It is very important for the OeNB to live up to the high moral standards demanded of an official institution. To make certain that every OeNB staff member fully respects legal and internal requirements, the Compliance Office takes measures to prevent any actions that might constitute criminal offenses or that might damage the OeNB’s reputation.
The Compliance Office identifies compliance risks and, on this basis, develops, adapts and implements compliance guidelines for OeNB staff. The effectiveness of compliance measures is regularly monitored and ensured through staff training. In the interest of transparency, all potentially compliance-relevant activities are clearly and comprehensively documented, including routine compliance scenarios as well as more complex situations with particular relevance.
With the help of local compliance officers, the implementation of the OeNB’s compliance system is likewise ensured in all majority-owned OeNB subsidiaries. The Compliance Office is directly responsible to the OeNB’s Governor. It regularly reports to the Governing Board and directly to the OeNB’s President and Vice President if necessary.
The Compliance Office monitors adherence to the code of conduct, which sets out the conduct expected of all OeNB employees both within the OeNB and outside the workplace. Related requirements range from the careful use of corporate resources to the avoidance of conflicts between private and professional interests and acts that could damage the OeNB’s reputation. Certain rules of conduct have been laid down in separate regulations in greater detail, e.g. rules concerning the authorization of secondary employment. Any employment outside the central bank is only permissible if it does not affect the employee’s work at the OeNB through conflicts of interest, does not take up too much of the employee’s time and does not cause a reputation risk for the OeNB.
The Compliance Office also sees to the prevention of insider trading by enforcing guidelines that prohibit the use of insider information, especially in the area of securities transactions.
To avoid any acts that could be interpreted as bribery, the OeNB has developed guidelines governing gift giving and receiving (including hospitality). These guidelines ensure that OeNB employees are aware of all aspects of anticorruption law and act accordingly. Monitoring the implementation of the anticorruption guidelines is also part of the Compliance Office’s job.
The OeNB has also established guidelines on sponsoring and donations, specifying the conditions under which it subsidizes projects in the following four areas: (1) (economic) science, (2) arts and culture, (3) humanitarian endeavors and (4) projects promoting environmental protection, democracy or human rights.
Finally, the Compliance Office also carries out risk assessments of business partners in cases of doubt.
In fall 2012, Austria’s federal government passed a public corporate governance code (Bundes Public Corporate Governance Kodex – B-PCGK), which the OeNB and its subsidiaries will need to implement. Many provisions contained in this code have already been implemented in the Federal Act on the Oesterreichische Nationalbank. Next to national legislation, the OeNB must also comply with international laws, rules and directives, in particular with the Statute of the European System of Central Banks and of the European Central Bank, and other legal provisions applicable to central banks.