Informer system: the ombudsman (no arbitration body)

NORD/LB Luxembourg Covered Bond Bank has set down clear rules on proper and professional conduct for its employees, for example in the event of conflicts of interest, in the fight against financial crimes such as corruption, fraud and money laundering, for the maintenance of confidentiality and data protection, customer service, the protection and use of Bank resources or protection against discrimination.

NORD/LB Luxembourg Covered Bond Bank has implemented an informer system that can be used by both employees and customers. This includes the function of an external ombudsman whom informers can contact in confidence if they suspect criminal activity or unlawful business transactions.

The ombudsman

• confidentially handles corresponding evidence of criminal acts and gross irregularities
• advises the informers
• notifies NORD/LB Luxembourg Covered Bond Bank of the suspicious matter if the informer waives legal privilege

Notes

• The ombudsman is not a general complaints department or a "suggestion box". He is solely available as a contact if criminal acts such as fraud or gross irregularities are suspected.
• The identity of the informer is never disclosed. There is no charge to you for contacting the ombudsman.

At NORD/LB Luxembourg Covered Bond Bank Dr. Rainer Buchert from Frankfurt am Main occupies the role of ombudsman. He is a lawyer and is thus subject to a duty of confidentiality and the right to refuse to testify. Even if matters proceed to trial, he must not name the informer. Dr. Buchert has already worked as an ombudsman for other large German companies for many years. For more information see www.dr-buchert.de (in German only).

Our appointment of an ombudsman is in tune with the guidelines of the German Corporate Governance Code and corporate social responsibility. All individual measures are important preconditions for successfully fighting and preventing potential losses arising from fraudulent or otherwise criminal activities.