THE KEY ROLE OF COMPLIANCE
Compliance is taking part of the Group Culture
The key role of compliance
First set up in 1997 to monitor market activities, the Compliance Department has since extended its scope of intervention to cover all banking activities. Today, the Group has developed a body of compliance standards and rules of good conduct that meet the highest sector standards. Moreover, the Group's rules generally go beyond the simple application of legal and regulatory requirements, particularly in countries that fail to meet Société Générale’s own ethical standards. Société Générale’s core principles include:- refusing to work with customers or counterparties that are not well known to the company;
- knowing how to assess the economic legitimacy of a transaction;
- being able to justify an adopted position under any circumstances.
- does not enter into relations with individuals or businesses whose activities fall outside of the law or are contrary to the principles of responsible banking;
- refuses to conduct transactions for clients or counterparties if it is unable to determine the economic legitimacy of these transactions, or where a lack of transparency suggests they may be contrary to accounting and compliance principles, and particularly if there is any indication of money laundering or the financing of terrorist activities;
- adopts a major international objective of combating corruption in the private and public sectors (an Group internal instruction was published in 2009)
- provides information that is accurate, clear and not misleading on the products and services it proposes and verifies that said products and services are suited to customer needs;
- has established a “right to alert” which can be exercised by any employee who believes they have good reason to think that an instruction received, a potential transaction or, in general, a given situation, does not comply with the rules that govern the conduct of the Group’s activities;*
- has defined strict internal rules to prevent the setting up of operations in a country considered by the OECD as “having harmful tax practices” or by the FATF as “having an inadequate anti-money laundering system”. However, the Group does not rule out a presence in these countries where there is an efficient banking and financial activity that meets the economic needs of local or international customers and where the Group’s anti-money laundering standards are applied, even when the latter are stricter than the standards applied under local legislation. Société Générale Group applies the specific provisions of the French General Tax Code relating to countries with privileged taxation – a much broader concept than that applied by the OECD. It therefore spontaneously submits a tax return in France for the revenues of entities located in these countries where these entities come under the scope of application defined by the law (article 238A of the French General Tax Code).
* Verified by Ernst & Young ( Statutory Auditors' Report )