Dutch Banking Code
Background
The Banking Code 2010 is a form of self-regulation, which came about based
on the report of the Advisory Committee on the Future of Banks. The main
focus of the principles in this bank-specific code is on strengthening the
governance within banks, risk management, audit and the remuneration
policy.
A new Banking Code was presented in October 2014, as part of the Future-
oriented Banking package.The updated Banking Code - in conjunction with
the Social Charter and the introduction of the bankers' oath, rules of
conduct and disciplinary rules - is designed to make a major contribution to
public trust in banks within society and their role in society.The principles
from the 'old' code that have already been embodied in legislation and
regulations are not repeated in the new Banking Code.The banks, and
therefore also Rabobank, will continue to comply with these national and
international regulations as a matter of course.The updated Banking Code
became effective on 1 January 2015.
This chapter looks at the context in which the provisions of the current Banking Code have
been applied in 2014, and briefly describes how the provisions have been implemented.
Compliance by Rabobank with the provisions of the Banking Code is based on the 'comply or
explain' principle. Further information concerning the particulars of each provision can be
found in the appendix 'Compliance with the Banking Code'to this Annual Report that is
available on www.rabobank.com.
Scope of Dutch Banking Code
Local Rabobanks
The local Rabobanks occupy a special position in the Banking Code, as they are not required to
apply the Code on an individual basis. Specifically, this means that the principles in sections 1, 2
and 3 (principle of comply or explain, supervisory board and executive board) do not apply to
the individual local Rabobanks. 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.
Chapters 4, 5 and 6 (risk management, audit and remuneration policy) have been applied
indirectly to individual local Rabobanks in the form of Group-wide policy.
Subsidiaries and other group entities
The Banking Code applies only to banks with a registered office in the Netherlands.
Within Rabobank, this includes only FGH Bank (part of Rabo Real Estate Group) and DLL.
Rabo Real Estate Group reports separately on the application of the Banking Code on its
139 Dutch Banking Code
