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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 and RBI were fined in 2018 in the context of non-compliance with laws and
regulations. For confidentiality reasons, the monetary value can not be mentioned.
All new RBI employees must attend training courses on the topic of compliance. In particular, these cover
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 2018, 38 percent of the
Board and 52 percent of the B-1 managers as well as 52 percent of the B-2 managers, 63 percent of other
management staff, and 73 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, 45 percent of
B-1 managers, 44 percent of B-2 managers, 49 percent of other management staff, and 100 percent of
employees without a managerial function were 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, processbased
annual risk assessment and scenario analysis; commitment of the executive management; a rigorous disclosure
regime for 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).
All employees are 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 constantly analyze our
rules and regulations in order to minimize the risks for the future as far as possible.
Raiffeisen Bank International | Sustainability Report 2018