’s Board of Managing Directors is responsible for the
life. Society as well as investors are requiring financial topic and has mandated Corporate Communications to
institutions to comply with sustainability frameworks coordinate sustainability and related issues with compe-
such as the German Sustainability Code. In this context tent departments. The main objectives are to strengthen
DVB is aware of its multiple roles in society: being a existing measures and to identify potential for new ac-
global transport financier, a player in the financial mar- tion. Various topics are under review and development.
kets, a partner to its clients all over the world, an interna- By implementing DZ BANK Group’s joint climate strategy,
tional employer, a client to service providers, advisers and DVB’s carbon footprint has been reducing and a careful
suppliers as well as a corporate citizen. Thus, the Bank use of natural resources is ensured. The Bank is further-
has made a commitment to sustainability and seeks to more participating in initiatives which address key con-
combine economic operations with responsible action cerns around environment impact. Also the quality of the
towards the environment and society – an approach Bank’s workplace is important: diversity, equal opportuni-
enshrined in this Code of Conduct. ties, health care and work-life balance are taken into
account. Human Rights will be safeguarded in all our
The five elements of DVB’s approach are strategy, business, processes including products for clients or by selecting
society, environment and people. Guidance is derived vendors. Beyond that DVB initiated corporate sponsoring
from legal and regulatory requirements (such as the UK guidelines and dedicated a fixed budget to support local
Modern Slavery Act) as well as the German Sustainability initiatives.
Code. Compliance in the highest degree possible with
these framework and rules have a high priority for the Management of our sustainability activities is a process
Bank and will maintain and further improve our reputation. and all of you are invited to contribute. Sustainability is
about our values. And our values shall determine the
Bank’s conduct and working environment.
13IMPRINT
DVB Bank SE Responsible author
Platz der Republik 6 Oliver Tarrach
60325 Frankfurt/Main, Germany Head of Group Compliance Office
info@dvbbank.com, www.dvbbank.com Managing Director
Phone +49 69 9750 4412
Sabine Schlieben
Group Corporate Communications
Senior Vice President Photos
Manager Investor & Online Relations
Phone +49 69 9750 4449 Adobe Stock/Caner, enanuchit, Kozioł Kamila, MARIMA,
oliviaelisa92, Ralf Gosch, STOCKSTUDIO
Design realisation
MPM Corporate Communication Solutions, Mainz, Germany
The Code of Conduct of DVB Bank Group is published in English only and is
available on our website www.dvbbank.com > Footer > Compliance.
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