Compliance

ASN Bank can only be successful if it earns the trust of its stakeholders. In everything we do, integrity is a crucial prerequisite to safeguarding this trust in a sustainable way. ASN Bank approaches integrity in a way that reflects its identity as a sustainable financial service provider, always aiming to serve the long-term interests of its customers.

Impact of sanctions on payments to and from Russia
In recent days, the European Union has imposed numerous sanctions on Russia. Dutch banks are implementing measures in response. These sanctions impact payments made by our customers. It is no longer possible to transfer money to Russia. Incoming payments from Russia are only partially possible. We ask for your understanding.

Integrity, manifesto and banker’s oath
Integrity is also a fundamental value in ASN Bank’s Manifesto, which centres around four key themes: sustainability, people helping people, purpose over profit, and financial resilience. Integrity has been translated into rules of conduct that apply to all employees. The banking sector has introduced the banker’s oath to foster a cultural shift in the financial industry. This is meant to restore public trust in the sector. ASN Bank regards the banker’s oath as a reinforcement of its Manifesto. It is only natural, therefore, that our employees take the oath and are subject to the sector’s disciplinary rules. By doing so, they become personally accountable for complying with the sector-wide rules of conduct, which align with our own Code of Conduct: “Common Sense, Clear Conscience.”

Common sense as a guiding principle
However, rules and procedures alone cannot guarantee integrity. New dilemmas will always arise. ASN Bank therefore expects its employees to use their common sense in daily activities. We aim to foster an open culture where integrity dilemmas can be discussed freely.

Compliance within the three lines of defence
The ASN Bank brands and business units are responsible – as the first line of defence – for maintaining an ethical business operation. ASN Bank’s Executive Board bears ultimate responsibility. Cross-brand issues concerning non-financial risks are handled by the Operational Risk Committee (ORC).

The Compliance department plays a second-line role in safeguarding and promoting integrity. It does so by developing and maintaining frameworks, monitoring compliance, and advising on integrity issues.

Four pillars guide this work:

• Employees
• Products and services
• Customers
• Partnerships

The Compliance department operates independently. This means it is separate from brands and business units and considers the interests of all stakeholders. Compliance Officers report hierarchically to the Director of Compliance, who reports to the CRO, has a functional reporting line to the CEO, and may escalate to the Chair of the Supervisory Board. The third line of defence is formed by the Audit department.