Compliance consists of ensuring that a company complies with the laws in force governing the way in which it conducts its business
Compliance with all these legal and regulatory requirements determines Dexia's reputation
As a company, Dexia undertakes to conduct its activity in a professional and responsible manner vis-à-vis its customers and counterparties, the Surveillance Committee and any partner, whether internal or external to the Group. Indeed Dexia undertakes to abide by the laws of the countries in which it operates and to ensure the adoption of honest behaviour within the context of the carrying on its activities.
Compliance is an independent function which forms part of the internal control system. Its task consists of overseeing the management of non-compliance risks and assessing the compliance of internal codes of conduct, policies and procedures with legal obligations and the best practices applicable to its activities.
In terms of organisation, The Chief Compliance Officer ensures that a coherent and effective policy is applied within the entire Dexia Group, with the aid of a Compliance Officer based in each entity. These Compliance Officers report functionally to the Chief Compliance Officer.
Its activity falls within the framework of a charter which describes the role and areas of competence of the compliance function and presents the governance principles underlying Dexia's approach to compliance. A compliance policy specifies the organisation and all the areas covered by this function. These key documents have been approved by the management board and the board of directors of Dexia.
Compliance covers the following areas:
The Dexia Group (including the parent company Dexia Holding, its subsidiaries, branches and other related companies) formally undertakes to participate actively at an international level in combating money laundering and terrorist financing. The programme conceived and put in place by Dexia is based on the following principles:
These principles reflect the Dexia Group's desire to prioritise combating money laundering and terrorist financing.
Dexia undertakes to conduct its activities in a healthy and integrated environment, in full compliance with all legal and regulatory provisions in force.
Within this context, Dexia seeks to take all necessary measures to prevent corruption in all its activities and throughout the Group’s scope, including the development of a code of conduct.
This code of conduct reinforces the monitoring systems in place and should be read in conjunction with other Group policies (such as the Group's code of ethics and professional conduct, the compliance charter, the policy on gifts, favours or invitations, and so on).
As an issuer of financial instruments and having regard to its activities, Dexia has implemented measures to manage the risks of market abuse. The aim of the system put in place is to prevent, detect and, if necessary, declare to the competent authorities any suspicious behaviour relating to:
The Group entities concerned have implemented policies to prevent market abuse, as well as dedicated training to raise awareness among the managers and staff members concerned. The establishment of lists of insiders and Chinese walls are part of this prevention effort. These measures are taken in relation to financial instruments issued by Dexia, but also with other issuers for which Dexia and/or its staff members may have inside information.
Dexia undertakes to respect the proper functioning of the markets on which it operates, and the internal rules and procedures of those markets and other trading platforms. Dexia undertakes not to intervene in transactions that may contravene laws and regulations.
Dexia is committed to ensuring that market operators demonstrate professionalism and integrity vis-à-vis intermediaries and counterparties and has developed policies and procedures to that end. Indeed, Dexia has implemented a code of conduct for trading rooms, policies and procedures which define the conditions under which market operators can operate on the markets or enter into relationships with other counterparties.
Compliance ensures that regulatory changes within its areas of competence are regularly updated.
Dexia is likely to be confronted with conflict of interest situations.
Dexia has developed a policy in this area on three lines: the prevention, detection and management of conflicts of interest.
This policy is supplemented by rules addressing specific conflict of interest issues, such as rules on personal transactions, gifts, favours and invitations.
Compliance periodically informs Dexia's management board and board of directors of the effectiveness and monitoring of the system for preventing and managing conflicts of interest.
The General Data Protection Regulations (GDPR) strengthen the security and confidentiality of personal data in European Union countries and impose new obligations on all organisations which process such data.
The protection of personal data is essential and Dexia seeks to comply with all national and European provisions.
Dexia collects personal data as controller and, as such, it seeks to ensure the greatest transparency with regard to the processing and use of the data, their storage period and the rights available to the data subjects. For more information, please please click here.
Dexia has put in place an internal whistleblowing system offering all members of staff and stakeholders the opportunity, in good faith and confidentially, to report any potential or established breach of regulations, corporate values and internal codes of conduct, or any unethical or illegal behaviour concerning aspects falling within Dexia's competence and control.
Compliance ensures the independence, objectivity and confidentiality required to deal with any internal whistleblowing.