The Group Compliance Sector operates independently from the business units. It has dual reporting to the CEO and 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
The Group Compliance Sector (GCS) supports the Audit Committee of the Board of Directors in the management of compliance risk by providing oversight and coordination in relation to the responsibilities of Eurobank and all the Group subsidiaries in Greece and abroad for compliance with the regulatory framework, the rules of the Supervising Authorities, as well as the adopted internal policies. The Group Compliance Sector responsibilities are as follows:
- New laws and regulations – GCS notifies Eurobank’s Management on new laws and regulations, and advises them on the impact these may have.
- Compliance risks – GCS determines and monitors the framework for assessing the risk of non-compliance with the regulatory requirements. It supports the Eurobank Management and employees with regards to monitoring, identification and effective management of compliance risks. To this end, it uses specialized IT tools.
- Regulatory framework – GCS ensures that Eurobank and all the Group subsidiaries comply with the regulatory framework, as applicable to the regulatory requirements of each and every country where the Group operates, and notifies the Eurobank Management accordingly.
More specifically, the key areas covered by the Group Compliance Sector 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 – GCS develops policies and procedures against potential market manipulation and insider trading, as well as the MiFID provisions.
- Banking secrecy and personal data protection – GCS works with all the Eurobank Group units toward compliance with the applicable legal requirements.
- Consumer protection –GCS monitors compliance to the consumer protection regulations and has an oversight of the complaints that have been communicated to the regulatory authorities.
- Supervisory authorities – GCS 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) – GCS provides assurance for the quality of information submitted to TEKE, in compliance with the regulatory framework.
- Code of Professional Conduct – GCS 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. The Code of Professional Conduct is eventually approved by the Audit Committee of the Board of Directors. 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.