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The sustainability, effectiveness and independence of the compliance function at comdirect bank (Compliance Office) as well as the responsibilities, rights and obligations of this office are regulated in the compliance policy. The role of the Compliance Officer is assumed by the Head of Legal Services/Compliance, Mr Dietmar Gabor; he is also the Money Laundering and Corporate Governance Officer at comdirect bank. When implementing the “Act Implementing the Second E-Money Directive", comdirect bank’s Money Laundering Officer has also assumed the function of the central office to prevent criminal offences (Section 25c German Banking Act, KWG) and established an anti-fraud policy, a cross-divisional “criminal offences network” and a web-based whistleblower system via which customers, employees and other third parties can provide information online regarding financial fraud at any time.

In accordance with the supervisory regulations, comdirect bank’s Compliance Office is also responsible for monitoring whether the controlling specified in the work and organisational instructions is carried out correctly and regularly by the specialist departments (ICS – control monitoring). This showed that the process-dependent internal control system (ICS) is effective.