Compliance
Trust and integrity are essential for ASN Bank as a sustainable financial services provider and form the foundation for carefully serving the long-term interests of customers.
Our Values and banker's oath
ASN Bank is committed to a sustainable and fair future for everyone and adheres to three core values: Frank, Personal and Entrepreneurial. All employees take the banker's oath and annually sign ASN Bank's Code of Conduct. By taking the banker's oath, they confirm their personal responsibility for complying with the sector-wide code of conduct of the Dutch Banking Association (Nederlandse Vereniging van Banken), which is in line with our Code of Conduct.
Common sense as a guide
Rules provide guidance, but cannot anticipate everything. ASN Bank expects employees to be guided by their common sense and encourages an open (risk) culture in which dilemmas can be discussed freely and dialogue can be conducted without hesitation. A healthy risk culture enables employees to identify, assess, manage and respond to risks in a timely manner. It guides our daily decision-making and encourages timely escalation of concerns, so that we make well-considered and balanced decisions at all levels of the organisation.
Compliance as part of Three Lines
ASN Bank operates using the Three Lines Model, in which clear responsibilities are assigned for managing risks and ensuring integrity and controlled business operations:
- 1st line: The business units are primarily responsible for managing risks and ensuring integrity and controlled business operations; the Executive Board bears final responsibility.
- 2nd line: Compliance promotes and monitors adherence to laws and regulations, internal standards and integrity requirements from an independent position. Compliance fulfils a framework-setting, advisory, challenger role as well as a monitoring role towards the 1st line. The Director of Compliance reports hierarchically to the CRO, has a functional reporting line to the CEO and can escalate to the Chairperson of the Supervisory Board if necessary.
- 3rd line: Audit provides independent assurance on the effectiveness of governance, risk management and internal control, including the functioning of the 1st and 2nd lines.
Below are a number of regulations, procedures and provisions that relate to compliance: