56
=================================================== =========================================================== s, to voice opinions. All of these contribute to a better result. You will benefit from this yourself, so will the bank and so, last but certainly not least, will the customer, on k. With the Code of Conduct as a reference, we can compare ourselves against what we expect of each other. With regard to customers, society and each other. The code Code of Conduct Rabobank is us

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Page 1: Code of Conduct - Rabobank · The Code of Conduct shows who we ... By working together, ... Rabobank was founded in the Netherlands by enterprising people who had virtually no access

============================================================================================================================

============================================================================================================================Working in an open culture is not only pleasant, it also benefits the quality of our work. You feel free to broach sometimes difficult issues, to provide feedback, to express doubts, to voice opinions. All of these contribute to a better result. You will benefit from this yourself, so will the bank and so, last but certainly not least, will the customer, on whom all our

The Code of Conduct shows who we are: our values, attitude and conduct. And by ‘us’ I do not mean the individual employee, but us as a collective of employees of Rabobank. With the Code of Conduct as a reference, we can compare ourselves against what we expect of each other. With regard to customers, society and each other. The code provides guidance, but

Code of Conduct Rabobank

is us

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Working in an open culture is not only pleasant, it also benefits the quality of our w

ork. You feel free to broach sometim

es difficult issues, to provide feedback, to express doubts, to voice opinions. All of these contribute to a better result. You will benefit from

this

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The Code of Conduct shows who we are: our values, attitude and conduct. And by ‘us’ I do not mean the individual employee, but us as a collective of employees of Rabobank.

Code of Conduct Rabobank

is us

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2

Rabobank

4 Foreword Wiebe Draijer

Core values

This is us Mission Statement

9

12

Contents

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This is how we act Code of Conduct

23 Core values

24 What do these core values mean in practice?

Dutch Bankers’ Oath

37

21

It’s like this How to deal with

dilemmas?

51

39 Towards a solution step by step

41 You are not alone

43 What does the Compliance Officer do?

45 What does the Ethics Office do?

47 What does the Trusted Person do?

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4

Rabobank

The Code of Conduct shows w

ho we are: our values, attitude and conduct. And by ‘us’ I do not m

ean the individual employee, but us as a collective of em

ployees of Rabobank.

ForewordWiebe Draijer

“ Proud to work at Rabobank.”

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Foreword

Our Code of Conduct

The Code of Conduct shows who we are: our values, attitude and

conduct. And by ‘us’ I do not mean the individual employee, but

us as a collective of employees of Rabobank. With the Code of

Conduct as a reference, we can compare ourselves against what

we expect of each other. With regard to customers, society and

each other. The code provides guidance, but not by definition the

answers to questions we sometimes encounter in practice. That is

why it is important to share and to discuss those questions or

dilemmas with each other.

The importance of an open and transparent culture

Working in an open culture is not only pleasant, it also benefits

the quality of our work. You feel free to broach sometimes

difficult issues, to provide feedback, to express doubts, to voice

opinions. All of these contribute to a better result. You will benefit

from this yourself, so will the bank and so, last but certainly not

least, will the customer, on whom all our efforts are centred.

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Rabobank

Socially responsible bank

Rabobank consciously shares in the responsibility for the living

environment of our customers. We are a socially responsible

bank that sets store by the well-being and prosperity of people.

As an international bank for the food & agri sector, we contribute

to solutions for the global food issue. Our strategy is based on

four pillars: complete customer focus, being a rock-solid bank,

a meaningful cooperative and empowered employees. These

pillars form the foundation of Rabobank, viewed from the past,

relevant in the present and inspiring for the future.

Rabobank’s social role in the Netherlands

We have 7.5 million customers in the Netherlands, where almost

half of all small and medium-sized enterprises are customers of

ours. That means we play a crucial role in the national economy.

If the Netherlands is doing well, so will our customers. This means

we are obligated to contribute maximally to the success of our

customers and thereby to our country. We do so in the first place

through our services to the customer, but also by participating

in communities and providing access to our knowledge and

Rabobank consciously shares in the responsibility for the living environment of our custom

ers. We are a socially responsible bank that sets store by the w

ell-being and prosperity of people. As an international bank for the food &

agri sector, we contribute to solutions

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experience to make the economy strong and healthy.

