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Raiffeisen Bank International | Sustainability Report 2017
GRI content index / Assurance statement Engaged citizen Fair partner Responsible banker Sustainability management Overview Foreword
Furthermore, RBI 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 11).
Compliance
RBI places great value on 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 RBI operates through
our CoC and clear, detailed regulations contained in the Compliance Manual. The compliance area has
an important managing and checking function in our company, particularly in the context of the development
of group standards and their implementation. In total, five network banks were fined in 2017 in the context of
non-compliance with laws and regulations. For confidentiality reasons, the monetary value cannot be
mentioned.
Each new employee of RBI must attend training courses dealing with the topic of compliance. These cover, in
particular, aspects of preventing economic crime (in particular corruption and fraud prevention), 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 2017, 41 percent of the
Board and 44 percent of the B-1 managers as well as 48 percent of the B-2 managers, 58 percent of other
management staff and 64 percent of employees without a management function were trained on the issue of
preventing corruption across the group and also had to take an associated test. At RBI AG, there were 35 percent
of the B-1 managers, 43 percent of the B-2 managers, 50 percent of other management staff and 59 percent of
employees without a managerial function trained on the issue.
Measures and activities to prevent corruption are guided by the principles of the Austrian criminal code, the
UK Bribery Act and the US Foreign Corrupt Practices Act, in the current applicable version. These include the
obligation of the management staff of all units of RBI to shape a corporate culture in which each and every
form of fraud is unacceptable. Assessment and evaluation of the risk of fraud takes place periodically and is
documented accordingly. Persons who provide services for us are subject to due diligence. The relevant
procedures for avoiding fraud are communicated clearly and put into practice effectively. Monitoring and
reviewing these procedures takes place on a regular basis. The group’s internal Anti-Corruption and Bribery
(“ABC”) framework was revised in 2015 and is now even more strongly based on risk and prevention. To
ensure the greatest possible level of plausibility with regard to invitations and gifts, relevant cost refunds have
only been approved by Accounting since 2017 upon presentation of a compliance statement. In addition, not
only customers but also suppliers and business partners are assessed in terms of integrity and reputation. The
relevant data from these assessments is also published in the course of the MiFID II Inducement Register.
Our anti- bribery and corruption framework is based on the following principles: proportionate, process-based
annual risk assessment and scenario analysis; commitment of the executive management; a rigorous disclosure
regime of gifts, invitations, secondary employment, company participations and sponsoring; a continuous
communication and training program including a candidate testing; monitoring and review of the company
conduct (concentration risks, accounting checks to avoid reimbursements without Compliance approval).