code of conduct - rabobank · the code of conduct shows who we ... by working together, ......
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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
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
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
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
2
Rabobank
4 Foreword Wiebe Draijer
Core values
This is us Mission Statement
9
12
Contents
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?
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.”
5
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.
6
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
7
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
8
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
9
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,
10
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:
11
• 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,
12
Rabobank
13
Core value # 1
Respect
Rabobank works together on the
basis of respect, appreciation and
commitment.
This is us
14
Rabobank
Rabobank believes that all its activities
must be carried out with honesty,
sincerity, care and reliability.
Integrity
Core value # 2
15
This is us
16
Rabobank
17
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
18
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
19
This is us
20
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.
21
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.
22
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:
23
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
24
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
25
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
26
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.
27
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
28
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
29
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
30
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
31
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
32
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
33
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
34
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.
35
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
36
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
37
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
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
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
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
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
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,
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
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
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
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
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
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
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
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
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
Colophon
Published by
Rabobank, Executive Board and Cooperative Affairs & Governance
12105
May 2015
Contact
Design
Volta_thinks_visual
Illustrations
Aron Vellekoop León
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