Code of Conduct for Business Ethics and Compliance

A high level of business transparency and effective controls support and strengthen the trust which customers, investors, business partners, employees and the general public place in the integrity of the Dresdner Bank Group. As a result, they are a foundation stone for long-term value creation and the Bank’s sustained growth.

With this aim, and in order to implement the provisions of the Sarbanes-Oxley Act, Dresdner Bank’s Board of Managing Directors resolved a revised Code of Conduct for Business Ethics and Compliance in August 2005.

The Code of Conduct, which incorporates the ten principles of the UN Global Compact Programme, and should be considered as a minimum standard, provides guidelines to ensure that professional independence within the Dresdner Bank Group is not called into question and conflicts of interest are avoided. It also serves employees as an orientation aid for their own decisions.

Its 22 principles include not only the goals of effectively combating money laundering, terror financing and white collar crime as well as a “zero-tolerance” business policy on the violation of competition rules and misuse relating to tax evasion, but also guidelines relating to the guarantee and acceptance of gifts and benefits.

Equally important in the Code of Conduct are the compliance rules for dealing with potential conflicts of interest, the prevention of insider trading and the protection of confidential customer data.