In September 2009, the Dutch Banking Association published a Banking Code in response to an advisory committee's report on the future of banking. That report, entitled 'Restoring Trust', called for banks to initiate improvements to the way they work and so restore the public trust damaged by the financial crisis.

The Banking Code laid out the principles for good conduct and initially took the form of self-regulation. These principles have since been enshrined in legislation by the Dutch Ministry of Finance. The Banking Code took effect on 1 January 2010. 

The Banking Code is divided into the following sections:

i. Compliance with the Code;
ii. Supervisory Board;
iii. Executive Board;
iv. Risk Management;
v. Audit; and
vi. Remuneration Policy.

In December 2009, our Supervisory Board approved revisions to NIBC's charters, those of our committees, the Supervisory Board and the Managing Board, to ensure our governance was fully aligned with the Banking Code.

We have now implemented all the procedural and operational measures required under the Banking Code. We revised our remuneration policy for staff and completed the revision of our remuneration policy for the Managing Board. The Managing Board members signed a moral and ethical conduct declaration as worded in the Banking Code and this is published on NIBC's website. A programme of lifelong learning was drawn up and training sessions for the Managing Board and the Supervisory Board were held in 2010. Dates and programmes for 2011 have been set. The members of the Supervisory Board evaluated their performance in March 2010, with the support of external advisors and began following up on the recommendations. The Report of the Supervisory Board offers more information.

The Minister of Finance and the Dutch Banking Association set up a monitoring committee that will report annually on compliance with the Banking Code. As from 2011, banks must specify how they are applying the Banking Code in a 'comply or explain' statement in their financial report for the previous year. For a detailed overview of NIBC's compliance with the Banking Code, per article, see our overview: NIBC Bank N.V. compliance with the Dutch Banking Code.

In a preliminary report published in December 2010, the Monitoring Committee said it would focus on client focus, risk management and governance in 2011, when it releases its first full report on the implementation of the Banking Code. For NIBC's view on these focus areas, please see:

• Client focus
• Risk Management
• Governance