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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 certain 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 Staff Department, Group Compliance 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. To the extent there is a Compliance function within a specific regulated group entity these Compliance Officers facilitate the implementation in close cooperation with Group Compliance. The Compliance Function reports directly to the Executive Board of Deutsche Börse AG and / or the Management Board of the respective group entity.

The Compliance Policy deals with the following topics:

Prevention of Market Abuse

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. The Market Abuse Policy serves as a group-wide guideline for the Prevention of Insider Dealing and Market Manipulation. An important instrument to ensure insider surveillance and in particular compliance with the prohibition of insider dealing, including the attempt thereof, includes the classification of employees in Compliance Levels depending on their exposure to compliance-relevant information, entailing various obligations, e.g. for personal account dealing.

Price and market manipulation are willful 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 – already the attempt of these offences is punishable by law. 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.

Closed Period

Within the framework of their professional duties, persons can have access to compliance-relevant information about interim financial statements and reports or year-end reports of Deutsche Börse AG prior to publication. These persons are prohibited from conducting any transactions on their own account or for the account of a third party, directly or indirectly, relating to the shares or debt instruments of the issuer, such as DBAG, and to derivatives or other financial instruments linked to them. The Closed Period starts 30 calendar days prior to the announcement of the respective financial report and ends on the day after the publication of these.

Prevention of Miscellaneous Criminal Activities

Deutsche Börse Group is committed to creating an environment in which Miscellaneous Criminal Activities s are 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 suspicious cases. Furthermore, appropriate procedures have been introduced to prevent any cases of Miscellaneous Criminal Activities and expose them as fast as possible. The Compliance Function primary concentrates on the regulated entities and their core financial services practice.

Management of Conflicts of Interests

Being a market infrastructure provider with broad interaction with major market participants along the value chain, the potential for conflicts of interest is inherent in Deutsche Börse Group’s business. Moreover, individuals may be subject to circumstances in their professional as well as their personal life that create the potential for conflicts of interest. Thus, it is of utmost importance that Deutsche Börse Group can identify and effectively manage potential or actual conflicts of interest between itself (including its management body members, employees, or any persons closely associated to them) and third parties. 

Conflicts of interest may arise in situations in which the interests of one party interfere with (or appear to interfere with) the interests of another party. This can impair the ability of one or both conflict parties to act fairly and ethically, particularly either party’s objectivity to take a decision or to participate in a decision-taking process in the course of its professional obligations. 

See also the “Principles on the Management of Conflicts of Interest at Deutsche Börse Group” here

Prevention of Corruption

Active and passive corruption are prohibited in all circumstances. Even if the offering or accepting of benefits only raise the appearance of bribery or corruption, that person must refrain from proceeding in any way.

Granting or accepting benefits (e.g. gifts, business entertainment or other benefits) should be aimed at promoting, maintaining and strengthening the overall business relationship. Such business purpose should clearly outweigh the personal aspects. Granting or accepting benefits requires a responsible attitude of all involved persons. The frequency, type and value of the benefit must be appropriate and must not risk reputational damage for Deutsche Börse Group and its employees. 

For the purpose of the protection of Deutsche Börse Group, its employees and reputation for conducting business with integrity, all employees must comply with the notification and (pre-)approval requirements established at Deutsche Börse Group. 

Data Protection

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 and Terrorist Financing and to satisfy the legal obligations, Deutsche Börse Group has established internal rules including measures to identify customers and train employees as well as internal control and notification procedures.