RepoRt on - BNP Paribas

— Procedures relating to the accessibility,
integrity and retention of
information;
— Procedures relating to the flu pandemic
business continuity plan;
— numerous compliance policies and
procedures (relations with regulators,
outsourcing, controls over personal
transactions etc.).
Professional
ethics
department
this department draws up an annual
control plan, through which it ensures
compliance with the group’s code of
conduct and the proper application
by bnP Paribas sa staff of obligations
arising from the Autorité des Marchés
Financiers’ general regulations relating
to personal transactions. this includes
the prevention of insider dealing and
market abuse. no material violations
were reported in 2009.
more generally, the process of harmonising
practices with the parent company’s
high standards, and the integration
of professional ethics procedures (relating
to personal transactions, gifts and
whistleblowing) is progressing well.
in accordance with bnP Paribas’ values,
the group code of conduct sets
out fundamental principles governing
the conduct of all staff.
application procedures are used in defining
basic behavioural rules. the code
of conduct comprises ten principles.
failure to comply with them may lead
to disciplinary proceedings.
the group is constantly building and
adjusting its professional ethics systems,
in order to protect the reputation of the
bank and of its staff.
while doing this work, the group seeks
to maintain the sometimes difficult balance
between ever-tougher regulations,
respect for privacy (including application
of cnil rules), strict compliance with
the french labour code and the desire
for bnP Paribas to set the highest standards
in terms of ethics.
compliance training, which covers
protecting client interests, maintaining
market integrity and combating money
laundering, is a key responsibility of the
compliance function.
almost 60,000 training sessions (1) relating
to financial security were taken by group
staff in 2009. almost 40,000 staff received
training on other compliance themes in
2009, including client interests, conflicts
of interest, gifts and whistleblowing.
a new module to raise awareness of
compliance issues has been developed
to combat fraud, and the compliance
awareness-raising module initially introduced
in 2006 has been updated to
reflect changes in compliance.
financial
security
the mission of the bnP Paribas group’s
financial security unit is to co-ordinate
efforts to combat money laundering,
corruption and terrorist financing. it
also applies financial sanctions such as
embargos.
it sets standards for the whole group
and oversees various it projects, including
those related to filtering money flows
and monitoring transactions.
(1) Each training module taken by a member of staff counts as 1 session. An employee taking two financial security
modules in the last 12 months will be counted as 2 sessions.
132 <strong>RepoRt</strong> on CoRpoRate SoCial and enviRonmental ReSponSibility
in 2009, the system was adjusted to meet
new requirements arising from the third
european money laundering directive,
which was transposed into french law
by the order of 30/01/2009. this included
the introduction of a tool to assess customers’
sensitivity to risk.
in its operational role, financial security
handles suspected money laundering
cases in france, as well as alerts arising
from the filtering of international
money flows.
financial security also works with business
segments to provide training in its
area of expertise, both in france and in
the international network.
in 2005, the group set up a system
for monitoring entities in tax havens.
after the most recent g20 meetings,
bnP Paribas has increased its monitoring
activities and undertaken to withdraw
from certain countries that fail to
co-operate in terms of tax evasion.
following the transposition of the third
european money laundering directive,
the group will step up its efforts to monitor
business relationships with low-tax
countries.
despite the lack of any major changes
regarding financial sanctions in 2009,
the international situation gave rise to
an increase in new regulations increasing
existing restrictions. as a result of
these regulatory developments — relating
to embargos, new designations
for individuals and entities subject to
financial sanctions — instructions and
systems used within the group were
updated.
the system set up by financial security
was enhanced. this included efforts to
improve sanction lists, which are used in
various group monitoring systems, and
increased use within entities of tools for
transaction filtering, client profiling and
management of suspect transactions.
financial security also co-ordinates
procedures used to process cross-border
fund transfers, which are subject to
specific regulations.