Advertising Code Committee Private individuals and corporations can submit complaints about advertisements to the Dutch Advertising Code Committee. During 2010, a total of six complaints were submitted in connection with statements made by Rabobank, Robeco, De Lage Landen, Obvion and Rabobank International. In three instances, the Committee ruled in favour of the client. The other complaints were rejected. Netherlands Authority for the Financial Markets In 2009, as part of a sector-wide survey, the Netherlands Authority for the Financial Markets (AFM) reviewed how Rabobank has interpreted the rules for mortgage advice. AFM went on to raise a penalty of EUR 150,000 against Rabobank in 2010. AFM concluded that Rabobank would grant well-educated, young first-time buyers slightly higher mortgages because of their jobs and education, and their promising perspectives on the labour market. AFM felt that Rabobank did not have enough regard for the customer's individual circumstances. AFM also established that, when advising clients about life insurance and incapacity insurance policies, Rabobank does not go into sufficient detail, and that arrangements made with clients should be documented better. In Rabobank's opinion, well-educated first-time buyers who have a good job were not automatically offered a higher mortgage. Loan applications were consistently followed by a broad and in-depth consultation with the client, and decisions on potential increases in a client's income were always taken in dialogue with them.The basis for this process was data published by Statistics Netherlands and the bank's empirical knowledge. In Rabobank's experience, this group of first-time buyers is particularly well equipped to bear higher mortgage costs. AFM's decision forced Rabobank to revise its policies, which have now been amended. With a view to expected legislation, Rabobank has chosen not to appeal the penalty imposed by AFM. AFM claims that Rabobank did not document clearly enough, in advising clients on their life insurance and incapacity insurance policies, what the exact considerations were that led up to the insured amount. Rabobank feels that it has provided its clients with appropriate advice on these insurance policies. Any arrangements made with clients were documented in their files. The products were transparent and offered value for money. Rabobank has also adjusted its procedures in this respect. Balanced advisory model With regard to charges and fees for services provided to clients, Rabobank aims to charge amounts that are appropriate to the service provided. In 2011, the relevant subjects will be identified in further detail. Secure banking Safety, security and privacy Rabobank gives high priority to the safety, security and privacy of clients and employees. In connection with this, a number of long-term ICT and other programmes have been introduced to improve the quality of logical access control and the security of virtual channels. Employees are given specific training on security risks and desirable behaviour. During 2010, Rabobank updated the ICT Code of Conduct. New additions to the code include rules governing the use of online media for communication. In this way, we are preparing our employees to work and communicate securely in an increasingly digital society. Clients can go to www.rabobank.nl for advice on security aspects of online banking and mobile banking. In addition, Rabobank has actively contributed to the launch of a new 'secure banking'campaign by the Dutch banks. Cyber crime Rabobank pays constant attention to cyber crime, a form of fraud that primarily targets online banking. We invest heavily every year in maintaining the security of virtual channels. In 2010, the quality of monitoring improved sharply. This has put Rabobank in a better position to detect and stop fraudulent transactions. 16 Annual Report 2010 Rabobank Group

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Annual Reports Rabobank | 2010 | | pagina 17