Compliance

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Proactive compliance risk management

With a view to the regulatory environment, compliance identifies upcoming risks and challenges and actively manages them in line with the Group's risk appetite and strategic goals. The focus is on the prevention of money laundering, terrorist financing, insider trading, fraud, corruption, and other criminal activities as well as ensuring sanctions, embargos, and markets compliance are observed in the context of our business activities. In addition, compliance focuses on addressing human rights and environmental risks in the Bank's supply chains in accordance with the principles set out in Commerzbank’s Human Rights Position.

AML

Anti-Money Laundering and Counter Terrorist Financing

One of the core tasks of compliance is meeting regulatory requirements intended to prevent and combat money laundering and the financing of terrorism. In addition to national requirements and industry standards, Commerzbank complies with established international standards such as the Financial Action Task Force (FATF) recommendations and the Wolfsberg Anti-Money Laundering Principles .

Sanctions and embargos

Compliance ensures that financial and economic sanctions of relevance for Commerzbank, as well as the supplementary regulatory requirements, are observed.

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Markets Compliance

Compliance is responsible for the early detection of compliance risks in the provision of investment services and securities ancillary services that could jeopardise the integrity and, therefore, the success of the Bank. By controlling these risks, they will be adequately reduced and, if possible, prevented in the interests of all parties involved.

Fraud prevention and anti-corruption

The Commerzbank Group takes extensive precautions so that clients and employees do not become the victim of or a part of fraudulent acts. Moreover, we protect our products and processes against misuse. In all areas we emphatically advocate preventive anti-fraud measures. We have defined comprehensive measures so as to prevent, uncover, and adequately respond to white-collar crime. Commerzbank is persuing a zero-tolerance policy for any such crimes.

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Human rights and environmental due diligence obligations

Commerzbank is aware of its corporate responsibility to respect human and environmental rights. It therefore undertakes to respect these in its own business area and in its supply chain and to give those affected by human rights and environmental law violations access to remedies. Anyone who is potentially affected by human rights or environmental law violations within Commerzbank AG or within the supply chains can submit information via the whistleblowing system, regardless of whether this happens in Germany or abroad.

COI

Conflict of interest management

Commerzbank is active in numerous business areas worldwide and can offer its customers a large portfolio of financial services. However, when Commerzbank, its customers, or suppliers face business interests, this can also lead to conflict situations. With the aim of avoiding potential conflicts of interest and resolving conflict situations appropriately, Commerzbank has introduced a system for conflict of interest management. For example, Commerzbank uses a conflict-of-interest tool (COI tool) in its business with corporate customers. The standardised procedure and documentation also make COI-based decisions transparent and comprehensible for independent third parties.

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Whistleblowing system

In its corporate values, the Commerzbank Group is committed to the integrity of its dealings with each other and with its customers. We are strongly committed to preventing wrongdoing on the one hand and punishing wrongdoing on the other hand. This also means that we are open to clues that lead to the investigation of economic crimes and violations of legal, regulatory, or internal requirements in connection with Commerzbank.

In addition to the established contact channels, for example via the compliance or auditing departments, Commerzbank has set up a platform with the Business Keeper Monitoring System (BKMS), through which customers, employees, and third parties can provide online information to the Commerzbank Group. If you wish to provide us with a notice via this system, you may do so by name or anonymously. However, as we seek open communication with customers, employees, and third parties, we encourage you to use your name when making notices. In any case, we will treat your information strictly confidentially and take into account the legitimate interests of all parties involved within the scope of the legal possibilities.

Report for Commerzbank AG Germany

Further information and link to the BKMS® for reports regarding
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Commerzbank AG Germany
place the report
Please select the unit for which you want to submit the report from the list below.

Overview - international branches of Commerzbank AG

Further information and links to the BKMS® system for notifications from the respective branch (foreign unit):

International branches
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Commerzbank AG United Kingdom
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Commerzbank AG China
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Commerzbank AG Japan
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Commerzbank AG Singapore
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Commerzbank AG Czech Republic
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Commerzbank AG France
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Commerzbank AG Spain
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Commerzbank AG Austria
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Commerzbank AG Italy
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Commerzbank AG Netherlands
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Commerzbank AG USA/Commerz Markets LLC USA
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DTC Commerzbank AG Sofia (interim link)
Please select the unit for which you want to submit the report from the list below.

Overview - Subsidiaries of Commerzbank AG

Further information and links to the BKMS® system for notifications from the respective subsidiariy:

Subsidiaries
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CERI International Sp. z o.o.
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Collegium Glashütten
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Commerzbank (Eurasija) AO
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Commerz Business Consulting GmbH
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Commerz Direktservice
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Commerz Factoring GmbH
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Commerz Real AG
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ComTS Finance GmbH
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ComTS Logistics GmbH
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ComTS GmbH
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Kenstone GmbH
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mBank SA
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Commerz Service-Center Intensive GmbH
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Soltrx Transaction Services GmbH
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Yellowfin Asset Management GmbH

UK Tax Strategy

We are committed to complying with UK tax obligations, and we operate within the Commerzbank Group’s policies. We are committed to ensuring that we pay the right amount of all UK taxes and that all UK tax returns are completed accurately and on time.

USA PATRIOT Act

Commerzbank AG has renewed its certifications in accordance with the USA PATRIOT Act as of 9 May 2014.
The USA PATRIOT (Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism) Act, signed into law by President George W. Bush in October 2001, requires financial institutions to put in place stringent compliance programmes regarding the activities of a broader range of account holders than ever required before.
Commerzbank AG certifies the compliance with the USA PATRIOT Act. The certification is available in PDF. In order to print or view it, you must have the Adobe Acrobat Reader installed on your computer.

Special note on Commerzbank AG's Grand Cayman branch
The Grand Cayman branch of Commerzbank AG does not maintain a physical presence or staff on the Cayman Islands. The branch is managed by Commerzbank AG North America, New York, United States of America.
The branch maintains a banking license issued by the Cayman Monetary Authority and is regulated and under supervision of the Cayman Monetary Authority.
Please note: The Grand Cayman branch is included under Commerzbank AG's certification to the USA PATRIOT Act.

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