Dutch Banking Code
Scope of the Dutch Banking Code
Background
The financial crisis that began in mid-2007 led to a profound public 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 various 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 (NVB) 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, parts of which are still being developed. Banks have to take
this entire framework into account when applying the Banking Code.The Banking Code
contains provisions on the structure of a bank's 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 the right steps in response to the financial crisis.
The Banking Code is intended to help restore trust in the financial sector.
Rabobank fully complies with the Dutch Banking Code. This section looks at the context in
which the provisions of the Banking Code are applied, and briefly describes how the provisions
have been implemented. Compliance with the Banking Code is based on the 'comply or
explain' principle. Rabobank values transparency and clear accountability. Further information
concerning the particulars of each provision can be found in a separate appendix to this
Annual Report that is available on our website: www.rabobank.com/annualreports.
Local Rabobanks
A policy is in place at Rabobank Group to ensure the group-wide application of the Dutch
Banking Code in all group entities established in the Netherlands, including the local
Rabobanks. This policy covers such aspects as risk management, audits and remuneration.
Given the structure of Rabobank Group, in instances where the Banking Code mentions the
executive board and the supervisory board, this refers to the bodies of Rabobank Nederland
rather than to the management teams and supervisory committees of the individual local
Rabobanks. The Banking Code therefore does not apply to the individual local Rabobanks.
Subsidiaries
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 Code. The composition and
performance of the supervisory board of De Lage Landen reflects the fact that De Lage Landen
is a wholly owned subsidiary of Rabobank Nederland.
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Annual Report 2011 Rabobank Group
