What is compliance?
Acting in compliance consists of knowing and respecting the rules issued by the regulators. So that all Group staff can act in a compliant manner, the rules have to be expressed in a clear and simple way, and every member of staff must be made aware of these rules and trained in accordingly. The purpose of these rules is to ensure the transparency of the Bank’s relations with its clients and supervisors, as well as its integrity. Compliance is thus the bedrock of trust between the Bank and its stakeholders.
Universal Registration Document 2020 - Compliance chapter
Our vision of compliance
The Group’s activities are carried out in strict compliance of the rules. In particular, the Group’s strives to:
- work with clients and partners whose practices comply with international standards and rules regarding the fight against money laundering and the financing of terrorism;
- work with clients or carry out transactions in compliance with international financial sanctions and embargo rules;
- carry out transactions, offer products and advisory services and work with partners in compliance with the rules notably with regard to client protection and market integrity and by applying its commitments in terms of fiscal conduct and fighting corruption;
- prevent and manage conflicts of interest;
- ensure the protection of its clients and staff members’ data;
- control the risks of any serious environmental or human rights offences associated with its activities, as defined by the Duty of Care law;
- develop a culture of compliance amongst its employees and ensure they have the right to raise the alert.
A strengthened organisation
The Compliance Division (CPLE) was reorganised on 1 January, 2018 and directly reports to the Group’s General Management, thus becoming an independent division in its own right headed by Edouard-Malo Henry, member of the Group’s Management Committee. A number of committees are in place in the presence of General Management and the Inspection to define the Group’s main orientations and principles in terms of compliance.
The Compliance Division is organised around:
- teams devoted to each business line;
- central teams devoted to supervising the various risks and controls, as well as key cross-business functions such as the digital transformation and training.
To meet the growing challenges in this area, over the last 3 years Societe Generale has doubled the workforce devoted to this activity and significantly increased the training budgets.
The Compliance Division ensures:
- compliance with laws, rules and ethical principles specific to banking activities and investment services undertaken by the Group, as well as compliance with staff members’ personal rules of good conduct and ethics;
- awareness-raising and training of all players in preventing non-compliance and reputational risks.
Our compliance behaviour is a key part of our business as a responsible banker and our ambition to be the relationship-focused bank that enjoys the trust of our clients, and is illustrated by our Code of Conduct, which has been translated into 24 languages and is given to each new Group employee.
The 8 main non-compliance risks:
KYC (Know Your Customer)
Know Your Customer (KYC) corresponds to all responsibilities and duties borne by financial institutions regarding the knowledge they must have of their clients. KYC centres on the actual identification of the client, global knowledge of their characteristics (activity, origin of their funds, etc.), the updating of this information and the implementation of suitable vigilance vis-à-vis these elements.
The fight against money laundering and the financing of terrorism
The Compliance Division’s mission is to prevent the operational risk associated with money laundering and the financing of terrorism. It coordinates the fight against such risks and ensures that the Societe Generale group’s member of staff receive continuous training in this respect.
Anti-money Laundering Certificate
Certification regarding correspondent accounts for Foreign Banks (The original certificate was executed on January 21, 2019. The certificate will be updated from time to time, as required, to reflect changes to the appendix to the certificate)
Wolfsberg Group Financial Crime Compliance Questionnaire
International Sanctions - Embargos
Compliance with sanctions is an ongoing issue which is increasing in importance and complexity, thus generating significant operational risks and requiring an international approach. Trade embargos and economic sanctions are strictly complied with throughout the Societe Generale group.
The Group is paying heightened attention to this major issue by implementing strong actions in terms of training and equipping its members of staff, by adapting its tools and by strengthening its internal rules regarding the way it deals with client complaints, including on social networks. The importance the Group places on this issue is widely reflected in its Code of Conduct updated in October 2016. On the European scope, the MiFID II and insurance distribution directives that came into effect in 2018 enable the transparency of our relations with our clients as well as their protection to be strengthened across all of our activities.
Societe Generale Code of Conduct
The Compliance Division strives to avoid 2 categories of potential conflict of interest: those that may arise between the Group and its clients (or between clients) and those between the Group and its employees. Particular attention has been paid to improving detection and analysis tools, as well as to staff training, in order to detect, identify and map potential conflict of interest situations.
The fight against corruption
For a long time now, Societe Generale has promoted strict principles laid down in its Code of Conduct that comply with the most rigorous regulations in this respect, such as the UK Bribery and Corruption Act (2011). The Group has also made some major commitments and taken significant measures:
- Integration within the United Nations Global Compact.
- Drafting of an anticorruption code in compliance with the law, and incorporation within SG France’s internal regulations
Prevention of risks associated with tax evasion
Control provisions have been put in place by the Group to ensure that transactions comply with local rules, laws and the Group’s Tax Code of Conduct. Societe Generale operates in compliance with fiscal transparency requirements and applies the Common Reporting Standard (CRS) within its entities. The same is true of the American Foreign Account Tax Compliance Act (FATCA), the purpose of which is to fight tax evasion schemes. The production of a declaration at national level and the exchanging of tax information allow Societe Generale to meet its fiscal transparency objectives.
Group's Tax Code of Conduct
Being particularly sensitive to protecting data of a personal nature, back in 2007 Societe Generale strengthened its protection set-up by creating a special unit in liaison with the CNIL (the French data protection authority). In order to implement the new European General Data Protection Regulation (GDPR) in 2018, in 2016 the Group launched a vast programme incorporating all of this regulation’s requirements, notably regarding its personal data security and usage aspects, as well as the implementation of the increased rights of people concerned.
Societe Generale group is strengthening its set-up for recording and processing alerts. The new mechanism, in compliance with the obligations defined by French legislation, allows staff to report serious matters that do not comply with the rules governing the conduct of the Group’s activities. Open to staff, external and temporary members of staff or service providers with whom an established commercial relationship exists (subcontractors or suppliers), the whistleblowing tool is based on a secure external platform that guarantees the protection of personal data and the strict confidentiality of information. It is accessible in multilingual versions via the below link.
A reminder of the terms and conditions can be found in the Group’s Code of Conduct.