60 Responsible sales practices and marketing As surveys consistently show, trust is at the top of the list when it comes to choosing the right bank partner. Since trust is based on honesty, it is important to the RZB Group that its products and services are clearly and transparently communicated for all customers and stakeholders. That is why we align ourselves with strict principles, which are intended to protect customers, when advertising and marketing our products. False or misleading information is taboo. Our goal is to inform our customers as far as possible in an easy-to-understand manner. For recommendations, our main focus of attention is to be objective and comprehensive. It is essential that the risks associated with our products can be clearly demonstrated and explained to the customer. During the period under review, violations of regulations and voluntary codes of conduct in relation to information and labeling obligations for products and services were identified at three network banks, and 14 relevant penalties were enforced. All violations that have been classified as operational risks are monitored and controlled groupwide within the scope of the operational risk management by the “Operational Risk Controlling” team as part of the “Integrated Risk Management”. The incidents are recorded in a central database, the risk is evaluated, scenarios and action plans are analyzed and early warning indicators are developed. In addition, we carry out promotions in accordance with the ethical and moral principles of the code of ethics of the Austrian advertising industry, and we are committed to complying with quality criteria agreed jointly with the advertising industry that extend beyond the statutory provisions. For this reason, the Raiffeisen Banking Group (and therefore also RZB AG and RBI AG) have been awarded the Pro-Ethics Seal of the Austrian Advertising Council. The Pro-Ethics Seal is awarded for a period of two years. Companies are awarded for marketing measures which reflect • the ethical and moral principles of the code of ethics of the Austrian advertising industry (for ethics in advertising) • the community social-ethical ideals of the communications industry (for self-regulation) • and for standing up for freedom of advertising and against advertising bans in this form. The marketing measures of the RZB Group, including the nationally and internationally advertising RBI AG as well as the network banks in Central and Eastern Europe, all comply with the “Consolidated ICC Code – Advertising and Marketing Communication Practice” published by the International Chamber of Commerce. This is to ensure a transparent and fair market presence, one that is oriented to internationally recognized guidelines. In addition to protecting customers, our responsible marketing managers also ensure that only those marketing activities which are in the interests of the company are actually carried out. Bribery and corruption are not to be tolerated to any degree, and our strict compliance guidelines help us to achieve this goal. International advertising and marketing campaigns of the RBI Group are exclusively developed and commissioned by the marketing department of the Vienna head office. This department also evaluates and approves all local campaigns by the network banks in Central and Eastern Europe by reviewing and approving TV spots, online advertising, print boards, etc. before they are published. The RZB Group values a functioning capital market and public confidence as being just as important as its reputation as a professional player on the market. Any action which endangers this principle would have serious consequences for both the RZB Group and the employees involved. The need for integrity also applies in the fight for market share. This means that no unauthorized agreements should be entered into and that it is necessary to abide by the rules of fair competition and the standard international rules of market behavior (MiFID). There were no complaints at the Vienna sites during the timeframe covered by this report. One network bank became the subject of a court case in connection with anti-competitive behavior or monopolistic practices.
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