Responsible corporate governance includes making all employees aware that access to sensitive and confidential information – about Deutsche Börse AG or other issuers – entails certain obligations. For example, insider trading is a punishable crime in Germany. In many areas of their activities, Deutsche Börse Group employees have access to information that results in them being deemed “insiders” therefore they are not permitted to exploit this information in their own securities and derivatives dealings or make it accessible to third parties. The WpHG (German Securities Trading Act) has established additional rules of conduct for all companies involved in trading securities and their employees, stipulating that they act “in the best interests of customers and the integrity of the market” to “avoid conflicts of interest”. Acting in line with the applicable legislation is called “compliance”.

Compliance is an integral part of corporate culture at Deutsche Börse Group. The Company introduced compliance rules for all employees back in 1996 and has constantly developed them since then. Uniform compliance policies apply across Deutsche Börse Group. In order to inform and train employees, and to ensure that they adhere to the regulations, Deutsche Börse AG has set up a Group Compliance department. This department is active across the Group and its head reports directly to the Executive Board. A newsletter is used to keep employees informed about new developments in compliance rules.

Deutsche Börse AG has compiled a register of insiders, listing the names of all people who are employed by or on behalf of the Company and whose activities give them access to confidential information that could influence the price of Deutsche Börse AG shares and derivatives on these shares. In addition, all employees are classified into different insider groups. These ratings govern the various regulations that employees must observe when trading in securities and derivatives.

Trading Window

Persons who have access to financial information about Deutsche Börse Group companies prior to its publication may only trade in Deutsche Börse AG shares or derivatives on these shares in specified periods of time. The trading window indicates the periods of time in which employees may do so.

These measures mean that Deutsche Börse AG complies voluntarily with the high security standards of the banking industry designed to avoid insider trading and conflicts of interest. Every year, internal and external auditors ensure that Deutsche Börse AG complies with the statutory and voluntary compliance guidelines.