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Français/English - Arab Banking Corporation, ALGERIA

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Corporate Governance<br />

l The Business Continuity Plan: It is responsible for developing<br />

the plan and procedures for business continuity. It regularly tests<br />

functioning of this plan.<br />

l Implementation of internal control in the subsidiary ALC: The<br />

scope of activity of internal control is extended to all related<br />

companies (wholly or jointly controlled), thus it ensures the<br />

implementation of systems control within the affiliate and<br />

integrates the results of these checks in the periodic reports.<br />

COMPLIANCE<br />

ABC Algeria is fully committed to complying with all regulatory<br />

provisions in force in Algeria and to adopting best practices and<br />

the standards applicable to the finance sector. To do this, the<br />

Compliance Officer is responsible for:<br />

l drawing up and keeping updated the legal mechanism in force<br />

within ABC Algeria;<br />

l ensuring constant compliance of the acts and management of<br />

the bank with this mechanism;<br />

l carrying out compliance checks and providing assistance to the<br />

bank’s different structures;<br />

l implementing anti-money laundering and the financing of<br />

terrorism actions;<br />

l assuring that the procedures comply with the law and<br />

regulations, before being approved by the Procedure Validation<br />

Committee (compliance approval);<br />

l informing the Ongoing Audit and Internal Audit Departments of<br />

all laws or regulations (new text or update);<br />

l coordinating the sending out of the annual internal control<br />

report to the Bank of Algeria.<br />

ABC Algeria has drafted policies and procedures containing<br />

specific guidelines for its personnel in terms of compliance,<br />

international sanctions, acceptance of customers, dealing with<br />

complaints and claims made by customers and the correct<br />

application of the laws in force and compliance with the strictest<br />

standards. It has also adopted a Code of Conduct and Ethics which<br />

contains all rules of ethics which can be imposed in the business<br />

areas of the bank.<br />

The Compliance Officer is also responsible for the “fighting against<br />

money laundering and the financing of terrorism” function. He<br />

is appointed Money Laundering Reporting Officer (MLRO) and<br />

reports directly to the Group MLRO, to the Senior Management<br />

and to the Board of Directors. His main tasks include notions<br />

which consist of sending suspicious transaction reports to the<br />

CTRF and putting in place the AML procedures, policies, controls<br />

and systems as well as scheduling appropriate training for<br />

employees. He is also in charge of assuring compliance with the<br />

international principles on this matter.<br />

This year, the Compliance/AML Department set about reinforcing<br />

what has been learned from the previous years and contributing<br />

to the implementation of new policies and procedures so that<br />

the Bank can be protected against any threat or lack of noncompliance,<br />

particularly after the promulgation of the new<br />

Regulation 11-08 of 28 November 2011 on the internal audit<br />

of banks and financial institutions, the Regulation 12-03 on the<br />

prevention and the fight against money laundering and the<br />

financing of terrorism and the Instruction 03-2012 establishing<br />

the procedure as to the right to an account.<br />

As audit today is everyone’s job, employees are regularly<br />

informed as to the need to look into all the transactions carried<br />

out by customers in order to identify those which are not part<br />

of the normal activity of the customer. To do this, the bank has<br />

intensified the training and awareness-raising actions of its<br />

personnel by putting in place an ambitious programme which has<br />

seen the organisation of five external training courses and ten<br />

internal ones, including an on-line course on money laundering in<br />

collaboration with the parent company and Thomson Reuters.<br />

This year has also seen the intensification of compliance missions<br />

in the branches inside the country; these missions are supported<br />

by training courses on money laundering given to the employees<br />

of these branches and the putting in place of new computer<br />

applications such as the electronic KYC sheet and the warnings<br />

reports on suspicious transactions.<br />

INTERNAL AUDIT<br />

The Internal Audit Department reports administratively to the<br />

Managing Director and hierarchically to the Audit Committee of<br />

ABC Algeria (sub-committee of the Board of Directors).<br />

The extent of the internal audit works includes the examination<br />

of the risk management procedures, the internal audit systems,<br />

the information systems and the governance process in order to<br />

achieve the goals and objectives fixed in its annual plan through<br />

examining:<br />

l the reliability and integrity of the financial information and<br />

management tools;<br />

l the mechanisms put in place to assure that the Bank complies<br />

with the policies, procedures, laws and regulations and those<br />

likely to have a significant impact on operations and reporting;<br />

l the existence of the Bank’s assets and the means put in place<br />

to protect them;<br />

l the effectiveness of the risk management mechanisms;<br />

l the effectiveness in the implementation of the<br />

recommendations of the various audit bodies.<br />

In addition to the local regulatory provisions as to internal audit<br />

particularly the Regulation 11-08 of 28 November 2011 on the<br />

internal audit of banks and financial institutions, the Internal<br />

Audit Department adheres to the various codes, standards and<br />

best professional practices of the Institute of Internal Auditors<br />

(IIA) as well as the reports and recommendations of the Basel<br />

Committee on Bank Audit.<br />

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