Compliance
BPCE is the central body of the cooperative banking group formed by the networks of the Banque Populaire banks and Caisses d’Epargne along with the other affiliated credit institutions. Within this framework, BPCE ensures strict compliance with laws, regulations and good professional practices within its affiliated entities.
In accordance with applicable law and regulations, the Compliance function guarantees this integrity and reinforces a sense of trust among all of the Group’s stakeholders. It exercises constant vigilance in four key areas:
- Ethics
- Prevention of financial crime
- Business continuity
- Training in regulatory requirements
Ethics
Ethics form an integral part of the compliance policy whose guiding principles are defined by BPCE and then adopted by each entity in accordance with its specific characteristics.
Compliance on the part of employees with the rules of good conduct enables each entity to pursue its business activities in an honest, upright and professional manner while providing the highest possible degree of protection for its customers’ interests. Continuous training and awareness-building sessions organized for employees to ensure compliance with the rules of ethics in the pursuit of their everyday work are essential.
The entities of Groupe BPCE subject to the regulations of the French Financial Markets Authority take all reasonable measures to identify conflicts of interest liable to arise in the rendering of investment services, related services or in the management of mutual funds.
The Group has reinforced its system set up to monitor and control the management of confidential and privileged information. The respect of bank or professional secrecy is a principle that admits no exception. Confidential information – i.e. information intended to be kept secret – about a customer or company is subject to specific monitoring procedures with, if necessary, a requirement that the individuals concerned should sign specific confidentiality agreements. As the Group owns several publicly listed companies, procedures have been set up to monitor and control the use of privileged information. These special provisions concern securities transactions carried out by employees who enjoy access to privileged information about the listed subsidiaries on a permanent or occasional basis.
The prevention of financial crime
Groupe BPCE is actively committed to the prevention of financial crime, notably measures taken to combat money laundering and the financing of terrorism or to prevent fraud.
All entities belonging to Groupe BPCE ensure compliance with the rules and regulations introduced by French legislation that comply with international standards as defined by the Financial Action Task Force (1), by the United Nations or European community institutions (2). In particular, Groupe BPCE is subject to the supervision and control of the French regulatory authorities responsible for the financial services industry, such as the French Banking Commission, the AMF French financial markets authorities, or the ACAM authority responsible for monitoring insurance and mutual insurance companies.
The principles and framework are defined by the central institution of Groupe BPCE and circulated within all Group entities. Awareness-building measures are taken at regular intervals to ensure that all the operating personnel remain sensitized to financial security issues, both regarding the new ways in which financial crime is perpetrated or regarding changes in the law and regulations in this area. Training also focuses on the different tools used within Groupe BPCE.
The prevention of money laundering and terrorist financing, which is based on the principle of developing a personal understanding of the customer, goes hand-in-hand with strategies designed to combat fraud. These different missions generate synergies capable of improving all the measures adopted to fight against the multifarious dimensions of financial crime. These measures are reinforced by constant vigilance maintained over financial activities, calling on the assistance of the local networks and the team of Group employees directly assigned to the management of these issues.
Business continuity
Like all companies, the different entities belonging to Groupe BPCE may be affected by incidents of an accidental or criminal nature liable to disrupt their smooth operation and, consequently, the quality of the services they provide.
Under such circumstances, the Business Continuity function identifies and approves the alternative solutions to be adopted with a view to:
- Minimizing the impacts of the incident,
- Ensuring that the activities of the BPCE Group’s entities start up again as rapidly as possible,
- Maintaining a minimum level of service, by all means available,
- Restoring a normal operating environment as rapidly as possible.
All the financial institutions belonging to Groupe BPCE, as well as the structures contributing to the pursuit of financial activities, have developed a system that can be activated in the event of a major incident.
All the Group’s employees are involved to different degrees and are liable to contribute to the business continuity solution.
These solutions are developed from scenarios of previously identified incidents. Their validity is ensured by a policy of regular tests involving the Group’s employees and by a periodical review of needs, resources and related procedures.
Training in regulatory requirements
Training provided for retail network employees is one of the priorities of the human resources policy. This represents the framework for training in regulatory requirements, overseen in association with the Compliance Department.
This training covers specific issues related to the prevention of money laundering and terrorist financing. It also covers questions related to the regulation of banking operations such as:
- The application of the “market abuse” and “markets in financial instruments” (MiFID) directives,
- The practical context of banking activities such as bank secrecy or the protection of customers’ data,
- And, lastly, cross-functional subjects such as the need for personal knowledge about customers resulting in the gathering of relevant information in order to be in a position to recommend products appropriate to the needs of each customer.
(1) The Financial Action Task Force (FATF) is an inter-governmental body whose purpose is the development and promotion of national and international policies to combat money laundering and terrorist financing.
(2) Directives and regulations published by the European Commission or the European Council