Human rights and arms industry
Anti-corruption
Moral and ethical declaration
exceptional and vulnerable position, and is incapable of sorting out the situation. There is no
perspective of a new home. The branch wants to look after its customer without creating a
precedent. The bank's duty of care, humane aspects and reputational risk came into play in this
case. In the Committee's opinion, the branch had an obligation to find an acceptable solution,
for instance by initiating a dialogue with the housing association and the local authorities.
The Committee also felt that the customer could not, in any event, be allowed to continue to
own the property. For this reason, the Committee asked the local Rabobank in question to
explore further options for minimising the losses on the sale of the house as much as possible.
Although this was an exceptional case, there is a chance of similar circumstances given the
current economic situation. This case is illustrative for the broader public debate about the
role and duty of care of banks in this day and age.
Another example of a dilemma addressed by the Ethics Committee was a loan application for
a number of ships that will be used as patrol and fast interceptor vessels in the territorial
waters of a South American country. This country is fighting drug smugglers and drug cartels,
and wants to use patrol and fast interceptor vessels to protect its coastal waters. Rabobank
Group's policy for the arms industry sets criteria for how to assess a loan application such as
this one. Among other provisions, the policy stipulates that human rights should not be
violated, nor is the equipment to contribute to the provocation of conflict or the rise of
tensions that might adversely affect the peace, safety and stability in the region. The vessels in
question are civilian objects; they do not carry any military equipment and they will be used
to protect the coastal areas of the country. The Ethics Committee ruled that the export
transaction involving ships for this South American government was acceptable at that time.
Rabobank Group's human rights policy (including labour rights) was updated at the end of
2011. This policy is in keeping with the United Nations'international human rights framework
for corporations. This policy was further integrated into Rabobank's supply chain policy in the
year under review. In addition, the policy was transposed to the local Rabobanks to help them
address the current abuses and risks in mushroom farming and irresponsible ship scrapping.
The further implementation of this policy will be fleshed out in 2013.
Investments in cluster munitions have been legally banned since 1 January 2013. Rabobank
updated its arms industry policy to reflect these new rules. The policy was tweaked also in
respect of controversial regimes. Rabobank wants no involvement whatsoever with such
regimes. Regimes qualify as controversial if they are subject to an arms embargo as well as to
financial sanctions and travel restrictions imposed by the United Nations, the United States
and/or the European Union.
The group-wide anti-corruption policy was updated in 2012 to fall in line with the provisions of
the British Bribery Act. Flaving been a member of the United Nations Global Compact ('UN GC')
since 2002, Rabobank is not only committed to avoiding bribery, extortion and other forms of
corruption, but it has also undertaken to develop policies and concrete programmes to address
corruption (based on the tenth principle of the UN GC). Rabobank has shared its knowledge
of, and approach to, anti-corruption with the UN GC so that others can use it to their benefit.
On 1 January 2013, the moral and ethical declaration came into force for executives and
non-executives as part of their suitability check. At Rabobank Nederland, the qualifying
persons are the members of the Executive Board and the members of the Supervisory Board.
The members of the Management Teams and Supervisory Committees of the local Rabobanks
are also required to make the declaration. Rabobank started to ask these persons to make the
moral and ethical declaration in mid-December 2012. In the course of 2013, the Dutch Ministry
of Finance will issue detailed recommendations for the introduction of the declaration for
other staff and the sanctions that will be imposed for non-compliance. As far Rabobank is
concerned, the declaration is perfectly in keeping with its cooperative identity enshrined in
the Ambition Statement and the related behaviours described in the Code of Conduct.
What is more, the moral and ethical declaration is inherent in cooperative banking practices.
25 Sound sustainability policy
