P.
65
Cecabank Report 2018
Corporate Culture
3 | 3.2
a monitoring channel that gathers claims and enquiries.
•
Procedures on the prevention
of money laundering and the financing of
terrorism and control structure.
•
Internal code of conduct regulations
for the securities market.
•
Policies for providing investment services or
MiFID policies.
These policies include the likes of trade policies (Marketing Manual),
policies relating to the execution of clients’ orders (Better Order
Execution Policy), policies relating to safeguarding clients’ assets (Asset
Safeguarding Policy) and the policies regarding records that must be
maintained by the company in relation to the investment service (Record
Maintenance Policy). The main aim of these policies is for the institution
to adequately comply with the codes of conduct and organisational
requirements linked to the provision of investment services.
•
The bank has
IT systems
that allow analysing own and brokered
operations, for the purpose of detecting any possible transactions related
to money laundering and the financing of terrorism. Therefore, financial
sanctions lists are used to verify there are no such transactions and there
are specific scenarios to detect suspicious transactions. In addition, there
are tools and processes in place that provide comprehensive information
about the client and allows monitoring the relationship therewith.
•
The organisational structure and internal control mechanisms are intended
to guarantee that the institution’s activities are streamlined and effective,
that the information is reliable, relevant and complete and that the
applicable laws are complied with. There are specific management and
control units in the various risks with comprehensive and uniform areas of
action; and a decentralised structure with relationships between the risk
management units guided by the principles of coordination, cooperation and
reciprocal information, and by having three control levels.
In addition, to promote, coordinate and monitor the CSR policy, Cecabank
has a CSR and Sustainability Committee in place that reports directly to the
Steering Committee.
Cecabank imposes ethical
behaviour demands with the
aim of preventing, to the largest
extent possible, the criminal risk
of the legal entity
The code of ethics formalises the
commitment of the staff, with
the highest standards of integrity
Culture and
identity
Human capital
Innovation in
the commercial
offering
Transparency
Ethics
CSR