Banking Code
Scope Banking Code
Subsidiaries
Background
The financial crisis that began in mid-2007 led to a profound social debate on the performance
of financial institutions. In the Netherlands, the Advisory Committee on the Future of Banks
took the lead in this debate by publishing a report entitled 'Restoring Trust' (Naar herstel van
vertrouwen) on 1 April 2009. The banking industry held follow-up talks on this matter, in
which Rabobank actively participated. These talks led to the publication of the Dutch Banking
Code, which was adopted by the Dutch Banking Association on 9 September 2009 and came
into effect on 1 January 2010. The Banking Code is enshrined in law.
The Banking Code forms part of a set of national, European and international laws and
regulations, case law and codes, which is still being developed. Banks have to take this entire
framework into account when applying the Banking Code.
The purpose of the Banking Code is to provide banks in the Netherlands with points of
reference to be used for the organisation of their governance, risk management, audit
function and remuneration policy. At the same time, it provides third parties with a tool they
can use to ascertain whether banks have taken proper steps in response to the financial crisis.
The Banking Code is intended to help restore confidence in the financial sector.
Rabobank naturally endorses the Banking Code and believes it is important that the sector
improves the organisation and operation of internal functions. Improvements are required in
terms of both culture and structure. Rabobank values transparency, and while it weathered the
financial crisis entirely on its own, without any state support, it believes that more information
needs to be provided to the public.
Rabobank will apply the Banking Code in its entirety. This section looks at the context in
which the provisions of the Banking Code are being applied, and briefly describes how the
provisions are being implemented. The provisions of the Banking Code are implemented on
the basis of the'comply or explain'principle. Detailed information on each provision can be
found on our website at www.rabobank.com/annualreports.
Local Rabobanks
A policy is in place at Rabobank Group to ensure the group-wide application of the Banking
Code for all group entities established in the Netherlands, including the local Rabobanks.
This policy covers, among other things, risk management, audits and remuneration. Given
the governance structure of the consolidated Rabobank Group, in instances where the
Banking Code refers to the Executive Board and the Supervisory Board this refers to the
bodies of Rabobank Nederland, not the Management Teams and Supervisory Committees
of the individual local Rabobanks. The Banking Code therefore does not apply by law to the
local Rabobanks.
At Rabobank Group, Robeco and Rabo Real Estate Group report separately on the application
of the Banking Code. As De Lage Landen does not publish an annual report of its own,
reporting on the application of the Banking Code at De Lage Landen has been consolidated
in this Annual Report. Considering the group policy on risk management, audits and
remuneration, De Lage Landen complies in full with the relevant provisions of the Banking
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Annual Report 2010 Rabobank Group
