Our decision-making procedures and organisational structure clearly specify reporting lines, functions and responsibilities. Our organisational chart, which is approved by the Board, shows the division of responsibilities amongst members of the Management Committee, by region, business line, and support function.
Internal control systems include:
- An independent Compliance function, responsible for monitoring compliance with regulatory obligations and reporting breaches to management on a timely basis
- A Risk Management area which evaluates and monitors risk within a defined strategy set by the Board of Directors
- An Internal Audit department which examines and evaluates the adequacy and effectiveness of internal control mechanisms and activities.
A compliance officer is appointed for the Bank by the Board of Directors. The compliance officer is supervised by the Bank’s internal auditor.
The responsibilities of the Bank's compliance officer include the following:
- Overseeing compliance with the Bank’s General Rules on Working Procedures, including rules on treatment of insider information and insider trading, participation of employees in commercial operations, separation of operational divisions, rules on actions to combat money laundering and terrorist financing and the Bank’s proprietary trading;
- Maintaining a record of employees’ transactions as provided for in the General Rules and the exceptions granted to them;
- Taking the initiative in interpreting Company rules and making decisions based upon them;
- Informing employees of the Bank’s internal rules;
- Keeping a record of employees working across the boundaries of separated divisions;
- Receiving complaints from clients concerning alleged violations of the Bank’s internal rules and directing them to the proper channels; and maintaining a record of these complaints and carrying out other specifically assigned tasks.
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