RepoRt on - BNP Paribas

the
ComplianCe
funCtion Within
bnp paRibaS
bnP Paribas’s compliance function
(group compliance) is a key element
of the group’s internal control system. it
was created in 2006 to deal with issues
that very quickly became regulatory requirements.
the relevant provisions are
crbf regulation 97-02 regarding the internal
control of credit institutions, and
the general regulations of the Autorité
des Marchés Financiers, amended following
the transposition into french law
of the european directive regulating
markets for financial instruments.
managing risks of all kinds is a vital part
of bnP Paribas’ organisation, management
and strategy. Particular attention
is paid to compliance risks. according
to the group’s definition, compliance
is “respect for legislative and regulatory
provisions, professional and ethical standards,
guidelines given by the Board of
Directors and instructions given by head
management.” it involves protecting the
group’s reputation and implementing
conduct rules, including respecting
market integrity and the primacy of
client interests, helping to combat money
laundering, terrorist financing and corruption,
and complying with financial
embargos and professional ethics.
compliance applies exhaustively and
universally, i.e. to the same degree
regardless of the activity or entity, in
france or abroad, through the application
of the “ethical highest bidder”
principle. this principle requires that, of
the rules set out by legislation and regulations
in various territories and those
arising from the group’s directives and
procedures, the most demanding ones
should be followed.
dedicated
teams
group compliance is under the ceo’s
direct authority and is led by a member
of the executive committee, who is also
responsible for co-ordinating the internal
control system.
group compliance has a central team
as well as decentralised teams. the
central team supervises and co-ordinates
the compliance function within
the group, and establishes the applicable
standards. decentralised teams
within business segments, business lines,
functions, subsidiaries and branches
are in direct contact with operations.
their headcount was stable relative to
2008, with around 900 fte staff, equal
to almost 95% of all compliance staff.
decentralised teams are supervised in
two ways. they are supervised in functional
terms by group compliance, and
in hierarchical terms by those responsible
for entities’ operations, in line with
the principle that operational staff have
primary responsibility for risk.
in 2009, the central team continued its
work to provide the group with a highlevel,
up-to-date body of standards.
this work included:
— tasks relating to the fortis integration:
procedure for managing conflicts
of interest involving the group’s
minority shareholders and critical
compliance requirements arising
from the bnP Paribas – fortis / bgl
integration;
131 <strong>RepoRt</strong> on CoRpoRate SoCial and enviRonmental ReSponSibility
baudouin prot, Ceo 
 of bnp paribas, reiterated
the code of conduct’s
importance in a letter sent
to all staff:
“At BNP Paribas,
we pride ourselves on
the reputation for excellence
which we have established
with our clients, counterparties
and authorities in all the
countries in which we operate.
This reputation is key
to the success and stability
of BNP Paribas. Our reputation
rests primarily on the quality
and integrity of our
employees. Our corporate
values (responsiveness,
creativity, commitment
and ambition) are reflected
in our work and we must
behave in an exemplary
manner. The BNP Paribas
Code of Conduct sets out
the fundamental rules
of conduct in force within
our firm.
I expect each and every
one of you to strictly comply
with this Code of Conduct,
regardless of your position
or the services you provide,
in order to guarantee
the success and stability
of our Group.”