47 GRI Index and Assurance statement Engaged citizen Fair partner Responsible banker Human Capacity Report Sustainability management Overview Foreword on all of the websites of the RZB Group. It is based on the fundamental Raiffeisen values and is oriented towards the specific requirements of everyday business at home and abroad. This includes observance of laws including supporting the fight against money laundering and terrorism, implementing financial sanctions, prohibiting fraud, corruption and bribery, as well as respect for the fundamental rights of employees and environmental legislation. Ultimate responsibility for the CoC lies with the Managing Board of RZB AG, whose Chair is also the highest authority on issues of sustainability. Operational responsibility for implementation of the CoC in all global group units lies with the respectively competent management bodies. The division head responsible for compliance is tasked with coordinating the activities in connection with the CoC. This person is also responsible for all issues relating to compliance with selected legal requirements. In addition, all members of management are responsible for ensuring compliance with the CoC in their own areas of responsibility. Third parties who are commissioned to work on behalf of or in the name of the RZB Group are also obliged to comply with the CoC. This also includes all suppliers as well. The RZB Group also does not finance directly nor indirectly businesses, projects or parties in which human rights may be violated. Our employees have been instructed to take information on forced or child labor into account and, in case of doubt, to involve Compliance. The CoC undergoes regular critical examination and is revised and adapted to improved standards as required. A new version is currently in preparation which has the aim of increasing awareness within the group by means of a clearer representation and through a broad consultation with the various stakeholders Furthermore, the RZB Group is one of the signatory companies of the UN Global Compact (UNGC) and is therefore committed to consistently complying with the ten UNGC principles of responsible business. These principles include the core areas of human rights, labor standards, environmental protection and combating corruption. The concomitant attitude of global responsibility is expected of all staff and managers, as well as of partners and suppliers (see also page 12). Compliance The RZB Group attaches great value to compliance with relevant regulations. We do not tolerate any form of corruption, money laundering, financing of terrorism, fraud or market abuse and work actively against such activities. A prerequisite in our business and operational practices is the fair, ethical and legally compliant behavior of all members of our staff. Mechanisms for complying with laws as well as internal or external codes of conduct are established in all countries in which the RZB Group operates through our CoC and clear, detailed regulations contained in the Compliance Manual. The compliance area has an important managing and controlling function in our company, particularly in the context of the development of group standards and their implementation. In total, three network banks have been fined in the context of non-compliance with laws and regulations. For confidentiality reasons, the monetary value cannot be mentioned. Each new employee of the RZB Group must attend training courses dealing with the topic of compliance. These cover, in particular, aspects of preventing corruption, market abuse and conflicts of interest as well as appropriate measures and rules concerning internal reporting obligations. Defined groups of employees must also attend refresher courses on a regular basis. In addition, there are numerous special training classes for management staff and those sectors where there are particular aspects of compliance involved. The terms of the CoC apply worldwide, for all employees. In 2016, 44 percent of the Board and 43 percent of the B-1 managers as well as 40 percent of the B-2 managers, 51 percent of other management staff and 56 percent
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