Code of Conduct

The key to the sustainable success of Hamburg Commercial Bank AG is a strict adherence to the rules and standards that apply to us. Especially for us as a privatised commercial bank, it is important that all market participants can be assured of the personal integrity of our employees and the integrity of the bank.

Extensive rules of behavior apply to Hamburg Commercial Bank AG, of which all of its employees have to comply with. These are summarized in the Code of Conduct . Each of us is required to review, acknowledge and understand our Code of Conduct .

Besides the classic compliance rules, the Code of Conduct also covers requirements applicable to our behavior in the tax, finance, risk management, data protection and communication areas. Moreover, the Code of Conduct contains standards of behavior that we have to adhere to in day-to-day dealings with our colleagues and customers, as well as to be able to satisfy our social responsibilities.

The Code of Conduct contains requirements concerning the behavior in the following areas that are essential for Hamburg Commercial Bank:

• Integrity
• Clients, employees and society
• Risk management, finance and taxes
• Conflicts of interest
• Insider information and customer protection
• Anti-money laundering, terrorist financing and financial sanctions
• Other criminal activities / Anti-financial crime
• Information security, data protection and communication