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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