Invested in each other

Our underlying cooperative principle is that you can achieve

more together than alone. That is where the origins of our bank

lie. By working together, you magnify each other’s strengths

and mitigate each other’s weaknesses. We have translated this

principle into a concise, powerful motto that makes clear in

a few words what sets us apart. How we relate as a socially

responsible bank to the customer, the community, the future:

‘We are invested in each other!’

Wiebe Draijer

Chairman of the Executive Board of Rabobank

Foreword

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Rabobank

Our goals and core values are set out

in Rabobank’s Mission Statement,

which provides essential guidance and

inspiration for all our employees.

This is us

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This is us

Who we are

Rabobank was founded in the Netherlands by enterprising

people who had virtually no access to the capital market. It has

a tradition in the small and medium-sized companies segment,

especially in the agricultural sector.

By working on cooperative, or mutual, principles, a financial

institution has since evolved which enables customers to achieve

their financial ambitions. Those goals form the driving force

behind Rabobank: it aims to create opportunities for individuals

and businesses to play an independent and meaningful role in

the economy.

Rabobank provides all financial services needed by customers as

they participate in economic activities in today’s social context.

It has developed into a broad financial services provider in the

Netherlands, seeking to tailor its services in a modern manner

for individuals and businesses in the Netherlands as well as

elsewhere in the world.

Mission Statement

Rabobank was founded in the N

etherlands by enterprising people who had virtually no access to the capital m

arket. It has a tradition in the small and m

edium-sized com

panies segment, especially in the agricultural sector. B

y working on cooperative, or m

utual,

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Rabobank

Rabobank believes that sustainable growth in prosperity and

well-being requires careful nurturing of natural resources and the

living environment. It seeks to contribute to this with its activities.

It respects the culture and customs of the countries where it

operates, insofar as these do not conflict with its own objectives

and core values.

In all its activities, Rabobank will safeguard its solvency and

liquidity as the basis for the continuity of its services to its

customers.

We are highly committed to improving the collective well-being and

increasing prosperity in the Netherlands and to playing a key role in

solving the global food issue: the socially responsible bank

Our goal

We, the employees and directors of Rabobank, have as both

point of departure and primary goals the best interests of our

customers. We aim to create value for them by:

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• Providing those financial services considered best and most

appropriate by our customers.

• Ensuring continuity in the services provided with a view to the

long-term interests of the customer.

• Commitment of the bank to its customers and their

environment so that we can contribute to achieving their

ambitions.

Our source of legitimacy

We are open to the views of those affected by our services.

Customers who express their commitment to the bank in a

membership will gain a say in our direction and the way we

contribute to achieving their ambitions.

Our core values

We believe it is important that customers recognise and

experience the four core values on the following pages in all our

activities.

This is us

Rabobank believes that sustainable growth in prosperity and w

ell-being requires careful nurturing of natural resources and the living environment. It seeks to contribute to this w

ith its activities. It respects the culture and customs of the countries w

here it operates,

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Rabobank

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Core value # 1

Respect

Rabobank works together on the

basis of respect, appreciation and

commitment.

This is us

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Rabobank

Rabobank believes that all its activities

must be carried out with honesty,

sincerity, care and reliability.

Integrity

Core value # 2

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This is us

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Rabobank

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Sustainability

Rabobank is committed to

contributing to the sustainable

development of society in the

financial, social and ecological sense.

Core value # 3

This is us

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Rabobank

Rabobank provides its customers with

high-quality expertise and facilities.

It is committed to maintaining

high quality – whenever possible

anticipating the future needs of

customers – and providing its services

in an efficient manner.

