RepoRt on - BNP Paribas

procedure for control of
accounting and financial
information
Accounting internal control within
the group finance-development
function
to enable it to ensure the monitoring
of accounting risks centrally, the
group finance-development function
has combined the teams from “group
control & certification” and “bnP Paribas
sa (france) control & certification” in a
“control & certification” department.
“group control & certification” has the
following key responsibilities:
— defining the group’s policy as regards
the accounting internal control
system. this system provides for
the implementation by the accounting
entities of a certain number of
principles organising the accounting
internal control environment and
key controls geared at ensuring the
reliability of the information featured
in their consolidation reporting package.
the group has issued accounting
internal control guidelines for use
by the consolidated entities and
distributed a standard plan of accounting
controls listing the mandatory
major controls aimed at covering
the accounting risk;
— ensuring the correct functioning of
the accounting internal control environment
within the group, in particular
through the internal certification
procedure described below;
— quarterly reporting to executive
management and the financial
statements committee of the board
of directors on the quality of the financial
statements being produced
within the group;
— monitoring implementation by the
entities of the statutory auditors’ recommendations
in conjunction with
the core businesses/business lines.
this monitoring is facilitated by use
of a dedicated tool fact (finance
accounting control tool) allowing
each accounting entity to monitor
the recommendations made to
it and to regularly report on the
progress made on different action
plans. group finance-development
can identify improvements to the
accounting internal control system
made within the consolidated enti-
ties and provide, as applicable, solutions
to any cross-functional problems
that may have been identified thanks
to the centralised monitoring of such
recommendations.
the “bnP Paribas sa (france) control &
certification” team is in charge of providing
quality control on accounting information
provided by the french retail
banking network, and by corporate
and investment banking businesses that
report to bnP Paribas sa (france) and
some french entities for which group
finance-development is in charge of
their accounting. the team has the following
key responsibilities:
— liaising between the back offices
feeding the accounting system and
the group accounting department;
— training back office teams in accounting
controls and tools made
available to them;
— coordinating the “elementary certification
process” (described below)
whereby back offices report on the
controls conducted by them;
— implementing second-level accounting
controls within all entities within its
scope. these controls are in addition
to the first-level controls carried out
by back offices.
the accounting control of the french
accounting hub relies in particular on
accounting control tools that permit:
— identifying for each account, the
sector responsible for its justification
and control;
— running reconciliations of the balances
recorded in the accounting system
with the balances in the operational
systems for each business;
— identifying suspense accounts so as
to monitor their discharge.
internal certification process
• at group level
the group finance-development
function has introduced a process of
internal certification of quarterly data
produced by the different accounting
entities, as well as of the controls performed
within finance departments
of the core businesses/business lines
and by the consolidation department
within the group finance-development
function. the process uses the fact
(finance accounting control tool) internet/intranet-based
application.
126 <strong>RepoRt</strong> on CoRpoRate SoCial and enviRonmental ReSponSibility
the Heads of finance of the entities
concerned certify to group financedevelopment
that:
— the accounting data reported to
the group finance-development
function are reliable and comply
with group accounting policies;
— the accounting internal control system
designed to ensure the quality
of accounting data is operating
effectively.
since the first quarter of 2009, the main
certificate completed by all entities
consolidated by global or proportional
integration reproduces all of the major
controls defined in the standard accounting
control plan published by
group finance-development and not
only a selection of such controls.
this internal certification process forms
part of the overall group accounting internal
control monitoring system and enables
the group finance-development
function, which has overall responsibility
for the preparation and quality
of the group’s consolidated financial
statements, to be informed of any problems
in the financial statements and to
monitor the implementation by the accounting
entities of appropriate corrective
measures and, if necessary, to set
aside appropriate provisions. a report on
this procedure is presented to executive
management and to the financial
statements committee of the board
of directors at the close of the group’s
quarterly consolidated accounts.
• at entity level
the certification procedure vis-à-vis
the group requires a suitably adapted
accounting internal control system for
each accounting entity that gives the
local finance function an overview of
the entire accounting process. towards
this end, “group control & certification”
recommends implementing an “elementary
certification” (or “sub-certification”)
process for accounting data whenever
the processing of transactions and the
preparation of accounting and financial
data are organised in such a way that
such process is necessary.
this process requires that those involved
in preparing accounting data and in
performing accounting controls (e.g.,
middle office, back office, Human
resources, risk management, tax
department, management control/
Planning, accounts Payable, treasury,