RBI Group's ABC programme

In line with RBI Group's CoC RBI Group follows a zero tolerance policy, when it comes to unlawful or unethical business behaviour, such as bribery and corruption (B&C) and does not participate in any transaction in which there is a reason to believe that B&C is involved. RBI Group commits to proactively combat B&C in the environment RBI Group operates.

To ensure the right level of attention and importance of RBI Group's ABC programme, management functions / Management Boards of RBI Group units periodically promote and endorse relevant ABC activities and initiatives e.g. by taking part in internal / all staff communication initiatives, etc. 

RBI Group's ABC programme builds upon clear and concise policiesas well as other written internal procedures. All policies must be in line with the relevant local legal or regulatory framework.

All RBI Group employees as well as management functions must undergo periodically ABC training activities and programs to establish and maintain a high level of awareness for B&C risks and to inform employees / management functions about their role and responsibilities within the ABC programme.

Key pillar of RBI Group's ABC programme is - in line with the methodology and standards of RBI Group's Operational Risk Controlling Management Framework - a holistic and periodic risk assessment of B&C risks for all relevant business lines and processes. The periodic risk assessment is giving a comprehensive picture of which parts of the business lines and processes might be most vulnerable to corrupt practices and whether the controls in place mitigate existing inherent risks. In addition to that, also ad-hoc risk assessments may be conducted, e.g. based on new or changed processes, products or upon occurrence of special incidents.

All RBI Group units perform regular controls to prevent, mitigate or detect B&C risks. Key control process that may be executed by First- (e.g. Human Resources, Procurement etc.) or Second Line of Defense functions (e.g. Compliance) i.a. include:

1. Conflict of interest disclosure and assessment process (mandatory reporting of gifts / invitations offered / received, professional activities, close relationships, economic interests etc.);
2. Expense reimbursement controls (e.g. invoices for entertainment expenses are matched with related compliance disclosures);
3. Know-your-customer checks / customer due diligence (e.g. before onboarding, based on specific triggers);
4. Know-your-employee checks (e.g. before onboarding, based on specific triggers);
5. Know-your-business partner checks (e.g. before onboarding, based on specific triggers);
6. Compliance check / mandatory Compliance involvement for contributions to external parties (e.g. sponsorships, donations, membership fees exceeding defined thresholds or based on specific triggers are checked by Compliance).

In line with RBI Group's corporate values a strong cooperation and ongoing exchange between all RBI Group units facilitates experience sharing, allowing to constantly improve and enhance RBI Group's ABC programme.

The local Compliance function within all RBI Group units has a direct reporting line to the local management and periodically reports about incidents, gaps or general developments with regards to the ABC programme in their unit. Group Compliance periodically reports to RBI Group's management and supervisory board.

RBI Group strives to promote a compliance culture allowing employees to work in a safe and ethical organization. This includes bringing forward any potential breaches of RBI Group's CoC or regulatory requirements. Addressing wrongdoings is essential for the security and development of RBI Group, however, may be difficult for various and valid reasons. For this purpose RBI Group established a whistleblowing program that provides different ways to raise concerns, including the possibility to report anonymously.

In line with RBI Group's zero tolerance policy for B&C all employees and management functions are held accountable for their actions or potential omissions resulting in violations of RBI Group's ABC programme. In such events internal sanctions and disciplinary measures - irrespective of any potential criminal law sanctions or other legal consequences - will be adequately applied and enforced.