2020 Universal registration document and annual financial report - BNP PARIBAS 555
7 A COMMITTED BANK: INFORMATION CONCERNING THE ECONOMIC, SOCIAL,
CIVIC AND ENVIRONMENTAL RESPONSIBILITY OF BNP PARIBAS
7
Our economic responsibility: financing the economy in an ethical manner
COMMITMENT 2: ETHICS OF THE HIGHEST STANDARD
The respect of the most rigorous ethical standards is a prerequisite at BNP Paribas. All Group employees are required to strictly respect all laws, rules and regulations in effect, as well as all professional standards that apply to their activities. In the event of conflict between the laws of a country and BNP Paribas ethical rules, the Group s employees are required to respect local legislation while at the same time looking for ways to apply and respect internal ethical rules.
ETHICS OF THE HIGHEST STANDARD
Code of conduct
In May 2016, BNP Paribas published and distributed to all its employees its new Code of conduct supplemented in 2018 by a more specific section on anti-corruption. It is accessible to everyone on the Group s website(1). Mandatory online training in the Code of conduct was delivered in 2016, and has continued since then for new hires.
The whistleblowing system
BNP Paribas has a dedicated internal ethics alert (whistleblowing) system, based on dedicated communications channels, available to employees on the intranet. Every employee has the right to report ethics violations and the ethics alert policy guarantees employees exercising this right protection against the risk of retaliation for having launched an internal alert in good faith.
The whistleblowing system is subject to continuous improvement measures. It was reviewed in 2018 to meet new regulatory standards (Sapin 2 law, MiFID 2 and Duty of Care) and to strengthen protection for the whistleblower: through a thematic memo sent to all employees, the communication of rules, and the creation of a dedicated forum for whistleblowing referents (employees tasked with the reception and processing of ethics alerts), in order to standardise the handling of these cases.
The fight against corruption and money laundering
In terms of financial security, the Group continued to develop its Anti- Money Laundering and the Financing of Terrorism (AML/CFT) system through the updating of several key elements of its regulatory framework, in addition to organisational and IT developments. It also continued with the implementation of the programme to ensure compliance with the Sapin 2 law of 9 December 2016, in its fight against corruption section.
Thus, the BNP Paribas system in terms of preventing and managing acts of corruption was strengthened:
■ the corruption risk mapping methodology has been aligned with the Group procedure of the Risk Function as regards the general framework for the identification and assessment of operational risks and controls Operational risk mapping process (Risk & Control Self-Assessment) to enable a more detailed analysis of corruption risks and scenarios by process;
■ the employees most exposed to the risks of corruption received a dedicated online training course; and
■ work has been undertaken to improve the management of risks concerning supplier relations and accounting controls, with better consideration of corruption risks.
Training
In 2020, 97% of the Group s employees completed the online training on International sanctions and embargoes .
The anti-corruption training for the most exposed employees, i.e. 27,000 employees, was carried out, reaching 95.9%.
Regarding competition law, 96% of the Group s employees (not accounting for exempted individuals) passed the Competition Law and You training at the end of 2020. In order to boost awareness through an innovative format, a video module entitled Compliance with Competition Law make the right decisions was launched in mid-December 2020.
Lastly, in 2020, 99.8% of the Group s employees took the Know Your Data (KYD) training as part of the Compliance training programme (compared to 91.3% in 2019). In addition, 90.7% of employees in the European Economic Area completed the Personal Data Protection training in 2020 (compared to 87% in 2018). This module will now be part of a dedicated section of the new training course entitled Personal Data Protection Awareness , which will be launched in 2021 and will be aimed at all Group employees. This new training course includes an improved section on Personal Data Protection at BNP Paribas with concrete actions to help teams better understand their responsibilities.
The fight against tax evasion
Compliance with all tax obligations is one of the BNP Paribas Group s commitments in terms of economic, social, civic and environmental responsibility. The tax compliance of transactions intended to meet its needs or those of its clients is therefore a major objective of the Group s governance, which, for this purpose, has defined principles and procedures applicable to all transactions in which the Group is a stakeholder. These elements are included in the BNP Paribas Group s Tax code of conduct published in 2020(2).
(1) https://group.bnpparibas/uploads/file/codeofconduct_en_11_01_2018_40p.pdf
(2) https://group.bnpparibas/uploads/file/the_bnp_paribas_group_s_code_of_tax_conduct.pdf
