G1-3 – Prevention and detection of corruption and bribery

Structures, rules and prevention mechanisms

As both a federal public law institution and a credit institution, Rentenbank is under a particular obligation to prevent and detect corruption, bribery and other criminal offences. To fulfill this obligation, Rentenbank has established comprehensive compliance procedures.

These procedures are based on the concepts described above and translate them into preventive measures or, where there is cause, reactive measures.

Risk assessment and internal control mechanisms

The effectiveness of the preventive protection system is based on several interlinked elements. As part of its proper business organisation and appropriate risk management aimed at preventing other criminal offences that could jeopardise the institution’s assets, Rentenbank has established internal principles and appropriate business- and customer-related safeguards.

In addition to the materiality and risk analysis prepared by the Compliance function to identify and mitigate institution-specific risks, the Anti-Money Laundering function prepares a risk analysis specifically addressing money laundering, terrorist financing, other criminal offences and sanctions on a risk-based basis each year and, where appropriate, on an ad hoc basis. As part of this analysis, Rentenbank’s organisational structure, other framework conditions, product and customer structure, and business structure are examined, and any changes since the previous review are identified. In addition, findings on potential institution-specific risks from process risk assessments, the loss event database and relevant audit reports are taken into account. Where new risks are identified in the course of the analysis, conclusions are drawn for the protection of Rentenbank following a weighting and assessment of the risk situation and, where necessary, appropriate safeguarding measures are initiated by the Anti-Money Laundering function.

The Anti-Money Laundering function derives a monitoring concept from the risk analysis and, on that basis, carries out documented monitoring measures throughout the year. Current developments in relation to other criminal offences within the meaning of Section 25h KWG, such as publications by the German Federal Financial Supervisory Authority (Bundesanstalt für Finanzdienstleistungsaufsicht; BaFin), situation reports issued by the Federal Criminal Police Office (Bundeskriminalamt; BKA) and press releases, as well as the bank-specific risk situation, are taken into account in the planning process.

Another important element of money laundering prevention relates to compliance with due diligence obligations and the identification of contrac-tual partners (know-your-customer principles). All procedures and processes required for this purpose are followed and any suspected cases are reported immediately to the Financial Intelligence Unit (Zentralstelle für Finanztransaktionsuntersuchungen; FIU) by the Anti Money Laundering Officer. No cases of suspicious activity were reported in relation to money laundering and terrorism financing and no other criminal offences are known to have occurred in 2025. Furthermore, there were no sanction violations in 2025.
The Compliance and Anti-Money Laundering functions are involved in every new product process and every significant change to Rentenbank’s organisational and operational structure or IT systems in order to ensure that potential compliance risks and risks arising from other criminal offences are duly taken into account.

On the basis of the German Securities Trading Act (Wertpapierhandelsgesetz; WpHG) and Regulation (EU) No 596/2014 (Market Abuse Regulation; MAR), Rentenbank has established internal guidelines and reporting obligations for the prevention of insider dealing. These include, in particular, the monitoring of employees’ personal transactions in financial instruments, the maintenance of an insider list, and notification and disclosure obligations in relation to managers’ own-account transactions.

The establishment of internal, external and anonymous reporting channels completes the control framework.

Investigation processes and governance integration

Rentenbank has established a formalised procedure for reporting and investigating potential violations. This includes internal, external and anonymous reporting channels. Reports are received confidentially, documented and processed in accordance with clearly defined review steps.

In the event of potential compliance violations, graduated escalation procedures apply which, depending on the severity of the matter, require the Management Board and, where appropriate, the Supervisory Board to be informed without delay. Information that is not substantiated is also fully documented in order to ensure transparency and traceability at all times.

Suspected cases are investigated in accordance with clearly defined responsibilities. The Compliance function and, where appropriate, the Anti-Money Laundering Officer coordinate the investigations and generally involve Internal Audit and, where necessary, other functions. Care is taken at all times to ensure that investigations are conducted free of conflicts of interest. Where a conflict of interest arises in a specific case, the person concerned is excluded from further involvement. The same applies where a member of the Management Board is implicated in the report itself. Investigations are conducted independently of the management chain involved in the matter.

Processing is carried out promptly, in compliance with statutory deadlines and with due regard to obligations to inform the whistleblowers. The confidentiality of the investigation process is ensured by limiting the group of persons involved in line with the need-to-know principle. Even where a cross-divisional whistleblowing team is convened in cases of particular severity or complexity, the number of participants is kept to a minimum. All persons involved in handling information are subject to strict confidentiality obligations. Following the initial assessment of the facts by the Compliance function or the Anti-Money Laundering Officer, and in parallel with further fact-finding, the Management Board is informed of the progress of the investigation; in serious cases, the Supervisory Board is also informed.

Where the suspicion is confirmed, appropriate remedial measures (e.g. process reviews or adjustments) are initiated and, where necessary, the matter is referred to the competent authorities for further investigation. Where suspicions are not substantiated, the internal whistleblowing procedure is discontinued.

Documentation of the handling of reports is carried out in compliance with statutory retention and deletion periods.

Training, awareness-raising and monitoring

Rentenbank raises employees’ awareness of the relevant laws and regulations through regular mandatory training, in particular on corruption and bribery, money laundering, and fraud prevention. Participation is monitored and, together with other indicators, serves as a risk indicator for measuring risk culture. In addition, employees are continually informed about the latest trends, attack patterns, and specific warning indicators to further raise awareness of IT security issues. The training courses are mandatory for all employees. This ensures that 100% of functions exposed to relevant risks are covered by training.

Training is mandatory upon commencement of employment and is supplemented by annual follow-up training. The training materials are updated on an ongoing basis and supplemented with new legal, regulatory or risk-related requirements.

This ensures that all employees are informed about current developments and fulfil their duties in accordance with the applicable prevention and compliance standards.

Members of the Management Board and the Supervisory Board also receive a Regulatory Update on key topics at least once a year. In addition to the Regulatory Update training course, which included a section on money laundering prevention, training on risk management was also provided in the reporting year.

The Management Board and Supervisory Board are regularly informed, in accordance with established procedures, about whistleblowing cases, preventive measures, reviews and training status.

Procedure for avoiding conflicts of interest

Rentenbank takes a systematic approach to preventing conflicts of interest. The Compliance function is responsible for identifying, preventing and managing conflicts of interest and is available to employees as a point of contact for all relevant matters and cases of doubt.

Members of the Management Board and the Supervisory Board are required to disclose potential conflicts of interest transparently. No conflicts of interest arose in the reporting year. The fixed remuneration system counteracts inappropriate incentives and strengthens the independence of decision-making.

The Management Board and Supervisory Board closely monitor management and receive regular reports on risk, compliance and control matters. In accordance with Section 25d (11), first sentence, nos. 3 and 4 of the German Banking Act (Kreditwesengesetz; KWG), the Supervisory Board reviews the structure, size, composition and performance of the Management Board and the Supervisory Board as a whole, as well as the knowledge, skills and experience of the individual members of those bodies and of each body as a whole. In accordance with Section 9(3) no. 2(c) and (d) of the Rules of Procedure of the Supervisory Board, the Supervisory Board is assisted in carrying out this review by the Nomination Committee. The Supervisory Board reviewed the results at its meetings on 20 March 2025 and 13 November 2025, discussed any need for adjustments, and derived recommendations for action.

Conflicts of interest are also prevented in procurement through strict processes. The relevant procurement rules are observed. Sponsorship and donation activities are carried out exclusively within the framework of clear rules and must under no circumstances give the appearance of improper influence. Rentenbank does not accept sponsorship or donations either.