Compliance

The financial sector is one of the most regulated and controlled sectors in the economic world

Compliance with all these legal, regulatory and prudential requirements determines the trust of the public, customers, staff members and shareholders as well as Dexia's reputation

Compliance within the Dexia Group

As an operator in the field of financial services, Dexia undertakes to conduct its activity in a professional and responsible manner vis-à-vis its customers, other financial operators, the competent authorities 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 financial 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.

What is its scope?

Compliance covers the following areas:

  1. Financial security
  2. Combating corruption
  3. Prevention of risks related to tax evasion (FATCA and CRS)
  4. Market abuse
  5. Market integrity
  6. Prevention of conflicts of interest
  7. Protection of personal data
  8. Right of alert

 

Financial security

The Dexia Group (including the parent company Dexia, 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:

  • Adopting appropriate anti-money laundering policies and procedures,
  • Establishing a prevention system based on identifying the customer or counterparty, monitoring our account and business relationships, during and after the relationship,
  • Applying enhanced due diligence for identified high-risk customers and politically exposed persons ,
  • Reporting all suspicious transactions and cooperating with the relevant authorities in a transparent manner,
  • Organising regular training for all staff members of the Group. 

These principles reflect the Dexia Group's desire to prioritise combating money laundering and terrorist financing.

Combating corruption

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 in compliance with the law.

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).

Prevention of risks related to tax evasion (FATCA and CRS)

Dexia acts in compliance with the requirements of tax transparency (OECD requirements) by applying the Common Reporting Standard (CRS) and the FATCA regulatory requirements to its entities in all the countries in which it operates. This concerns all its subsidiaries and affiliates (if Dexia holds more than 50% of their capital).

Market abuse

As an investment services provider, 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:

  • insider trading or attempted insider trading (in connection with the holding of inside information),
  • manipulation or attempted manipulation of the market,
  • the unlawful disclosure of inside information.

The Group entities concerned have implemented policies to prevent market abuse, as well as dedicated training to raise awareness among the managers or 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. 

Market integrity

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 financial 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 financial counterparties.

Compliance ensures that regulatory changes within its areas of competence are regularly updated. In accordance with its obligations, Dexia has instituted controls relating to declarations and reports to the supervisory authorities. 

Prevention of conflicts of interest

Dexia is liable to be confronted with conflict of interest situations which may arise when providing products and services to one or more customers or financial counterparties beyond investment services alone.

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.

Protection of personal data

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.

Right of alert

Dexia has established an internal alert system offering all staff members and stakeholders the opportunity, in complete confidentiality, to report any breaches, abuses and dysfunctions which might seriously damage the Dexia Group, in order to prevent them in time and to correct them.

Any conduct incompatible with good ethics, the law, internal rules or national and European regulations which might seriously harm the Dexia Group or the general interest may be the subject of an alert.

Compliance ensures the independence, objectivity and confidentiality required to process such internal alerts.