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    Zuger Kantonalbank

    Business ethics and corporate responsibility

    Bribery and corruption

    Zuger Kantonalbank does not tolerate bribery or corruption. It has issued regulations to this effect, according to which all employees must report gifts, invitations or incentives of a minor value to their line manager who decides whether or not they may be accepted. Gifts, invitations or incentives of a higher value must be reported to Compliance, which decides whether or not they may be accepted.

    Data security / cyber security

    Zuger Kantonalbank attaches great importance to cyber security and data protection. It follows international standards and has a multi-level threat management concept. The check is carried out via systematic and continuous monitoring, supplemented with regular external security checks such as security audits and penetration tests. The central pillars of the cyber security strategy are general awareness of threats and ongoing training of employees. External providers to whom IT services are outsourced must meet the high information security and data protection requirements stipulated in the contract. As part of the due diligence checks, the Bank ensures that all major outsourcing partners have at least ISO 27001 certification. It also has the quality of the processes checked annually by an external auditing company and documented in an ISAE report.

    Combating money laundering and financing of terrorism

    Combating both money laundering and the financing of terrorism is a top priority at Zuger Kantonalbank. The bank consistently implements Swiss and international regulations and has issued binding instructions that apply to all employees. The directive contains prohibitions on the acceptance of assets of criminal origin, on the establishment of business relationships with criminal or terrorist persons or groups, and on active assistance with capital flight or tax evasion. In addition, the directive stipulates – in accordance with the "Know your Customer” principle (KYC) – that new customers must be identified in accordance with the Swiss Banks' Code of Conduct for the Exercise of Due Diligence (CDB) and that the KYC must be regularly reviewed in accordance with the risk classification. The directive also stipulates that suspicious transactions must be checked and, in the event of suspicion or doubt, that a money laundering report be submitted to the responsible reporting office (MROS).

    Insider trading

    Due to its stock exchange listing, Zuger Kantonalbank complies closely with the requirements to prevent insider trading. To this end, it has taken organisational measures, issued instructions and carried out inspections. The same applies to stock exchange transactions that customers commission.

    Conflicts of interest Zuger

    Kantonalbank protects the interests of its clients. It has taken organisational measures to identify or avoid the occurrence of conflicts of interest. It has issued directives that set out rules of conduct aimed at preventing the occurrence of conflicts of interest as far as possible and ensuring that appropriate action is taken in the event of unavoidable conflicts of interest. If it cannot be ruled out that certain clients are disadvantaged, the conflict of interest must be disclosed to the client concerned. Furthermore, the remuneration system of Zuger Kantonalbank is designed to avoid situations in which incentives can lead to conflicts of interest.

    Organisational regulations/governance

    The relevant requirements for corporate governance are laid down in the Zuger Kantonalbank Act, in the associated articles of association and in the organisational regulations, including the competency regulations. The requirements ensure that responsibilities in terms of separation of powers (checks and balances) are clearly regulated. In doing so, the Bank Council, as an overarching management body, in particular exercises its supervision over the Executive Board.

    Business ethics and whistleblowing

    Morality and ethics are central values for Zuger Kantonalbank. If employees identify actions that are unethical or violate laws, regulations, our code of conduct or directives, they can report them to the external Integrity Plus unit. The reporting process guarantees the anonymity of the reporting person. If the reporting person decides to waive their anonymity, Zuger Kantonalbank takes measures to ensure that they are not disadvantaged.

    Stewardship

    With regard to its own investment funds, Zuger Kantonalbank engages in stewardship (proxy voting and engagement). The associated tasks have been delegated to the fund management company, which in turn works with a specialised company. For further information, please see the sales prospectus of our investment funds.

    Protection against sexual harassment, discrimination and bullying

    Zuger Kantonalbank does not tolerate sexual harassment, discrimination or bullying in the workplace. The bank takes its duty of care seriously, informs and raises awareness among its employees. All employees also have the opportunity to contact the external Integrity Plus unit on these topics.

    Sustainable procurement

    Zuger Kantonalbank is committed to lawful, ethical and socially responsible corporate governance. In terms of procurement, Zuger Kantonalbank also pays attention to sustainability and not only purchases products and services according to the cost-benefit principle, but also sets ecological, social and ethical requirements. Zuger Kantonalbank expects its suppliers to support it in this quest for sustainable procurement.

    Competition

    Zuger Kantonalbank is expressly committed to free competition. Unfair competition and unlawful market collusion are not tolerated.

    Detailed information about our responsibility in business conduct can be found in the Sustainability Report from page 29.

    Sustainability