Scope of Dutch Banking Code
Local Member Rabobanks
Rabobank Group applies a policy for the group-wide application of the Dutch Banking Code
in all group entities established in the Netherlands, including the local Member Rabobanks.
This policy covers such aspects as risk management, audit 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 local board of directors and local Supervisory Board. The Banking Code therefore does
not apply to the individual local Member Rabobanks.
Subsidiaries and other group entities
At Rabobank Group, Rabo Real Estate Group reports 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, audit and remuneration, De Lage
Landen complies in full with the relevant provisions of the Banking Code. The composition and
modus operandi of the Supervisory Board of De Lage Landen reflect the fact that De Lage
Landen is a wholly owned Subsidiary of Rabobank Nederland. Friesland Bank merged with
Rabobank in 2012. It will be some years before Friesland Bank has been fully integrated into
the organisation. Because of the integration process, Friesland Bank is unable to apply all the
principles of the Banking Code. It does not comply with sections: 2.1.5, 2.1.8, 2.1.9, 2.1.10, 2.2.1
3.1.3, 3.1.4, 3.1.6, 3.2.2,4.1 and 4.2 (see the separate appendix to this Annual Report that is
available on the corporate website).
Rabobank: customer interests and risk management as guiding principles
Rabobank naturally endorses the Banking Code and it believes the Code is an important
guideline for the sector to improve the organisation and operation of internal functions.
Governance: Executive Board
The main subjects covered in this section of the Banking Code are the duty of care (Treating
Customers Fairly (TCF)) and the moral and ethical conduct declaration.
Treating customers fairly
As a cooperative, Rabobank places customer interests at the heart of its service provision.
It is Rabobank's ambition to provide customers with the best possible service, while exercising
due care and treating them fairly. This has been enshrined in the Rabobank Group Code of
Conduct and the Rabobank Ambition Statement. Rabobank has a cooperative structure with
autonomous banks whose conduct in respect of their customers is based on the three pillars:
involved, nearby and leading. As every local member Rabobank has established a Members
Council, customers have influence and a voice regarding the course of the Local Member
Rabobank. In addition, the local Supervisory Boards oversee the actions of the local Rabobanks,
to ensure that they are in the customers' best interests. These are the essential aspects of the
local governance at local Rabobanks that guarantee customer focus.
The central policy that is proposed and implemented by Rabobank Nederland is only
implemented after being approved by the permanent representatives of the local
Supervisory Boards and the Local board of directors. As a result, the voice of the customer
is heard in group-level decisions as well. Rabobank's unique cooperative governance is
described in greater detail in the chapter on Corporate Governance.
Annual Report 2013 Rabobank Group
