How we manage the bank?

Risk management, compliance, AML, whistleblowing, remuneration

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Risk management

Risks are an integral part of every business activity. An informed and transparent approach to risk management is a central component of our socially responsible business model. In line with the risk strategy of the entire group, ProCredit Bank in Germany takes a conservative approach to risk management.

The basic principles of our approach to risk management include

  • a focus on our core business,
  • transparency and simplicity in all of our procedures and services, and
  • careful recruitment of staff followed by intensive training.

The fact that ProCredit Bank refrains entirely from engaging in certain areas of business stems from our long-standing identity. That is why all ProCredit banks are explicitly forbidden to trade in securities or foreign currencies beyond what is necessary to meet demand from clients, manage liquidity or guard against currency risks. Our business model also prohibits speculative investment transactions.

Compliance and anti-money laundering

The broad range of illegal or suspicious practices in the financial industry has recently re-ignited the discussion of compliance issues. As part of the international group of ProCredit banks, we see ourselves as holding a position of particular responsibility with regard to supporting international efforts to fight money laundering, terrorist financing and other acts punishable by law; adhering to all legal regulations (compliance); and ensuring that staff act in accordance with our internal code of conduct. The compliance function is performed by the legal department at ProCredit Bank.

The ProCredit Banks are required to uphold strict standards worldwide regarding the fight against money laundering and other illegal acts. In the interest of preventing these activities, the ProCredit group is guided worldwide by a uniform concept that incorporates all relevant legal and regulatory requirements, and adherence is monitored by ProCredit Holding. (Among other things, this concept has integrated the recommendations of the Financial Action Task Force on Money Laundering (FATF) as well as the recommendations and standards of the Basel Committee on Banking Supervision.) A special IT system monitors new and existing clients as well as ongoing transactions. Suspicious behaviour is reported to the Management Board of ProCredit Bank and to the AML officers of the group on a regular basis.

More information on the subject of money laundering can be found on ProCredit Holding's website under Anti-Money Laundering and the company’s Financial Reports.

Whistleblowing system

As part of the ProCredit Group the development-oriented ProCredit Bank in Germany is committed to maintaining high ethical standards with regard to our business activities and their impact on the environment and the social environment.

Our aim is to promote unbiased communication within the bank based on a common “ethical compass” and to create a professional climate in which honest and credible communication is a matter of course.

We therefore offer an open working atmosphere, which enables our employees to communicate directly with team leaders, Human Resources, Internal Audit, the Compliance Officer or Management. In addition, ProCredit Bank has a whistleblowing system that also allow for anonymous contact if grievances need to be addressed.

All employees and managers of the ProCredit Bank AG, as well as our customers and business partners and the general public, bear the responsibility for noticing and clearly addressing illegal, fraudulent or unethical behaviour.

If, in connection with our business activities and their impact on the environment and the social environment, you wish to disclose information about actions that have been committed with criminal intent, such as criminal violations of our Code of Conduct, internal policies or procedures, or violations of applicable law, you may contact us at the following e-mail address:

We process all indications of violations committed with criminal intent consistently and according to equal standards.


As transparency is one of our key values, and also in compliance with the Ordinance on the Supervisory Requirements for Institutions’ Remuneration Systems (§ 16 Abs. 1 InstitutsVergV i.V.m. Art. 450 of regulation (EU) No. 575/2013), we publish the following information on our remuneration system.

Remuneration for all staff is based on the standard principles established for the ProCredit group. The amount of remuneration is agreed when concluding the employment contract and is adjusted individually on a case-by-case basis. Our remuneration system does not provide any incentive to take undue risks. In addition, it does not create any incentives that could interfere with the monitoring duties of employees performing a controlling function.

In principle, ProCredit Bank AG only offers fixed remuneration components. Extraordinary payments are only made in individual cases and at the discretion of the Management Board. These payments are independent of the individual employee’s quantitative performance contributions and do not constitute a legal entitlement to receive such payments in the future.

Total staff expenses, including employer contributions to social security and pension insurance in the BVV (Versicherungsverein des Bankgewerbes) came to EUR 4.3 million in the 2022 financial year.

The Supervisory Board defines the remuneration of the management, including any possible extraordinary payments. The remuneration system has been designed in an appropriate manner. It provides no incentives to take undue risks.

According to the parameters stipulated in the Remuneration Ordinance for Institutions (InstitutsVergV), we do not qualify as a “major institution”. Therefore, the requirements for such institutions pertaining to separate risk analyses do not apply.

For detailed information on the subject of Risk Management and Remuneration please see the Disclosure Report published in accordance with CRR by our parent company, ProCredit Holding AG.