Group Compliance operates independently from the business units. It has direct reporting line to the Eurobank Audit Committee of the Board of Directors, thus enhancing the importance and the independence of the function.
Holistic management of compliance risk
Group Compliance supports the Audit Committee of the Board of Directors in the management of compliance risk. It provides oversight and coordination in relation to the responsibilities of Eurobank and all its subsidiaries for compliance with the applicable regulatory framework, the rules of the Supervising Authorities, as well as the adopted internal policies. Group Compliance main responsibilities are as follows:
- New laws and regulations – Group Compliance notifies Eurobank’s Management on new laws and regulations, and advises them on the impact these may have.
- Compliance risks – Group Compliance monitors the regulatory framework and assesses the risk of non-compliance with it. It supports Eurobank with regards to monitoring, identification and effective management of compliance risks.
- Regulatory framework – Group Compliance ensures that the operators and the group compliance units of Eurobank and all the Group subsidiaries comply with the requirements of the regulatory framework and notifies the Eurobank Management accordingly.
More specifically, the key areas covered by the Group Compliance General Division are the following:
- Combating tax evasion, money laundering and terrorism financing – It adopts appropriate policies and procedures, and monitors the level of implementation.
- Financial markets – Group Compliance develops policies and procedures against potential market manipulation and insider trading, as well as the MiFID provisions.
- Consumer protection – Group Compliance monitors compliance to the consumer protection regulations and has an oversight of the complaints that have been communicated to the regulatory authorities.
- Supervisory authorities – Group Compliance monitors whether responses to requests from supervisory and other authorities are managed quickly and efficiently. It cooperates with them in order to facilitate their tasks. It monitors whether all the Eurobank units meet regulatory reporting timelines. It notifies the Audit Committee of any delays or fines.
- Hellenic Deposit and Investment Guarantee Fund (TEKE) – Group Compliance controls the quality of information submitted to TEKE, in compliance with the regulatory framework.
- Code of Professional Conduct – Group Compliance sets the standards of the Eurobank internal Code of Professional Conduct. The Code applies to the human resources of the entire Eurobank Group and provides the framework for the principles, rules, conduct and decisions that the human resources ought to follow during their professional engagement. Compliance monitors adherence to the Code of Professional Conduct with the aim to identify potential conflicts of interest, bribery, corruption or other unusual transactions.
We apply the anti-money laundering rules and principles. To this end, we have posted the following documents that are publicly available:
- The AML Questionnaire of Wolfsberg Group, which outlines the measures and procedures the Eurobank Group has adopted.
- The Anti-Financial Crime statement, which states the key points of the Eurobank Group regulatory compliance programme.
- The Certification Regarding Correspondent Accounts for Foreign Banks, as stipulated by the USA PATRIOT Act.
Eurobank encourages all Eurobank and Eurobank Group staff, and any concerned third parties, to submit reports or comments.
Reports or comments should be about breaches of policies, procedures and legislation in force, e.g.:
theft, embezzlement, bribery and corruption, money laundering, conflicts of interest, non-compliance with the Eurobank Code of Ethics and/or policies, or anything that could damage the reputation of Eurobank, as well as any attempt to cover up any such incidence.
The Eurobank Audit Committee defines the procedures that ensure confidentiality and secrecy for all reports and comments. It also systematically monitors the application of these procedures.
How to report misconduct
Group Compliance General Division
2-6 Pesmazoglou Street
10559 Athens, Greece