G1-1 – Business conduct policies and corporate culture

Recognition of the Public Corporate Governance Code of the Federal Government (PCGK)

Effective corporate governance is of central importance to Rentenbank. Accordingly, on 20 March 2025, the Supervisory Board adopted the Public Corporate Governance Code of the Federal Government in the version dated 6 November 2024. The Management Board and Supervisory Board expressly endorse the principles of good and responsible corporate governance set out therein.

Compliance with the PCGK serves the public interest in ensuring that Rentenbank’s business activities are lawful, conducted with integrity and aligned with its promotional mandate. As envisaged by the Code, any deviations are disclosed transparently and explained annually in a declaration of compliance.

Codes of conduct

The Code of Conduct for Employees forms the ethical framework for all employees and managers. It emphasises fundamental democratic values, human rights, equal opportunities, integrity, transparency and the responsible use of resources. It sets out clear expectations regarding professional conduct, non-discrimination, fairness and the protection of confidential information. It thus represents the normative framework for a lawful and sustainable corporate culture. In particular, it contains binding provisions on the prevention of corruption, the acceptance and granting of benefits, conflicts of interest and secondary employment, the prevention of fraud and money laundering, the handling of insider information and market abuse, as well as confidentiality, data protection and IT security.

The principles defined in the Code of Conduct shape the corporate culture, guide decision-making processes and promote open and respectful cooperation. Training, dialogue sessions and organisation-wide values initiatives support their continued embedding within the organisation. The Code of Conduct is supplemented by further specific internal rules and guidelines, for example on gifts and invitations, procurement, sanctions screening and due diligence processes.

Members of the Management Board are subject to a separate Code of Conduct, which includes in particular fundamental principles governing conflicts of interest, the acceptance and giving of gifts and invitations, lecturing activities, dealings on the financial markets, secondary activities and voluntary engagement.

Rentenbank’s expectations of suppliers and business partners with regard to social and environmental aspects, as well as governance-related requirements, are set out in the Code of Conduct for External Parties and in other detailed organisational instructions.

Corporate policy and strategic orientation

The policies established at Rentenbank ensure that responsible behaviour, compliant conduct and the interests of business partners and other stake-holders are taken into account at all times. These include in particular:

• the prohibition of corruption, fraud and anti-competitive conduct;
• the avoidance of conflicts of interest;
• the prohibition of market abuse and the misuse of insider information;
• the protection of information, assets and IT systems;
• the prevention of money laundering; and
• strict data protection safeguards.

Corporate culture: promotion, communication and further development

Our corporate culture expresses our values, standards and convictions. It is therefore the basis for the responsible fulfilment of our statutory promotional mandate. In day-to-day business, it is reflected in organisation-wide values, management principles and a risk culture that is actively practised throughout the organisation. Corporate culture is not static, but adapts to changing internal and external requirements. Feedback is gathered through an open feedback culture and employee surveys. Compliance indicators are in place to measure the impact of the corporate and risk culture. Responsibility for corporate culture lies with the entire Management Board.

As part of Rentenbank’s transformation process launched in 2022, corporate values were presented in 2024. These are: drive, appreciation, responsibility, innovation and consistency.

The corporate values were developed in a participatory process involving all employees. Their publication was followed by extensive communication in various virtual and on-site formats. In the following year, workshops on corporate values were held in which employees had the opportunity to reflect on these values in the context of their day-to-day work. More than 90% of all employees took part in this format.

The management principles also embed our attitude within the corporate culture. As a “tone from the top”, the conduct of the Management Board and senior managers has an impact on all employees. The behavioural principle of making employees aware of Rentenbank’s tasks and objectives has a particular impact on the culture. Equally important is the embedding of a speak-up culture, which fosters active and open feedback in all directions.

The risk culture supplements the internal frameworks described above with requirements addressed to employees and managers, through which Rentenbank’s risk appetite is intended to be put into practice in day-to-day business. Particular emphasis is placed on risk awareness and risk appetite. The internal organisation-wide Risk Culture Working Group discusses issues relating to risk culture and develops indicators for measuring it. Responsibility for this likewise lies with the entire Management Board.

In 2025, the Culture Check, an organisation-wide anonymous survey of all employees, was used to gain an impression of the corporate culture. It could be analysed down to group level, provided that participants’ anonymity could be maintained. The results of the Culture Check will feed into the revision of the corporate culture framework.

Mechanisms for reporting and handling misconduct

Rentenbank has established a confidential whistleblowing system on the basis of the German Banking Act (Kreditwesengesetz; KWG) and the German Money Laundering Act (Geldwäschegesetz; GwG), as well as in accordance with the requirements of the German Whistleblower Protection Act and Directive (EU) 2019/1937. A structured whistleblowing and complaints system enables internal and external reporting, including the option of anonymous reporting via an ombudsman. The procedures ensure confidentiality, data protection, protection against reprisals, and objective and timely handling.

Information may be submitted verbally, by telephone or in person, in writing by post or email, or via Rentenbank’s website to the internal reporting office. It is also possible to report suspected cases to an ombudsman, anonymously if necessary. The ombudsman receives information from employees and forwards it to the internal reporting office, where necessary while preserving the anonymity of the employee concerned.

The internal reporting office has been established within the Compliance department. The persons responsible for the internal reporting office are generally independent in their handling of suspected cases. If an authorised representative has a conflict of interest in a specific suspected case, that representative is excluded from the relevant handling of the case.

All employees of Rentenbank, as well as external staff, are required to report any observed misconduct to the internal reporting office. The rights of all employees to involve the Staff Council remain unaffected.
Furthermore, Rentenbank’s website also offers persons who are not employees of Rentenbank the opportunity to submit information about a possible violation of the law or to obtain information about the relevant procedures.

The whistleblowing system therefore constitutes an important part of Rentenbank’s compliance culture and promotes openness and transparency.

The central principles of the whistleblowing system are:

• confidentiality of all reports;
• confidential handling by limiting the group of persons involved in line with the need-to-know principle;
• protection of whistleblowers against reprisals;
• structured review and investigation steps;
• complete documentation of the entire review process;
• defined reporting channels; and
• the derivation and initiation of remedial measures and permanent safeguarding processes.

The procedures are fully implemented and organisationally embedded in accordance with the German Whistleblower Protection Act. Rentenbank also raises awareness among its employees through regular briefings and needs-based training, both online and in person, which are continuously refined.

Protection of whistleblowers

The ombudsman enables internal and external stakeholders to submit information anonymously. The internal framework for dealing with suspected cases excludes reprisals resulting from a report or disclosure. In addition, the relevant internal policy provides that employees who make a report in good faith need not fear any disadvantages, even if the report proves to be unfounded. If employees self-report or report their own misconduct internally to their responsible manager or to the internal reporting office, this is taken into account in their favour in the event of disciplinary measures.

Training policy and risk-based prevention

Regular mandatory and on-demand training strengthens integrity and governance compliance throughout the organisation. The topics cover the principles set out in the Codes of Conduct, including the management of conflicts of interest, ethical conduct, and the prevention of money laundering and corruption. The training materials are updated on an ongoing basis and supplemented with new legal, regulatory or risk-related requirements. The following section provides information on the frequency and content of training relating to the prevention of corruption and bribery.