Banken for en verden i endring The bank for a ... - BNP Paribas

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Banken for en verden i endring The bank for a ... - BNP Paribas

• report of the Chairman / internal control

pLAyERS INVOLVEd IN pERmANENT

CONTROLS

The players involved in Permanent Controls are:

• the operational staff working in commercial,

administrative or support functions. They

directly control the operations for which they

are responsible, based on Group procedures.

These controls are known as first-level permanent

controls;

• managers, who perform controls as part of

operational or autonomous control procedures.

These controls are known as secondlevel

permanent controls;

• specialised functions autonomously integrated

within operational units or independent

of these units, which perform controls that are

independent of operations. These controls

are also known as second-level permanent

controls.

ThE pLAyERS INVOLVEd

IN pERIOdIC CONTROLS

Periodic Controls (known as third-level controls)

are carried out on an independent basis

by the General Inspection unit, which includes:

• Inspectors based at headquarters, who are

authorised to carry out controls throughout

the Group;

• Auditors within the various entities of the

Group, who now report to the General

Inspection unit.

Periodic Controls fall under the responsibility of

the Head of the Bank’s General Inspection unit,

who reports operationally to the Chief Executive

Officer and reports functionally both to the CEO

and to the Board’s Internal Control and Risk

Management Committee.

COORdINATION

Of INTERNAL CONTROL

The Internal Control Coordination Committee

(ICCC), which meets on a monthly basis,

includes the following participants:

The key players involved in Permanent

Controls:

- the Heads of Group Compliance, Group

Finance-Development and Group Risk

Management;

- the Heads of Group Tax Affairs, Group

Legal Affairs and the Group Operational

Effectiveness function.

- the Heads of the four core businesses;

The Head of Periodic Controls. Members of

the Bank’s Executive Management may participate

in all ICCC meetings. The heads of

other Group functions may be invited to participate

in the Committee’s meetings.

At Group level, coordinating Compliance work

is the responsibility of the Head of Compliance,

who sits on the Executive Committee and chairs

the Internal Control Coordination Committee.

The ICCC:

• is not intended to replace the different Group

Risk Management Committees but to enhance

their effectiveness within the overall system;

• guarantees the consistency of the Internal

Control system and its compliance with

regulations;

• seeks to promote the use of Internal Control

tools as widely as possible within the Group;

enhances the consistency of annual reports

on Internal Control and Control of Investor

Services prepared by the Permanent Control

and Periodic Control functions as required

under their “Charter of responsibilities”, and

of the report of the Chairman of the Board of

Directors on Internal Control procedures prepared

in accordance with Article L. 225-37 of

the French Commercial Code.

171

CORPORATE GOvERNANCE

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