The world's local bank Annual Report and Accounts CCF - HSBC

CCF
Risk management (continued)
pliance teams have also been reinforced to place a
greater focus on identifying accounts which should be
reported to Tracfin as suspicious.
Staff training
To support these anti-money laundering measures, the
major training campaign launched in 2002 was stepped
up in 2003 with over 4,500 employees receiving training.
The programme will continue throughout 2004
and the training package developed by a professional
consultancy in conjunction with Tracfin and the French
Banking Commission will be adapted to CCF’s various
business segments.
Compliance
2002 saw some major developments in the code of conduct
governing financial research. During 2003, the
Commission des Opérations des Bourse tightened up its
compliance regulations governing the asset management
business, most of which will come into force in
2004. Consequently, CCF took measures to integrate
these new procedures and upgrade its information systems
to comply with the new regulations.
Meanwhile, CCF has also substantially modified
its internal code of conduct. The code sets out the precautions
to be taken by all employees in terms of the
vigilance and reporting duties imposed by law on the
banking industry to help prevent terrorism financing
and money laundering. The definition of price sensitive
information and the risks involved in its use or disclosure,
notably in terms of criminal and civil penalties,
have also been supplemented and clarified.
The definition of “hypersensitive” employees, who
are subject to specific compliance rules, particularly in
terms of personal share dealings, has been extended
following the absorption of HSBC Investment Bank
by CCF in 2002. Specific provisions covering salesmen
and traders, asset managers and wealth managers have
also been incorporated into the internal code of conduct.
Their main aim is to protect the client’s interests
and uphold market integrity.
In accordance with developments in HSBC Group
rules, only hypersensitive employees are now subject
to a closed period for dealing in HSBC shares from
1 January or 30 June until the date of publication of
the Group’s results.
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