Professionalism

Core value # 4

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This is us

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Rabobank

Rabobank’s mission is to serve the financial interests of its custom

ers. Our cooperative roots ensure that w

e are always inspired and guided by our custom

ers. Our am

bitions and intentions are manifest in the w

ay in which w

e operate. This Code of Conduct

This is how we act

This code* contains the principles for our

conduct as bankers at Rabobank. The

Code of Conduct is an elaboration of the

values set forth in the Mission Statement

and provides guidance as to the manner

in which Rabobank wishes to act vis-à-vis

its customers, members, employees and

society in general.

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Why maintain a Code of Conduct?

Rabobank’s mission is to serve the financial interests of its

customers. Our cooperative roots ensure that we are always

inspired and guided by our customers. Our ambitions and

intentions are manifested in the way in which we operate.

This Code of Conduct sets out the views held within Rabobank

on this. The principles have been formulated for everyone who

has a position with us: employees, directors and supervisors.

Further to the Code of Conduct, specific principles, guidelines

and other detailed rules apply for each focus area and for various

positions.

We are genuinely invested in each other and are keenly aware of

our responsibility.

• Vis-à-vis customers – by providing useful services that help

customers realise their ambitions.

• Vis-à-vis society – by being an involved bank that operates

at the heart of society and is committed to the sustainable

Code of ConductThis is how

we act

* Readopted by the Executive Board in 2015.

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Rabobank

development of prosperity and well-being.

• Vis-à-vis each other as employees – by forming an active

working community that is challenging and provides scope

to develop personal abilities.

These ambitions and commitments are put into effect in the

bank’s actual performance. The objective of this Code of Conduct

is to formulate Rabobank’s views on this topic. The code provides

the basic premises for the required conduct of everyone within

Rabobank: employees, directors and supervisors. The Code of

Conduct also applies to external temporary staff.

These ambitions and com

mitm

ents are put into effect in the bank’s actual performance. The objective of this Code of Conduct is to form

ulate Rabobank’s views on this topic. The code provides the basic prem

ises for the required conduct of everyone within Rabobank:

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The Mission Statement defines the core objective of

Rabobank as producing customer value. Rabobank is

committed to providing its customers with the best possible

financial services based on a favourable price/quality ratio.

This mission ensues logically from the cooperative principles

upon which Rabobank was founded.

This cooperative foundation is characterised by a focus on the

long-term interest of the customer and the readiness to work

together. This structure means that Rabobank sets itself stringent

standards regarding its dealings with customers, members,

employees and society in general.

The way in which Rabobank views its role in the world is largely

determined by its four core values derived from the Mission

Statement.

Core valuesThis is how

we act

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Rabobank

The four core values determine the way in which Rabobank

meets the needs of its customers, its attitude to its

environment and its internal operations. The following

characteristics must be discernible in Rabobank’s conduct.

Rabobank employees are recognisable by conduct that is

aligned with these principles.

Customers and business associates

Rabobank principles

Rabobank aims to serve the interests of its customers by

developing products and providing services. The cost

effectiveness, usefulness, safety and transparency of the product

are of prime importance at Rabobank.

Integrity is a condition of existence for Rabobank. Any action or

cooperation in an action that lacks integrity is refrained from.

Acting with integrity means acting in a way that can be explained

and justified, in accordance with the spirit of the law or policy.

What do these core values mean in practice?

The four core values determine the w

ay in which Rabobank m

eets the needs of its customers, its attitude to its environm

ent and its internal operations. The following characteristics m

ust be discernible in Rabobank’s conduct. Rabobank employees are recognisable by

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The trustworthiness of Rabobank is of prime importance in

relationships with customers and others. Accordingly, we strive

for openness, dialogue, credibility and consistency.

Within the chosen strategic direction, the risks and the impact of

choices on customers and Rabobank are carefully weighed up.

Transparency on charges and terms is the basic principle; no

incomprehensible and unexpected clauses are included in

agreements.

Customers are not to be pressured; Rabobank refrains from using

improper sales motivations and methods.

Negative-approval statements (whereby the customer’s approval

is assumed unless notified otherwise) shall not be included in

price quotations and offers, unless this would be in the express

interest of the customers and involves relatively small amounts of

money.

