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

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

• report of the Chairman / internal control

hIGhLIGhTS Of 2006

Following two consecutive years of largescale

change, Group Internal Control gradually

strengthened its position in 2006 with the

ramp-up of new processes set up by the Group

Compliance and Permanent Controls functions,

on the one hand, and the General Inspection

unit on the other.

Group Compliance function

Compared to the former Ethics Department

which it replaced at the end of 2004, the

Compliance function has a broader remit: it is

tasked with enhancing compliance, defined as

“conforming to legal and regulatory provisions,

professional and ethical standards, as well as

the overall strategy of the Board of Directors

and Executive Management guidelines”.

The Compliance function has also significantly

enhanced its independence by establishing

supervised knowledge-sharing arrangements

with the heads of operating units for the teams

in charge of compliance in the core businesses

and support functions. These arrangements

are far more extensive than previously existing

ones. The Head of Compliance reports to

the Chief Executive Officer and represents the

Bank at the Commission Bancaire with regard

to all matters concerning Permanent Controls.

In 2006, the organisation of the Compliance

function was tailored to changes in the regulatory

environment and in the Group’s scope of


Regarding regulations, the entry into force of

the European directive on “market abuse” has

expanded the reach of requirements in the area

professional ethics, which now cover new areas

related to protecting market integrity (by detecting

any market price manipulation and insider

trading, and maintaining lists of insiders) and is

applicable to all Group entities outside France.

BNP Paribas anticipated the entry into force of

the directive on markets in financial instruments,

by setting up a dedicated unit in charge of overseeing

the important measures that will need to

be taken in operational and sales functions as

well as in the Compliance Department – with

regard to conflicts of interest, improved execution,

“suitability” and more.

The organisation of the Compliance function was

also modified in response to the Group’s expansion,

especially the addition of Banca Nazionale

del Lavoro. This subsidiary’s Compliance function

was aligned with the BNP Paribas model,

to enable it to bring its Permanent Controls and

Compliance processes up to Group standards

in the shortest possible timeframe.



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