The Compliance Unit, as the second line of defence in the internal control system, is responsible for ensuring that the Bank remains compliant with applicable regulatory and legislative provisions. Also, the Compliance Unit has been assigned with AML/CTF tasks provided for in Article 6(4) of Law 4557/2018, which are to be distinguished from the tasks of the Bank in its capacity as the competent authority under Article 6(1)(a) of the same law.
The Unit's main areas of responsibility are as follows:
1. Compliance and corporate governance
- fostering a compliance culture as a standard of corporate behaviour to be integrated into the Bank’s functioning;
- developing, implementing updating an appropriate compliance policy and procedure;
- assessing, measuring and managing the Bank’s compliance risk;
- working with the relevant business areas of the Bank in monitoring and assessing the impact of regulatory changes and in revising the existing policies and procedures accordingly;
- monitoring compliance with the regulatory framework across the Bank, recommending and following up on corrective action to address any deficiencies identified;
- providing assistance in the fulfilment by the Bank of its obligations arising from its status as an Athex-listed company, in particular corporate actions and disclosures and communication with the competent authorities as well as with its shareholders;
- managing the system for the internal reporting of breaches according to the Internal Whistleblowing Policy and the relevant circulars;
- monitoring the functioning of the system for handling complaints from external parties.
- monitoring compliance with and proper implementation of the Bank’s Code of Conduct, examining all relevant matters;
- providing advice and guidance on the proper implementation of the Code of Conduct;
- receiving, examining and assessing reports of breaches of the Code of Conduct;
- recommending on revisions of the Code of Conduct and/or the issuance of relevant guidance where necessary;
3. Compliance with the anti-money laundering and counter-terrorist financing (AML/CFT) legislation
- monitoring and evaluating the proper and effective implementation of AML/CTF policy and recommending amendments as necessary;
- receiving and evaluating internal information, reports and notifications of unusual or suspicious transactions or indications of ML/TF;
- monitoring compliance by the Bank’s business units with the AML/CTF regulatory framework.
The Compliance Unit comprises the following Sections:
- Regulation and Corporate Governance Section
- Compliance and AML/CFT Section
- Support and Secretariat Section