Compliance policy of Deutsche Börse Group
Compliance is an integral part of corporate culture at Deutsche Börse Group. The Group introduced compliance rules for all employees back in 1996 and has developed them continuously ever since. In 2005, the Group adopted a compliance policy that is binding for all employees throughout the Group including the Executive Board and service providers.
The compliance policy serves as a framework for introducing a compliance function as well as the measures taken by it. Deutsche Börse Group has set up a compliance department that is responsible for drawing up and developing the compliance rules. It informs and trains Group employees and ensures that they adhere to the rules. The compliance function reports directly to the Executive Board.
The compliance policy deals with the following topics:
Prevention of insider dealing
In the course of their professional activities, employees of Deutsche Börse Group and its service providers may obtain access to confidential information about Deutsche Börse AG and other issuers of financial instruments. Group-wide guidelines for the prevention of insider trading have been set up to ensure that legal regulations concerning insider surveillance and in particular the prohibition of insider dealing are observed. An important instrument in relation to this is the classification of employees according to the extent to which they have access to insider information, with the corresponding obligations and trading restrictions.
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.
Trading Window opened
In accordance with Deutsche Börse Group's staff trading rules the Trading Window opened on 30 April 2013 at the start of trading.
From this date all employees and external service providers, as well as third parties acting on their account, may place orders to buy or sell shares in Deutsche Börse AG or related instruments.
The Trading Window will, in all likelihood, close again on 28 June 2013 at close of trading.
Price and market manipulation
Price and market manipulation are wilful illegal acts to influence demand, supply or the market price of financial instruments. The intention to manipulate is decisive, whether this actually has an impact on demand, supply, or the market price of financial instruments or not. Deutsche Börse Group has established internal rules to prevent market manipulation. These include the obligation to satisfy notification and disclosure requirements as well as adequate financial market communication.
Prevention of fraud
Deutsche Börse Group is committed to creating an environment in which fraud is constrained to protect its own interests as well as those of market participants. Deutsche Börse Group has installed a system of internal controls and established mechanisms to report and pursue attempted fraud. These are regularly inspected to ensure that they are up to date. Furthermore, appropriate procedures have been introduced to prevent any cases of fraud and expose them as fast as possible.
Avoiding conflicts of interests and corruption
To avoid conflicts of interest, Deutsche Börse Group undertakes all the necessary measures to prevent and, if necessary, resolve conflicts of interest that might arise between customers, between customers and Deutsche Börse Group itself, between customers and employees, and between the different companies in the Group and the business units.
The Executive Board of Deutsche Börse AG is committed to combating corruption to prevent damage to Deutsche Börse Group and preserve confidence in its integrity. To this end, the compliance function has established rules of conduct for all employees, for example how to deal with accepting and giving presents and other benefits and, based on this, what conditions Deutsche Börse Group must fulfil when awarding contracts to suppliers.
The purpose of data protection is to protect personal data and, in particular, data relating to individual persons. The aim is to safeguard the private sphere of employees and customers as well as third parties such as service providers. To ensure this, personal data may only be processed with the appropriate authentication and in accordance with data protection policies. Deutsche Börse Group has set up the position of a company data protection official whose main duties are regulated in a Group-wide data protection guideline.
Prevention of money laundering and terrorist financing
To avoid transactions that are linked to money laundering or financing terrorism and to satisfy the legal obligations, internal rules were established including measures to identify customers and train employees as well as internal control and notification procedures.
Observing professional and banking secrecy
Deutsche Börse Group and its employees are committed to keeping confidential customer information secret both during the course of a business relationship and once this has been terminated.