Our compliance function aims to promote and ensure that our bank complies with laws and regulations, as well as with the internal procedures and rules of conduct that are relevant to the organisation’s integrity and associated reputation and to the integrity of the financial system as a whole. The compliance function reports directly to the Executive Committee and has direct access to the chair of the Supervisory Board.
Customer Due Diligence
Customer Due Diligence information comprises the facts about a business relation that enables us as a bank to assess the extent to which the business relationship exposes us to integrity risks, such as money laundering, terrorist financing and the circumvention of sanctions regulation. At the start of a business relationship we verify the identity of business relations and we gather information related to, amongst others, the nature and intent of the relationship as well as to the ownership and control structure. This gathering of data constitutes the foundation for the risk assessment that takes place at the start of a business relationship and during the life of the business relationship with NWB Bank. Detailed CDD requirements are laid down in our CDD Policy and Procedure. The result of successful customer due diligence is that we know with whom we are doing business and that relevant risks have been identified.
Anti-Bribery and Corruption
We have a zero-tolerance policy when it comes to bribery and corruption, regardless of the identity or job title of the person who offers or receives the bribe or is otherwise engaged in fraudulent activity. An Anti-Bribery and Corruption Policy is in place which sets out the high-level principles and standards for the management of the risk of corruption and bribery as well as to encourage staff members that have a suspicion of bribery or other form of corruption within or related to NWB Bank, to report this suspicion. We will never offer inappropriate commission, or anything that could be interpreted as such, to anyone or for any purpose.
Conflicts of Interest
We have a Conflict of Interest policy in place in order to ensure that any (potential) Conflicts of Interest are identified in a timely manner. Once identified, Conflicts of Interest are either prevented or, when they cannot be prevented, managed and mitigated. To this extend, hawse have implemented appropriate means such as policies and procedures, systems and control.
We have the regulatory obligation to take measures to ensure controlled and sound business operations and to prevent involvement in financial and economic crime, including money laundering related to tax evasion. Although not illegal, we also seek to gain insight into potential risks of tax avoidance among our business relations as its harmful effects could certainly damage our reputation as well as the confidence in the Dutch financial sector.
We ensure compliance with applicable sanctions regulations through, among others, screening against official sanctions lists (NL, EU, UN and OFAC).
Privacy and Data Protection
Information security, data protection, and cybersecurity are essential to our business continuity management. Our clients, employees and suppliers must be able to rely on their data being kept safe at the bank. A robust set of control measures is in place to ensure that our digital infrastructure functions properly at all times. To that end, we comply with the General Data Protection Regulation (GDPR), which entered into force in 2018.
To enable employees to report any suspicions of general, operational or financial irregularities within our bank without endangering their legal position, we have a whistle-blower scheme. Employees may choose to report a matter to their direct line manager or to another line manager at the bank who holds a position similar to or more senior than the employee in question. Employees may also take their reports to the compliance function.
Code of Conduct & Bankers Oath
Since April 2015, all internal and external employees (that work for our bank for more than three months) are required to take the Banker’s Oath. By taking the Bankers Oath, employees explicitly swear or promise that they will draw a careful balance between the interests of all parties associated with the business.
Those who commit themselves to the Oath also adhere to the Code of Conduct. The Code of Conduct outlays the most essential principles, standards, and the moral and ethical expectations that employees are held to.