Compliance is an important part of good corporate governance. NIBC is committed to comply with relevant laws, regulations and professional standards in each of the markets in which it operates and protecting the integrity of the financial system. We also are committed to comply with internal standards and values as defined in NIBC’s Code of Conduct, business principles and policies.
The Managing Board of NIBC is ultimately responsible for ensuring adequate compliance within NIBC. Managing compliance risk and complying with applicable laws, regulations and standards in both personal and business conduct is the responsibility of every employee or contractor working for NIBC. Regular training and updates are provided to our staff in order to maintain awareness and address any emerging areas of concern.
Important national and international/European regulations applicable to NIBC include the Dutch Financial Supervision Act (Wft), anti-money laundering laws such as Wwft and AMLD4, as well as a.o. MiFID II, FATCA/CRS, GDPR and MAD/MAR.
Client Due Diligence
To enable a proper assessment of the risks involved in a customer relationship, NIBC needs insight into clients’ backgrounds, their business and other activities. It is also essential to know why clients use specific products and where their funds or wealth comes from.
NIBC’s Client Due Diligence (CDD) processes aims to safeguard NIBC and the financial markets from integrity risks and helps to prevent money laundering, terrorist financing and reputational risks.
Anti-Fraud, Bribery and Corruption
NIBC’s staff is obliged to report actual or suspected fraud or misconduct. We do not accept nor tolerate any instance of fraud, bribery or corruption. Genuine concerns are handed fairly and investigated appropriately. Concerns may be reported anonymously in accordance with our Whistleblower policy or our Complaints procedure.
NIBC strongly values the reputation and integrity of the bank and its employees. It supports and protects the reporting of wrongdoing. Since employees are usually the first to recognise wrongdoings, like misconduct, fraud and corruption, NIBC promotes a “speak-up” culture and is committed to ensure that there is a climate of transparency in which employees can voice genuine concerns safely and without fear of reprisal.
Conflicts of Interest
We have a strong Conflicts of Interest policy in order to ensure that any (potential) conflicts are identified in a timely manner and adequately managed. We prevent and manage conflicts by means of an internal control framework which includes policies and procedures as well as systems and controls.
NIBC aims to be transparent about our position on tax. Activities, products and transactions including their purposes should be reasonably explainable to our clients, tax authorities and the general public. Tax cannot be the only purpose for a product or transaction. Our approach is applied through NIBC’s internal policies, procedures and due diligence.
NIBC applies a Sanctions policy sets out principles and measures to ensure compliance by NIBC with all relevant sanction laws, including EU, Dutch, German, UK, Belgian, and US sanctions.
We have robust data protections in place and comply with regulations in regard to data privacy such as GDPR. NIBC invests in cybersecurity safeguards and has policies and controls in place to protect our clients and their data. We continuously test and monitor systems for vulnerabilities and to prevent attacks. When data breaches are detected, those people who are impacted are notified in a timely manner.
Information security, data protection, and cybersecurity are essential to NIBC’s business continuity management. We manage information according to the need-to-know principle and establish controls through segregation of duties. NIBC works closely with national authorities, peer banks, and other parties in each of the markets in which it operates to protect people, mitigate cyberrisks and ensure the integrity of the financial system.