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HSBC France € 20,000,000,000 Euro Medium Term Note Programme

HSBC France € 20,000,000,000 Euro Medium Term Note Programme

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37<br />

in <strong>20</strong>07: business operations including among others Asset Management, investment funds, employee savings,<br />

factoring, compliance, commu nication, IT Systems Department, procurement, risk management and lending<br />

operations are scheduled for the first half of <strong>20</strong>08 for the remaining operations.<br />

A consultation took place, both with the FBF (French Banking Federation) and internally, to define specific<br />

plans that would meet the public authorities’ expectations for dealing with other major risks that could affect<br />

business continuity, such as floods and pandemics. This effort is due to result in specific business<br />

continuity/resumption plans being drawn up.<br />

Lastly, a business security department set up in <strong>20</strong>06, is responsible for crisis management and oversight of the<br />

<strong>HSBC</strong> <strong>France</strong> group’s business continuity plans.<br />

Dependency<br />

<strong>HSBC</strong> <strong>France</strong> is not dependent on any patents or licences or industrial, commercial or financial supply contracts.<br />

Environmental risks<br />

The Corporate Social Responsibility policy is described on pages 40 to 46 of <strong>HSBC</strong> <strong>France</strong>’s annual report for<br />

<strong>20</strong>07.<br />

COMPLIANCE RISKS<br />

Compliance risk is the risk of judicial, administrative or disciplinary sanctions, financial loss or damage to<br />

reputation associated with failure to comply with provisions of law, regulation, professional rules or codes of<br />

conduct applicable to banking and financial activities.<br />

Organisation of compliance control<br />

Within the <strong>HSBC</strong> <strong>France</strong> group, the compliance risk control system is directed by the Compliance Department.<br />

Effective March <strong>20</strong>06, all compliance personnel within the <strong>HSBC</strong> <strong>France</strong> group report hierarchically to the<br />

Compliance Department so as to ensure full independence of the compliance function from the operational<br />

activities, as required by CRBF Regulation 97-02. The Compliance Department consists of five departments<br />

reporting to the Head of Compliance: four departments specialised by business line (Retail Banking and<br />

Insurance; Global Banking and Markets; Asset Management; Private Banking) and a central compliance<br />

department responsible for ensuring that the system is internally consistent.<br />

As part of its role of coordinating and leading the compliance control effort, the Compliance Department is<br />

responsible for:<br />

• monitoring regulatory developments that will have an impact on the activities of the <strong>HSBC</strong> <strong>France</strong><br />

group, jointly with the Legal and Tax Department;<br />

• identifying the compliance risks associated with the activities conducted by <strong>HSBC</strong> <strong>France</strong>;<br />

• preparing and updating the necessary procedures and instructions to achieve compliance in practice with<br />

legal and regulatory provisions;<br />

• informing and training employees with regard to the compliance obligations arising from their activities<br />

and responsibilities;<br />

• performing an advisory function for operating managers to assist them in meeting compliance<br />

obligations;<br />

• organising and, in coordination with the internal control departments of the business lines and<br />

subsidiaries, carrying out the permanent controls of compliance;<br />

• coordinating relations with regulatory authorities.

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