BPCE - 2020 Universal Registration Document

NON-FINANCIAL PERFORMANCE STATEMENT

BEING A RESPONSIBLE GROUP IN ITS INTERNAL AND EXTERNAL PRACTICES

a harmonized training program for Group employees, • conducted at least once every two years, and specialized training for the Financial Security function. ORGANIZATIONAL STRUCTURE In accordancewith Groupe BPCE’s charters, each institution has its own financial security unit. Within the General Secretariat, a department is responsible for the prevention of money laundering and the financing of terrorism. It determines the financial security policy for the entire Group, establishes and obtains approval for standards and procedures, and ensures that money laundering and terrorism financing risks are taken into account in the Group’s procedures for approving new products and services.

out, if necessary, the reinforcedexaminationsand the necessary declarations to Tracfin (processing and action against illegal financial circuits) as soon as possible. The declarations are made in respect of money laundering or terrorist financing and/or tax fraud. The Group risk classification incorporates the issue of “at-risk” countries, whether in terms of money laundering, terrorism, tax fraud, or corruption, as well as the politically exposed status of the client or its beneficial owners, for legal entities. The transactions of high-risk customers are subject to particular vigilance. It enhanced its systems in 2018 with the introduction of a set of standards and automated scenarios tailored to the specific features of terrorist financing. With respect to compliance with restrictive measures related to international sanctions, Group institutions are equipped with screening tools that generate alerts on customers (asset freezes on certain individuals or entities) and international flows (asset freezes and countries subject to European and/or US embargoes). SUPERVISION OF OPERATIONS Internal reports on the prevention of money laundering and terrorist financing are submitted to company directors and governing bodies, as well as to the central institution.

SPECIALIZED DUE DILIGENCE

In accordance with regulations, the institutions have largely automated means of detecting atypical transactions, adapted to their risk classification. Alerts are mainly handled by the networks, as close as possible to KYC. Those that are identified as giving rise to a doubt that could not be resolved are usually referred automatically to financial security, enabling it to carry

ACTIVITIES IN 2020 In the area of international financial sanctions and embargoes, a central team has been set up to pool part of the processing of alerts on behalf ofthe Group’s institutions and strengthen the effectiveness otfhe system. The Group has launched a program to update its knowledge of its customers according to therisks of money laundering and the financing of terrorism.

ANTI-MONEY LAUNDERING EMPLOYEES TRAINED IN ANTI-MONEY LAUNDERING PROCEDURES

Change 2018-2019

2020

2019

2018

2017

Percentage of employees trained in their entity’s anti-money laundering policies and procedures (based on reports from the entities) (1)

99%

77%

79%

90%

28.6%

Number of employees (on permanent, fixed-term or work-study contracts) who have received anti-money laundering training in the last two years. (1)

CUSTOMER PROTECTION Groupe BPCE protects its customers’ interests by tasking committees with the approval of new products, services and sales processes and any upgrades. The organization and missions of the Group Compliance department in charge of the compliance of banking and insurance products and financial products are detailed in the section Non-compliance risks and security of Chapter 6 – Risk Management. In 2010, Groupe BPCE introduced an approval procedure for new banking and financial products and services. This procedure is designed to manage the risks associated with the sale of products and services and the implementation of new sales processes (digitalization, etc.) and to take into account the regulatory requirements aimed at protecting customers’ interests and personal data. The approval procedure includes contributions from the competent experts and business lines within BPCE. This procedure must be completed before the new product or sales process is presented to the Group’s approval committees prior to marketing or development. The approval system was overhauled in 2020 with the holding of a first Market Validation Committee on September 18.

FIGHTING AGAINST INTERNAL FRAUD Groupe BPCE has set up a common system to combat internal fraud, non-compliancewith internal regulations and breaches of ethics, in line with the Group’s Code of conduct and ethics. This system makes it possible to meet the requirements of the supervisory authorities and to pool the resources and work carried out by the institutions. It is formalized in a framework procedure and consists of the following elements: requests for detection, in particular of potentially fraudulent • transactions of which vulnerable customers could be victims, supplemented by additional sources for reporting alerts; a fraud management tool; • awareness-raising and information tools (depending on their • specific nature, the banks may implement their own awareness-raising actions); a training program; •

a psychological support system; • a declaration and reporting system; • anti-corruption measures. •

100

UNIVERSAL REGISTRATION DOCUMENT 2020 | GROUPE BPCE

www.groupebpce.com

Made with FlippingBook - Online Brochure Maker