Commerzbank AG and its branches, affiliates and subsidiaries (collectively referred to hereinafter as Commerzbank) are firmly committed to participating in international efforts to prevent money laundering and the financing of terrorism. To this end Commerzbank has implemented a programme to prevent its products and services from being misused for such criminal activity in compliance with applicable rules and international best practices.

At Eurohypo AG, as a subsidiary of Commerzbank AG, there are guidelines and systems in place to protect the interests of its clients and maintain confidentiality. They are also aimed at preventing Eurohypo AG from being used in connection with criminal activities and are based on a risk-oriented approach.

The USA PATRIOT (Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism) Act, signed into law by President Bush in October 2001 requires financial institutions to put in place stringent compliance programs regarding the activities of a broader range of account holders than ever required before. Commerzbank AG as parent company certifies the compliance with the USA PATRIOT Act.

Every Eurohypo employee is aware of his or her responsibility to the public, to Eurohypo clients as well as shareholders and colleagues. This responsibility is enshrined in the Code of Conduct below, which is an extract from the Eurohypo Compliance Manual that applies throughout the Group.