Principles and Policies of Compliance
The objective of the Compliance & Corporate Governance Division is to prevent and effectively manage the risks of non-compliance of the Bank and its Group companies with the regulatory framework governing their operation, by establishing appropriate policies and procedures and adopting mechanisms for the identification, control and monitoring of the relevant risks. In addition, it is responsible for monitoring compliance with the principles and practices on the basis of which the Bank is organized, operated and managed in order to safeguard and satisfy the legitimate interests of all those associated with the Bank.
The Compliance and Corporate Governance Division was established in the context of the implementation of the rules of the supervisory framework BASILIA (as currently in force) and the provisions of the PDE 2577/2006, and is responsible for managing the risk of non-compliance by the Bank and the Group companies with the provisions of the applicable regulatory framework. It is organisationally subordinate to the Chief Executive Officer, prepares reports to the Audit Committee and the Board of Directors on matters relating to its responsibilities and is subject to the control of the Internal Audit Unit as regards the adequacy and effectiveness of its procedures. As an administratively independent unit, it has unrestricted access to all data and information necessary for the fulfillment of its tasks and is headed by a selected person (Head of Compliance) with sufficient knowledge of banking and investment activities.
Responsibilities of the Compliance and Corporate Governance Division
The prevention and effective management of the risks of non-compliance of the Bank and its Group companies with the legal and regulatory framework governing their operations, through the establishment of appropriate policies and procedures and the adoption of mechanisms for the identification, control and monitoring of the relevant risks.
Its remit also includes receiving, examining and settling complaints and grievances of customers and traders towards the Bank, ensuring that they are investigated fairly and objectively, and that they are answered in a timely and written manner, based on information and opinions received and obtained from the relevant Units or Services. In particular, inter alia:
- Monitoring the compliance of the Bank and the Attica Bank Group with the applicable legal and regulatory framework, which regulates the prevention of the use of the financial system for money laundering and terrorist financing. To this end, it is responsible for monitoring the compliance of the Bank’s organizational units with the obligations arising from the aforementioned framework, as well as from the Group Compliance Policy adopted by the Bank, and provides an appropriate environment for the timely detection, prevention, investigation and reporting of such efforts.
- It advises the Board of Directors,, through the Division, on issues related to the formulation and implementation of the Bank’s and the Group’s compliance policy, taking into account the institutional framework for corporate governance and supervision of the financial system.
- It submits an annual report on compliance issues, with respect to the institutional framework, to the Bank of Greece.
- Maintains a complete record of outsourcing contracts and submits to the Hellenic Central Bank, in accordance with both the current Attica Bank Outsourcing Policy and the regulatory framework (PD/TE 2597/2007 and Decision 2/452/1-11-2007 of the Hellenic Capital Market Commission), quarterly reports (on a consolidated basis) of the contracts in force and the list of outsourcing services provided.
- Ensure, through appropriate procedures, that the deadlines for the fulfillment of the obligations under the applicable regulatory legal framework are met and provide assurance to the Board in this regard.
- Ensure that the audited entities in question cooperate fully with those authorized by the Supervisory Authorities and cooperate themselves when required.
- Establishes and implements appropriate procedures and assists the Management, in the preparation of an annual programme to achieve in a timely manner the full and continuous compliance of the Bank and the Group companies with the applicable regulatory legal framework, the Articles of Association and the Internal Operating Regulations, as well as in the preparation of a Report on the previous year’s activities, which is submitted to the Management and the Board of Directors. Board through the Audit Committee, by the end of the first calendar half-year.
- Monitor, through benchmarks, the compliance of the individual Units of the Bank and the Group with the applicable regulatory framework, the Regulations and Directives of the Regulatory Authorities, as well as the Internal Regulations, Codes and Policies of the Bank and the Group Companies.
- Ensure that the employees of the Bank and the Group are informed in a timely and continuous manner about the developments in the regulatory legislative framework relevant to their responsibilities, by establishing appropriate procedures and training programs.
- Review the Compliance Manual and the Internal Regulations of the Division.
The Bank has established and implements the following policies, among others:
- Customer Complaint Management Policy.
- Customer complaints policy.
- “Policy on Compliance with the Regulations.
- Policy for the Protection of Personal Data “Prevention of Fraud and Terrorism Financing and Terrorism Financing” Policy.