N26’s commitment to identify risks and fight financial crime

N26 AG (“N26”) and each of its majority-owned subsidiaries (together with N26 Bank AG, the “Group”) are firmly committed to participating in combating and preventing financial crime.

N26, legally registered in Berlin (Germany), is a regulated financial holding company, licensed pursuant to Section 2(f) German Banking Act (“KWG”), supervised by the German Federal Financial Supervisory Regulator (“BaFin”), and obliged to fulfil its anti-money laundering (“AML”) and counter-terrorism financing (“CTF”) obligations pursuant to Section 2 German Money Laundering Act (“GwG”).

N26 implemented an Anti-Financial Crime (“AFC”) Framework and AML/CTF Compliance Program designed to observe applicable laws, regulations, regulatory guidance and best practice issued by the respective authorities and bodies at an international, regional or national level, such as the ones issued by the European Union (“EU”) and the jurisdictions where N26 operates.

The program implemented by N26 complies with required applicable German AML/CTF laws and local regulations related to the prevention of money laundering, terrorist financing, and financial crime, which is taken as minimum standards throughout the company. Furthermore, the AML Compliance Program applies local laws, regulations and guidance from the jurisdictions it operates in. This protects N26, its customers, investors, employees, and the financial system from the abuses of illicit finance.

As part of its AML/CTF Compliance Program, N26 has implemented AML/CTF written policies and procedures that include:

• The appointment of a Group and local Money Laundering Reporting Officers (“MLRO”) as required by local regulation;
• The adoption of minimum Identification and Verification (“ID&V”) and Know Your Customer (“KYC”) principles;
• The establishment of Customer Due Diligence (“CDD”) processes and Enhanced Due Diligence measures for customers who might present a higher financial crime risk such as Politically Exposed Persons (“PEPs”) and their relatives and close associates (“PEP associates”);
• The implementation of processes and integrated IT systems designed to screen customers and monitor their transactions for the purpose of identifying potential suspicious activities;
• The investigation and reporting of suspicious activity to the appropriate Financial Intelligence Unit (“FIU”);
• The establishment and execution of regular and mandatory AFC trainings for all employees and contractors;
• The conduct of regular independent testing and quality assurance by second line as well as audit by third line internal and external Audit.

N26 is committed to combating and preventing financial crime. One of the ways we do that is by complying with major sanctions regulations as well as the local regulations of the markets where N26 operates. In addition to the sanctions regulations, we apply our own sanctions policy which may result in the rejection of certain transactions, blocks and account freezes as well as a curtailment of services that may otherwise be permissible by law. These prohibitions generally apply to relationships and dealings linked or believed to be linked to sanctioned individuals and entities, comprehensively sanctioned countries and territories as well as a list of governments targeted by sanctions and their related entities. Any exception will be considered on a case-by-case basis at N26’s sole discretion.

N26 has a zero tolerance approach to any attempt of Bribery and Corruption. N26 and all employees of N26 are prohibited from engaging in any Bribery and Corruption. N26 has established an Anti-Bribery and Corruption Programme which is overseen by the Management Board. This Programme enables N26 and all employees to comply with all national and international laws and regulations that prevent Bribery and Corruption.

As part of the Anti-Bribery and Corruption Program, N26 adopted an Anti-Bribery and Corruption Policy (AB&C Policy) that describes the principles and standards to ensure compliance with related laws and regulations, and allows the implementation of correct measures to mitigate the risk of bribery and corruption. Minimum standards defined in AB&C Policy have to be observed by all employees of N26, including the Management and Supervisory Board, without any exception and irrespective of their location, function or level. These minimum standards prohibit anyone from engaging in any bribery and corruption activity. N26’s Management Board and Senior Management represent and uphold compliance culture and ethical behaviour within the company.

The AB&C Policy includes an adequate framework to avoid the materialisation of bribery and corruption risks in the course of N26 normal business activities, establishing clear guidelines for accepting or offering benefits in exceptional cases. Processes implemented include clear guidelines for the approval process with an overview of roles and responsibilities of the involved parties. The AB&C Policy contains clear prohibition or regulation in regards, but not limited to:

• Gifts and business hospitality;
• Third parties (partners) business hospitality;
• Sourcing and procurement agreements;
• Charitable and political contributions;
• Job offers or internship awards;
• Marketing sponsorship.

N26 implemented an annual mandatory Anti-Bribery and Corruption Training for all employees with focus on bribery and corruption risks that could affect N26. N26 employees must ensure that their interactions or relationships do not induce improper actions to obtain business advantage.

N26 maintains a Whistleblowing Programme, ensuring that any employee can issue concerns regarding bribery and corruption, safeguarding the principle of anonymity and non-retaliation when reporting their concerns.