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Each member of staff is obliged to report serious violations of the CoC – such as market abuse, fraud, theft,
embezzlement, bribery or corruption. This can be done in the form of an email to Compliance, a telephone
conversation with a Compliance employee, in writing or via an external telephone hotline run by a service
provider in the United Kingdom (group whistle blowing hotline). All allegations will be investigated. The group
reacted immediately to previously reported occurrences of corruption. Appropriate disciplinary action is
carried out in accordance with group regulations, up to and including dismissal. We analyze our rules on a
regular basis in order to minimize the risks for the future as much as possible.
Discussions on the topic of better identification of all sectors exposed to economic crime are usually carried
out at Board level, or with the second level of management, and ensure appropriate awareness. The necessary
measures and on-going efforts to provide in-depth training are implemented with the support of local
Compliance departments or the Financial Crime Management departments. These also play a key role in
avoiding corruption and in anti-corruption checks as well as in business activities in sensitive areas. Financial
contributions or contributions in kind to political parties, politicians or related institutions are given only in
accordance with strict rules and with the approval of RBI AG Management Board. Clear regulations in this
regard are enshrined in the Code of Conduct and are monitored by Compliance. Sponsoring, (financial)
support and contributions are also given only to recognized private organizations with impeccable reputations.
RBI has a well-established internal control system that entails documented controls and requirements in internal
governance documents to enable transparency in roles/responsibilities, periodic validation of the adequacy
and efficiency of the controls in place for managing the underlying risks and periodic assessment of the
controls by means of various forms of tests to measure its effectiveness. The reporting procedures in the form of
directives for strategically important topics are a central element and the basis for an effective internal control
system. These directives and instructions constitute our “company law”. They include the assignment of approval
authority for group and company directives as well as department- and division-specific directives, process
descriptions for the creation, quality inspection, approval, publication, implementation and monitoring of directives
as well as regulations for their revision and repeal.
The management of the respective group units is responsible for implementation of the directives. The
“Confirmation of Compliance” process is carried out each year. As part of this process, 58 group units must
confirm that they have followed the relevant policies. If this cannot be entirely confirmed for individual units,
these units must create a roadmap of how the gaps will be closed. Monitoring compliance with these group
regulations takes place within the framework of audits by the group and local audit departments.
Lobbying
Lobbying is defined as the deployment of suitable people within the company or independent companies to
influence public decision-making processes for the purpose of safeguarding or enforcing specific interests in
respect of the public sector. We basically consider this to be advisable and legitimate in the process of
democratic decision-making and in matters of the execution of state regulations. This activity is subject to high
standards of transparency, both for specialized lobbying companies and for companies that use their own
employees – known as corporate lobbyists – for lobbying activities. All members of RBI are required to register
lobbyists who are active for them in the national lobbying register. At RBI, lobbying work is carried out via RBI
AG as well as the “Fachverband der Raiffeisenbanken” (Association of Raiffeisen banks, part of the Austrian
Economic Chambers WKO). Accordingly, RBI AG is registered in the Austrian lobbying register.
At EU level, RBI AG is registered in the transparency register of the European Commission and the European
Parliament. This involves observing activities by EU institutions with regard to possible impacts on the Raiffeisen
Banking Group (RBG), creation of networks and shared interest coalitions and specific research and preparation
of information on EU initiatives and measures in the area of financial services that are of relevance to us (e.g.
Basel III, deposit insurance fees, corporate governance). Since being included in the register, RBI AG is bound to
comply with the code of conduct of the institutions (European Commission/European Parliament). Our position
statements concerning consultations of the European Commission can be found on the Commission website. At
national level, our position enters into joint position statements by the Austrian Economic Chambers, banking and
Raiffeisen Bank International | Sustainability Report 2017