This is how w

e act

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Rabobank

Rabobank attaches great value to its customers’ assessment of its

services. It is therefore expressly open to this assessment and

incorporates it into the decision-making process. Its customers

and business associates can call Rabobank to account for its

conduct.

Rabobank will not engage in any activities that are designed to

mislead governmental agencies, tax authorities or third parties.

It shall also not participate in the provision of services relating

to funds gained from criminal acts and terrorism.

The confidentiality of customer information must be safeguarded.

Information from and about customers, employees and

Rabobank shall be treated with care and confidentiality.

Any action that evokes the suggestion of a conflict between

private and professional interests must be avoided. All employees

will act professionally, honestly and reliably in internal and

external contacts – without personal interest.

Rabobank attaches great value to its customers’ assessm

ent of its services. It is therefore expressly open to this assessment and incorporates it into the decision-m

aking process. Its customers and business associates can call Rabobank to account for its conduct.

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Accepting or giving personal gifts that could affect the integrity

of business decision-making, are refrained from or reported in

accordance with the applicable guidelines.

All actions must be directly or indirectly aimed at realising a

favourable price/quality ratio for our products and services.

Continuous investments are made in product and service

development in order to realise this, with a focus on functionality

and effectiveness. We conduct all our business operations based

on a prudent approach.

Rabobank aims to always take the lead in developments in the

field of financial services that are relevant for the customer.

Rabobank accepts its primary responsibility for the continuity of

its services. The resources and interests its customers entrust to it

must be handled with the utmost care. Sound business

management establishes the necessary basis for this.

This is how w

e act

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Rabobank

Rabobank works with suppliers and organisations that act

according to the spirit of this Code of Conduct.

Employees of Rabobank

Employees of Rabobank are customer-oriented and

professional in everything they do.

Customer-oriented:

• We know the customer and make a personal connection.

• We advise the customer based on professionalism.

• We always put the customer’s interests first.

• We don’t stop until the customer is satisfied.

• We aim to positively surprise the customer.

Professional in everything we do:

• We handle risks and dilemmas responsibly.

• We carefully consider the interests of stakeholders.

• We are always honest and reliable.

• We accept responsibility and can be held accountable for

this.

Rabobank believes that all sections of society should have access to financial services. It does not exclude anyone from its services, other than on the basis of creditw

orthiness and morality. In developing products and in its services, it takes account of groups in society

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Society

Rabobank principles

Rabobank believes that all sections of society should have access

to financial services. It does not exclude anyone from its services,

other than on the basis of creditworthiness and morality. In

developing products and in its services, it takes account of

groups in society that require special attention.

Rabobank is closely involved in the society in which it operates;

it wishes to be an accepted member of the community.

Rabobank respects human rights. It does not wish to be involved

in matters that infringe upon human dignity.

Rabobank respects the local culture, customs and views and

adheres to them, inasmuch as they do not contradict its mission

and values.

This is how w

e act

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Rabobank

Rabobank is committed to a balanced development of society;

it contributes to promoting a healthy social and economic

climate and to initiatives in the field of self-organisation.

Rabobank takes into account the direct and indirect social

consequences of its activities. In keeping with its aim to achieve

sustainable development of prosperity and well-being,

Rabobank is committed to a responsible approach to nature

and the environment and the welfare of animals. This starting

point applies to both its own performance and the activities it

participates in as a financier/investor/insurer/reinsurer.

Rabobank is committed to playing a facilitating and inspiring role

in investments and transactions that contribute to sustainable

development. It does not enter into any associations that

contravene this.

All legislation, regulations and signed covenants are strictly

adhered to.

Rabobank takes into account the direct and indirect social consequences of its activities. In keeping with its aim

to achieve sustainable development of prosperity and w

ell-being, Rabobank is comm

itted to a responsible approach to nature and the environment and

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In all its activities, Rabobank weighs up the interests of all

stakeholders such as customers, members, bond holders and

other creditors, employees and society.

Employees of Rabobank

Employees of Rabobank are socially involved:

• We actively support the community in which we live.

