Conflicts of interest
The efficient functioning of Dexia's activities requires a strict policy with regard to conflict-of-interest management.
Conflicts of interest arise in a numerous situations; there can be a conflict between the interests of Dexia (or one of its employees) and those of its customers, between those of staff members and Dexia or indeed among the interests of several customers.
The Dexia Group has thus built a consolidated list – not exhaustive – of conflict-of-interest scenarios that might arise and has a policy to prevent them in each operating entity.
Internal rules on staff exercising functions outside the Group have been adopted pursuant to local rules and regulations or in line with the general principles governing conflicts of interest.
In this regard, Dexia SA complies with the current regulatory requirements . Dexia SA has adopted a policy governing the external functions exercised by its directors and managers aiming at:
- ensuring the availability of executive managers of Dexia SA ;
- preventing the occurrence of conflicts of interests and the risks linked to the exercise of external functions;
- preventing Dexia SA from being held liable for any market abuse relating to the financial instruments of listed companies in which directors or managers exercise a function;
- ensuring that external functions are made public.
Moreover, Dexia and its entities comply with regulatory requirements related to the verification of the expertise and professional integrity of its board members, executive directors and heads of the control functions.
Data protection and professional secrecy
Discretion and compliance with professional secrecy requirements (including bank secrecy, when applicable,) are essential, particularly with a view to preserving Dexia’s good reputation.
Appropriate procedures have therefore been introduced at various levels (employee, customer, transactional) throughout the Dexia Group in response to national rules and regulations.
The use of personal data is governed in many countries by legal provisions. Before using personal data, staff must acquaint themselves with the rules and obligations in force by referring to the guidelines and/or consult the Compliance department.
Independence of Auditors
The communication and reliability of financial data is of the utmost importance for any regulated entity, all the more so for a stock-market listed group like Dexia. So the role of the auditor and his independence when performing his task of auditing the accounts and in particular of evaluating all accounting data is of paramount importance.
Dexia has a policy designed to guarantee the independence of its auditors.
Dexia has set up an internal whistleblowing scheme with the aim of reducing the risks of suffering a financial loss, sanctions or a loss of image or reputation as a consequence of the non-fulfillment of legal and regulatory requirements.
This internal alert system involves a procedure within the company that can be used in complete confidence by employees or managers to warn it of shortcomings that are likely to have a serious impact on its business or invoke its liability, with a view in particular to enabling the company to prevent these shortcomings or take timely remedial action.
The Compliance department ensures that these internal alerts are handled with all due independence and objectivity.
Fight against corruption
The Dexia Group applies the highest standards of integrity and honesty in its business relations and dealings throughout the world. The Dexia Group tolerates no form of corruption – whether active or passive – whatsoever.
Anti-corruption rules apply to all staff and are set out in the “Integrity Policy”, in the “Code of Professional Ethics of the Dexia Group” and in the “Policy on Gifts, Favours and Invitations”.
To combat political corruption, Dexia has adopted the “Politically Exposed Persons Policy” (PEPs), which aims, above all, to prevent the risk of money laundering through personal corruption. Alongside that, the “Country Policy” considers the risk of corruption as an essential criteria in the Dexia Country Risk classification, established by Compliance.
There are several other policies that help reduce the risk of corruption. They include: the whistle-blowing policy, the principles governing the fight against money laundering and the financing of terrorism, the policy on conflicts of interest and Dexia’s policy guaranteeing the independence of its auditors.