Code of conduct and ethical principles

Transparent, fair, responsible and honest conduct – with the required degree of expertise, professionalism and integrity in dealings with one other and in relation to clients and business partners, competitors and the public – are deeply rooted in pbb, and demand that the relevant legal, supervisory and internal requirements as well as other relevant laws and regulations, are implemented and adhered to.

Within pbb, the Group’s code of conduct set outs the ethical and legal framework. Details of the non-negotiable requirements that pbb Group expects of all its employees are available to the public on pbb’s website.

The code of conduct offers very clear guidance on questions regarding relationships with clients, suppliers, shareholders, investors and competitors – as well as how to respond to conflicts of interest, bribery, the granting of undue benefits, preventing money laundering and market abuse. pbb Group does not support business practices that could harm its reputation or give rise to the suspicion that the Group assists clients in violating its ethical standards or in breaking the law. The applicable law, as well as all the regulatory provisions in force in the various jurisdictions where pbb Group does business, form the basis for the entire corporate decision-making process and day-to-day operations. They are complemented by internal regulations and detailed process descriptions.

As a listed company, pbb adheres to the German Corporate Governance Code and is subject to the principle of “comply or explain”. This Code describes the legal requirements laid down for Managing and supervising German listed companies, and reflects the current national and international developments and standards of good and responsible corporate management.


Compliance means ensuring adherence to legal and other requirements by building an organisation that proactively meets these needs and implementing additional measures. This is particularly true for legal requirements regarding the trading and/or managing of securities/assets. Compliance with these requirements serves the goal of client/investor protection and, as a consequence, the protection of pbb’s reputation. At the core of the norms pbb must adhere to, lie the EU Market Abuse Regulation, the German Securities Trading Act, and the regulations and guidelines based on These documents. Compliance risks include sanctions, financial losses and reputational losses that may arise from violations of these regulations.

pbb employees are bound by numerous internal guidelines and instructions, for example on combating criminal acts, on information security, on preventing money laundering and the financing of terrorism.

In pursuit of the goals of raising awareness amongst and educating staff, pbb employees are obliged to take part in compliance trainings on a regular basis. These trainings cover a variety of topics, including the prevention of money laundering and other criminal acts such as corruption (granting or accepting benefits, engaging in active or passive bribery), breach of confidentiality and tax offences, as well as general compliance issues. Successful participation in these trainings is only certified after completion of a test. Group Internal Audit regularly reviews how such training is conducted.

As a shield against corruption, pbb Group has established clear principles and guidelines for proper and professional conduct – for example in case of conflicts of interest, fighting corruption and active and passive bribery. Special attention is given to accepting and granting benefits and gifts.

In their interaction with government representatives and public agencies, staff must refrain from any actions that could unlawfully influence the decisions of officials. In particular, cash payments, gifts and other benefits or perquisites to officials that could, in any way, be interpreted as undue influence, bribery or corruption, are prohibited. As a rule, political donations of any kind are not permitted within the Group where they are effected in a professional context.

Pursuant to article 18 of the market abuse regulation, issuers or any person acting by order of, or for the account of, such issuer must maintain lists of persons who are active on their behalf, and who are authorised to access inside information. pbb Group shall inform those persons identified in such lists as to the legal duties associated with access to inside information, and with regard to the legal consequences of violating these regulations.



Dr. Christiane Pöppelmann
Head of Compliance

Phone: +49 89 2880 11481