• We engage customers and members with the bank.

• We share our knowledge and networks with customers and

members.

• We help bring about a better and more sustainable world.

Internal relationships

Rabobank principles

Rabobank is a system of interlocking parts designed to create

customer value. Rabobank offers a safe environment to actively

broach discussion of risks and dilemmas and to cooperate

transparently on responsible solutions. As a learning organisation,

we prevent repetitions of errors by eliminating their causes.

This is how w

e act

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Rabobank

Rabobank is a system of interlocking parts designed to create

customer value. Rabobank offers a safe environment to actively

broach discussion of risks and dilemmas and to cooperate

transparently on responsible solutions. As a learning organisation,

we prevent repetitions of errors by eliminating their causes.

Employees within Rabobank are treated on the basis of mutual

respect characterised by maturity, openness and involvement.

They are given full scope to develop their professional abilities.

Their well-being is of prime importance.

Rabobank is committed to creating a good working environment

that gives employees full scope for personal development. A

criterion for newly recruited employees is that they have the

ability to develop and produce added value within Rabobank

with its specific mission.

Trustworthiness and prudence form the basis for relationships

with employees. This requires the essential elements of openness,

consultation and the fulfilling of agreements.

Rabobank is a system of interlocking parts designed to create custom

er value. Rabobank offers a safe environment to actively broach discussion of risks and dilem

mas and to cooperate transparently on responsible solutions. A

s a learning organisation, we prevent

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Rabobank pursues a responsible remuneration policy that does

not provide incentives to employees to act negligently.

Integrity demands that each employee refrains from abusing the

knowledge and possibilities offered by his or her job within

Rabobank.

Professionalism demands that employees are familiar and comply

with legislation and regulations, internal rules, guidelines and

agreements.

Rabobank believes it is important for employees to pursue social

activities outside of their job; this expands experience and

broadens horizons. However, these activities must not impede

their integrity and objectivity in carrying out their job at

Rabobank.

Employees know and take responsibility for managing the risks

connected with their position.

Rabobank sets store by investing in employees to enable them to

This is how w

e act

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Rabobank

deliver added value. Employees and managers formulate

agreements on targets and mutual expectations and are

accountable for their achievement. If performance is not

(or is prevented from being) effective, steps are agreed that

lead to the desired adjustments.

Cooperation and team spirit are the key factors in creating

a successful working environment within Rabobank.

Rabobank promotes and facilitates mobility in the positions

and work of employees.

Rabobank believes its workforce should represent the broadest

possible cross-section of society. Diversity enhances the quality

of the services.

Rabobank rejects every form of unequal treatment of employees

for which there is no objective and reasonable justification.

deliver added value. Employees and m

anagers formulate agreem

ents on targets and mutual expectations and are accountable for their achievem

ent. If performance is not (or is prevented from

being) effective, steps are agreed that lead to the desired adjustments.

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Rabobank supports the prudent management of raw materials,

energy and resources in its business operations.

Employees of Rabobank

Employees of Rabobank mutually strengthen each other:

• We work to achieve continuous improvements and request

and provide feedback.

• We value different perspectives and diversity.

• We operate on the basis of one Rabobank and across the

boundaries of business units.

• We accept responsibility for a good balance between our

professional and personal life.

This is how w

e act

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Rabobank

Rules often provide clarity. And there are lots of them! Partly due to the huge social interests involved, w

e are faced with m

any laws and rules. These im

pose requirements in term

s of expertise, trustworthiness, reporting, privacy protection and num

erous other areas.

At Rabobank we act in the customer’s interest, we are respectful and professional and act with integrity and on a sustainable basis. But in practice it can sometimes seem impossible to live up to all these aspects all the time. In our work, we will unavoidably be faced with dilemmas. Dilemmas are situations in which different interests compete for priority or conflict with each other. These usually occur in a ‘grey’ area, in which legislation offers insufficient guidance. This means that you must carefully weigh up the arguments for and against and must test them against our guiding principles and core values. Go ahead or not? The right choice is not clear in advance.

