Dutch Banking Code - Amsterdam Trade Bank
In September 2009, the Dutch Bankers’ Association (NVB) adopted the Banking Code for Dutch banks as binding. The Banking Code lays out the principles by which Dutch banks should conduct themselves in terms of corporate governance, risk management, audit and remuneration.
In accordance with the Banking Code, banks licensed under The Financial Supervision Act (Wet op het financieel toezicht) in the Netherlands are required to describe what preparatory steps were taken in 2009 to ensure that they can apply the Banking Code from January 2010 onwards.
On 1 January 2010 the Banking Code came into force.
In 2009 Amsterdam Trade Bank (‘the Bank’) started to prepare for the introduction of the Banking Code and to implement the principles underlying the Banking Code that were not yet an integral part of the Bank’s policy principles. As of January 1, 2010 the Bank is substantially compliant with the Banking Code and continues to take steps towards full compliance.
The members of the Board of Managing Directors have considered to sign declarations of moral and ethical conduct and in 2010 a program of permanent education has been set up for the members of the Board of Managing Directors and Supervisory Board in accordance with the Banking Code’s principles.
The Bank intends to develop and implement a meticulous, restrained and long-term remuneration policy that is in line with its strategy, risk appetite, objectives and values. A remuneration committee was established in February 2010.
The Bank’s risk management and control system is based on the ‘three lines of defense’ principle, with the Board of Managing Directors bearing ultimate responsibility. The first line of defense assures effective management of key business process risks by the line managers’ internal control activities. The second line consists of the monitoring role by the Risk Management and Compliance Departments. In 2010 a management board member seat was given to a Chief Risk Officer.
The Bank complies fully with the Banking Code’s risk management and auditing principles. In accordance with the Banking Code, the Bank will provide further information on its compliance with the Banking Code.
Internal Audit Policy
The mission of the Internal Audit function of Amsterdam Trade Bank is to provide independent, objective assurance and consulting services designed to add value and improve the bank’s operations and systems of controls. The Internal Audit function helps the bank to accomplish its objectives by adopting a systematic, disciplined approach to evaluate and improve the effectiveness of risk management, control and governance processes. Internal Audit operates as an independent function, positioned directly under and reporting to the Board of Managing Directors. It is responsible to executing operational, IT and compliance audits with the purpose of providing reasonable assurance that the risk management, control and governance processes, as designed and implemented by the Board of Managing Directors, are adequate and functioning.
Anti-Money Laundering Policy
Amsterdam Trade Bank maintains the strictest anti-money laundering controls based on European guidelines and acts in full compliance with regulations and instructions set by De Nederlandsche Bank.
KYC Policy
All clients have been subject to an acceptance and identification process prior to the start of their relationship with Amsterdam Trade Bank. Subsequently, client transactions are diligently monitored to prevent the involvement of the bank in any illegitimate or otherwise unwanted activities.
Patriot Act Certificate
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Code of Conduct
Every employee of Amsterdam Trade Bank is required to sign the bank’s Code of Conduct, providing a clear statement of the bank’s ethical and cultural standards. Our culture is based upon a set of shared values and principles. These include working with integrity, and with respect for clients and employees. The following key duties and principles govern our conduct:
- Best interest of clients – every employee is expected to be alert to any actual, potential or appearance of a conflict of interest with a client.
- Applicable law – we have a duty to comply with the laws of the jurisdictions in which we operate, and to comply with the terms of the agreements with our clients.
- Client and employee confidentiality – we must maintain the confidentiality of information relating to clients and employees, and comply with the data protection requirements imposed by jurisdictions in the Netherlands and abroad.
- Information – clients must be provided with timely and accurate information.
- Segregation and protection of assets – processes must be established for the proper maintenance, control and protection of client assets.
- Relations with regulators and supervisors – we seek relationships with regulators and supervisors that are open and responsive in nature.
Data Privacy Policy
Customer data privacy has become a major political and legal issue, both in the Netherlands and abroad. Amsterdam Trade Bank is committed to protect client data from unauthorized disclosure. The bank has notified the Dutch Data Protection Authority that client data is recorded and maintained in full compliance with prevailing European and Dutch legislation and regulations.
Complaints Policy
Complaints from our clients are taken very seriously by the bank. We will do our utmost to reply to any complaint as soon as possible. To ensure complaints are immediately handled, clients are requested to forward any complaint by email to complaints. In case a solution suggested by the bank is not satisfactory, clients may consider forwarding their case to Klachteninstituut Financiële Dienstverlening Kifid.