40
Code of Conduct
Our Code of Conduct (CoC) forms the basis for our practices, dictating, among
other points, the avoidance of fraud, corruption, bribery, market abuses, money
laundering and financing of terrorism as well as the avoidance of any conflicts
of interest, upholding financial sanctions and securities regulations as well as
compliance with data protection standards and other sensitive issues(see
“Compliance” starting on page 41). As a main component of our corporate
responsibility, it consciously goes beyond formal and legally ordained conduct
and describes how we deal with customers, business partners and employees.
It ensures compliance with international standards, which are based on moral
concepts, customer focus, professionalism, quality, mutual respect, initiative,
teamwork and integrity.
Raiffeisen Bank International
Group Code of Conduct
January 2018
The business model of RBI places people at its core. The Code of Conduct is a binding regulatory framework which
is applicable group-wide for all employees and can be found in the respective national language on all of the
websites of RBI and the network banks. In addition, all persons acting for or providing services on behalf of RBI as
well as all other business partners are expected to apply rules and standards that are identical or comparable to
those set out in the Code. It is based on the fundamental Raiffeisen values and is oriented towards the specific
requirements of everyday business at home and abroad. This includes observing 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.
The Management Board of RBI AG has the ultimate responsibility for the CoC; the Chair is also the highest
authority on issues of sustainability. Operational responsibility for implementing the CoC in all global group units
lies with the competent management bodies respectively. 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.
Human rights violations may generate illicit profit, support slavery and human trafficking, promote
the continuation of poor working conditions, and lead to other abuses. RBI strives to further improve
the implemented controls concerning financed projects and corporate customers as well as
concerning existing and potential suppliers. RBI also does not directly or indirectly finance any
businesses, projects or parties in which human rights violations are discernible. 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 was revised in 2017 and adapted to improved standards according to international
practices and the “ethical bank” concept. The new version was the focus of extensive consultation
with various stakeholders and was approved by the Management Board of RBI AG in January
2018. The content was restructured to be more readable and transparent. The new wording is
more principle-based, and clearer requirements and obligations have been established. The previous text was
rephrased and explanatory elements were reduced. A number of existing and otherwise binding elements
were merged together under new headings. New topics were added in accordance with internal and external
developments (such as with regard to sustainability, social media, financial crime, corporate governance,
internal control system). With regard to the sensitive business fields of “Nuclear Energy”, “War Materials” and
“Gambling”, internal policies were passed, which must be adhered to by all employees.
Raiffeisen Bank International | Sustainability Report 2017