It’s like this

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Rules provide clarity

Rules often provide clarity. And there are lots of them! Partly due

to the huge social interests involved, we are faced with many

laws and rules. These impose requirements in terms of expertise,

trustworthiness, reporting, privacy protection and numerous

other areas. We are required to comply with these in any case;

they form a significant baseline requirement. But legislation and

regulations do not always provide an answer. And sometimes we

feel they do not go far enough and we have guidelines of our own.

Questions, questions, questions

If all these rules do not provide a solution to your dilemma, you

can consult the Code of Conduct. This is not the law, not a rule,

not a guideline: it is an aspirational code. It provides direction by

stating which values are important in working at Rabobank.

When you read the Code of Conduct, this will no doubt give rise

to many questions. Such as: How do we develop products that

are professional and sustainable as well as customer-oriented?

When does a product meet these requirements? With which

supplier do I want to do business? Does a specific mode of

How to deal with dilemmas?

It’s like this

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38

Rabobank

operation in fact attest to respectful conduct? When am I acting

with integrity, and when am I not? Questions, questions, questions.

And the Code of Conduct does not provide an answer. Because

every situation is different and every answer is required to do

justice to the specific circumstances in the situation concerned.

Major responsibility

Therefore everyone within Rabobank has a major responsibility.

We expect employees to be professionals who can themselves

best decide what the right choice is. But no one is always right.

Therefore discuss your dilemma with others in case of doubt.

To that end it is important to have an open working atmosphere

in which even difficult topics can be broached for discussion.

In which you are free to voice your doubts and in which you help

each other as a matter of course to achieve the best result. That

open culture is an additional responsibility of the manager. He or

she leads by example. Even more than a paper Code of Conduct,

his/her words and deeds will determine what employees

experience as a guiding framework. Together we develop ways

for ensuring a responsible approach to the moral tensions of our

daily work.

Therefore everyone within Rabobank has a m

ajor responsibility. We expect em

ployees to be professionals who can them

selves best decide what the right choice is. B

ut no one is always right. Therefore discuss your dilem

ma w

ith others in case of doubt. To that end it

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39

1. What is the dilemma?

Try to define the dilemma as clearly as possible by highlighting

its different sides. I can do this, because … it is not justifiable,

because…

2. Who are the stakeholders?

A dilemma involves direct stakeholders, but there are always also

indirect interest groups. The taxpayer, for instance. Be sure to

consider all of them comprehensively. This will highlight the

interests you need to take into account in your considerations.

3. Are there relevant rules, guidelines or agreements?

Often there are laws and regulations we are required to comply

with. Check whether they can help with your dilemma. Also take

the Code of Conduct and agreements into account

4. Which arguments for and against are there?

Prepare an overview of all pros and cons. This will reflect all

stakeholders, codes and relevant guidelines.

Towards a solution step by step

It’s like this

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40

Rabobank

5. What is my conclusion?

You can arrive at a thoroughly considered conclusion by

establishing which arguments carry the greatest weight. Try to

think through alternative solutions as well, which may enable you

to mitigate or in fact avoid the problem.

6. Will I go ahead?

Review your final conclusion in terms of questions such as: do I

fully support this conclusion, can I explain the result and does the

conclusion do justice to the standards and values of Rabobank? I

am not alone in this.

You can arrive at a thoroughly considered conclusion by establishing which argum

ents carry the greatest weight. Try to think through alternative solutions as w

ell, which m

ay enable you to mitigate or in fact avoid the problem

. Review your final conclusion in term

s

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41

Please realise that if you have questions, doubts or if you want to

discuss a certain case or dilemma, you can be confident you are

not alone.

Any employee who believes he/she is witness to or a victim of

any type of inappropriate behaviour, should and is urged to

report or complain as soon as possible according to the local

(regulatory) policy.

International colleagues in the Netherlands can consult their

supervisor or a trusted person. The Meeting Point intranet site’s

‘Speak Up’ button also offers access to the applicable English

versions of the reporting processes in the Netherlands.

International colleagues abroad can also use the ‘Speak Up’

button or click on their location on the world map for the

applicable processes or consult their local intranet site or a

person of authority.

You are not aloneIt’s like this

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42

Rabobank

A person of authority with whom you feel comfortable may be

your direct supervisor, a trusted person (internal or external), an

officer in the Human Resources, Compliance or Legal

departments or a member of Senior Management.

The Ethics Office may be a valuable sparring partner on dilemmas

in the Netherlands but also abroad.

The Compliance O

fficer supports the business in safeguarding and promoting the integrity and the reputation of Rabobank associated w

ith it. That is the mission of com

pliance. The Compliance O

fficer does this by informing and advising m

anagement and em

ployees,

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43

The Compliance Officer supports the business in safeguarding

and promoting the integrity and the reputation of Rabobank

associated with it. That is the mission of compliance. The

Compliance Officer does this as a sparringpartner and by

informing and advising management and employees, carrying

out investigations and reporting to the Board of Directors or

Executive Board and the Supervisory Board. The goal is to

promote a culture centred on acting with integrity. There are

four focus areas for compliance:

Responsible services

Are customers given suitable advice and is the product

information for the customer understandable and not

misleading?

Customer integrity

Do we know our customers and are we sure that we are not

working with parties that engage in money laundering or other

punishable activities?

What does the Compliance Officer do?

It’s like this

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44

Rabobank

Employee integrity

Are personal interests and the bank’s interests sufficiently

segregated (for instance, outside interests, donations, insider

trading)?

Design of the organisation

Are conflicting interests sufficiently managed in the bank

organisation?

In addition, the Compliance Officer will also be called on for

incidents that can harm the bank’s reputation.

Want to know more about Compliance?

Contact: your (local) Compliance Officer

Every employee at Rabobank w

ho is faced with an ethical dilem

ma can call on the Ethics O

ffice. Even after the event. If possible, you will receive a sw

ift answer to your question, for instance on the basis of com

parable cases in practice. The Ethics Office subm

its issues

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45

Every employee at Rabobank who is faced with an ethical

dilemma can call on the Ethics Office. Even after the event. If

possible, you will receive a swift answer to your question, for

instance on the basis of comparable cases in practice. The Ethics

Office submits issues that are relatively complex to the Ethics

Committee. Specifically, the duties of the Ethics Office and the

Ethics Committee are:

• assessing situations occurring in practice and weighing these

up by reference to the standards and values of the bank;

• publishing considerations and advice, so that the bank’s

position is clear to everyone;

• strengthening employees’ self-confidence when faced with

dilemmas;

• discussing social issues that call for a normative position on the

part of the bank.

The Committee does not just provide advice on specific cases but

also adopts views on social topics that are relevant to our business

operations. These include human rights, the arms industry, nuclear

energy, genetic modification and biofuels.

What does the Ethics Office do?

It’s like this

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46

Rabobank

Assessment by the Committee

The Ethics Committee carries out assessments by reference to the

legal framework, our own Code of Conduct and related conduct

guidelines and the external conduct rules to which we have

committed ourselves. The Committee also considers a range of

different viewpoints and research findings of authoritative

organisations and interest organisations in arriving at its opinions.

On that basis the Committee carefully weighs up the pros and

cons and takes a position or issues advice to the submitting party.

The composition of the Committee

Many of the disciplines within Rabobank are represented in the

Committee in order to be able to form an opinion that is as

thoroughly considered as possible. The Chairman of the

Executive Board is also the Chairman of the Ethics Committee.

Want to know more about the Ethics Office?

Contact: [email protected]

The Ethics Comm

ittee carries out assessments by reference to the legal fram

ework, our ow

n Code of Conduct and related conduct guidelines and the external conduct rules to which w

e have comm

itted ourselves. The Comm

ittee also considers a range of different

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47

If you are faced with a dilemma at work, you can also present it to

a trusted person.

Most of the local Rabobanks, entities and departments with

Rabobank have appointed a trusted person. This is someone

you can trust with your queries and concerns and who can

advise you on how you can resolve the problem or dispute.

Specifically, a trusted person can do the following for you:

• Provide initial assistance.

• Listen to you.

• Inform you of options for resolving the problem internally or

externally.

• Refer you to an HR professional.

• Refer you to an adviser under one of the three regulations in

place in the Netherlands.

What does the Trusted Person do?

It’s like this

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48

Rabobank

The three regulations in place in the Netherlands are:

1. Geschillenregeling Arbeidsverhoudingen

(Industrial Relations Disputes Procedure)

For (potential) disputes in the fields of work, working conditions

and terms of employment.

Contact: [email protected]

2. Klachtenregeling ongewenste omgangsvormen

(Complaints procedure for undesirable behaviour)

For (sexual) harassment, bullying, aggression, violence and

discrimination.

Contact: [email protected]

Most of the local Rabobanks, entities and departm

ents with Rabobank have appointed a trusted person. This is som

eone you can trust with your queries and concerns and w

ho can advise you on how you can resolve the problem

or dispute. Specifically, a trusted

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49

3. Whistleblowing Policy

For reporting irregularities or abuses to the external

trusted person.

Contact: [email protected],

telephone +31(0)6 51 51 18 66

* International colleagues abroad please refer to page 41.

It’s like this

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50

Rabobank

In this booklet we have set out how

we think and act as Rabobank. B

y signing the bankers’ oath we dem

onstrate that the customer’s interest is our interest. After all, w

e are invested in each other. In this booklet we have set out how

we think and act as Rabobank. B

y

In this booklet we have set out how we think and act as Rabobank. By signing the bankers’ oath we demonstrate that the customer’s interest is our interest. After all, we are invested in each other.

Naturally there may sometimes be conflicts of interest and we may be faced with moral or ethical dilemmas to which rules do not provide an immediate answer.

Discuss them with managers and your colleagues!

That’s how

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51

BANKERS’ OATHEMPLOYEE

I promise within the limits of my role that I perform at any moment in the banking sector:

• that I will perform my duties with integrity and care;

• that I will carefully consider all the interests involved in the company, i.e. those of the clients,

the members, the employees and the society in which the company operates;

• that in this consideration, I will give paramount importance to the client’s interests;

• that I will comply with the laws, regulations and codes of conduct applicable to me;

• that I will observe con� dentiality in respect of matters entrusted to me;

• that I will not abuse my knowledge;

• that I will act in an open and assessable manner and I know my responsibility towards society;

• that I will endeavour to maintain and promote con� dence in the � nancial sector.

This I declare and promise!

Furthermore, I con� rm that I will comply with the rules of conduct and abide by the enforcement

of the rules of conduct and the exercise of authority pursuant to the disciplinary scheme.

The a� rmation was made in the above form

on , at ,

before .

Employee

Employed at

Signature

Dutch Bankers’ O

ath

51

Dutch Bankers’ Oath

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Colophon

Published by

Rabobank, Executive Board and Cooperative Affairs & Governance

12105

May 2015

Contact

[email protected]

Design

Volta_thinks_visual

Illustrations

Aron Vellekoop León

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De gedragscode laat zien w

ie we zijn: onze w

aarden, houding en gedrag. En met w

e bedoel ik niet de individuele medew

erker, maar w

ij als collectief van medew

erkers van de Rabobank. Met de gedragscode als referentie kunnen w

ij ons spiegelen aan wat w

ij van

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============================================================================================================================

============================================================================================================================Working in an open culture is not only pleasant, it also benefits the quality of our work. You feel free to broach sometimes difficult issues, to provide feedback, to express doubts, to voice opinions. All of these contribute to a better result. You will benefit from this yourself, so will the bank and so, last but certainly not least, will the customer, on whom all our

www.rabobank.com

The Code of Conduct shows who we are: our values, attitude and conduct. And by ‘us’ I do not mean the individual employee, but us as a collective of employees of Rabobank. With the Code of Conduct as a reference, we can compare ourselves against what we expect of each other. With regard to customers, society and each other. The code provides guidance, but