Compliance

 
The Compliance Function at the Audi Group is fulfilled by a network of compliance teams which carry out their tasks under the global responsibility of the Group Chief Legal & Compliance Officer and the Group Compliance team.

The Compliance network consists of:
  1. The Group Compliance team directly headed by the Group Chief Legal & Compliance Officer.
  2. The Compliance Departments at Group Entities under the responsibility of a Head of Compliance. The Head of Compliance is generally also designated as Money Laundering Reporting Officer.

The mission of the Compliance Function is to:
  • Ensure that compliance risks are adequately identified, assessed, controlled, monitored, tested and reported;
  • Ensure that the Board of Directors and Senior Management are fully informed of significant compliance developments, issues and plans for resolution;
  • Promote a compliance culture by educating staff and raising compliance awareness throughout the organization;
  • Align its Compliance Program to reflect any change in regulatory environments;
  • Meet legal and regulatory expectations;
  • Issue and implement Compliance Policies, supported by procedures, to better comply with applicable laws and regulations and continuously adopt industry standards and best practices.
The scope of Compliance largely depends on the nature and the location of business activities. It generally includes:
  • Regulatory Compliance.
  • Anti-Money Laundering and Combating the Financing of Terrorism including:
    • Customer Acceptance – Know Your Customer / Customer Due Diligence.
    • Transaction Monitoring.
    • Investigation and Reporting.
  • Local and International Sanctions and Restrictive Measures (UN, US, EU sanctions).
  • Capital Markets Compliance which includes:
    • Treatment of Confidential Information.
    • Management of Conflicts of Interest.
    • Prevention of Insider Trading and Market Manipulation.
    • Fair Treatment of Customers.
    • Product Suitability / New Product Approval.
 
Compliance at the Audi Group is performed in line with the following governing principles:

The Group's integrity and reputation are key assets

The Group Board and Senior Management are proud of the integrity of its organization and the reputation for professional and ethical conduct. It is deeply committed to the preservation of its integrity and reputation, and thus requires of all businesses:
  1. A good understanding of and compliance with the letter, spirit and intent of applicable laws, regulations and standards in each of the jurisdictions in which the Group operates;
  2. The ongoing implementation of and adherence to Compliance Policies developed by Group Compliance. Their contents are mandatory and represent minimum standards which apply throughout the Group.

Moreover, it is within the Group’s policy for all its subsidiaries, branches or sister companies to be fully informed of the laws and regulations governing their foreign correspondents, and deal with the latter in conformity with these laws, regulations, procedures, sanctions and restrictive measures imposed by their respective governments. The Group considers this to be a matter of sound banking practices and reflects its commitment to international standards observed by the global banking community.

Management is the owner of Compliance

Management is the owner of Compliance and holds ultimate responsibility for the implementation of and adherence to Compliance Policies supported and advised by the Compliance Function. It is responsible for establishing an effective Compliance Function and providing it with adequate staffing and resourcing to implement internal and external requirements.

Management sets the good example and takes all appropriate measures to ensure that all employees will conduct their business activities in an ethical manner, consistent with legal/regulatory obligations and Compliance Policies.

The Compliance Function is independent

The Compliance Function is independent from business lines. Yet, it supports business heads in making informed choices and distinguishing among alternative courses of action.

Compliance is a responsibility that every employee shares

Compliance is a responsibility that individual employees share, regardless of their position within the Group. This implies a strong compliance commitment and responsible corporate behavior on a global basis. Each is expected to play his or her part, under the guidance of their Management and Compliance. Employees are entrusted to perform their duties and deliver products and services for which they have responsibility in accordance with the highest ethical standards, applicable laws, regulations and Compliance Policies.

Positive relationships between the Group and its regulators need to be maintained

A positive relationship between a bank and its regulator is a valuable asset. The Audi Group is committed to conducting its relationships with regulators in a transparent fashion and consults with regulators of jurisdictions in which the group operates on all pertinent issues.

While conducting business, the Audi Group is keen on demonstrating to regulators: Senior Management involvement in Compliance, a clear, risk-based approach to Compliance, Compliance Policies and related controls embedded within the business, Compliance Procedures applied consistently, robust procedures for reporting suspicious transactions and a clear lack of complacency.

Effective monitoring of compliance risks is required

The Compliance Function shall ensure the effectiveness and integrity of the compliance process of their business with appropriate and detailed monitoring of the adherence to Compliance Policies and their minimum standards and applicable legal and regulatory standards. The Compliance framework is the set of compliance risk management processes and tools which shall be used by the business, Management and Compliance for managing compliance risks.

Adequate Compliance reporting shall be provided

Compliance reports shall be provided on a regular basis to the Group Board and Senior Management, in which key risks, major developments and issues (especially legal and regulatory) and compliance breaches are brought to attention, including recommendations for follow-up. Compliance risks are properly communicated to concerned stakeholders in a transparent, systematic, structured, timely and accurate manner, in order to allow them to make prompt and informed decisions.

The Compliance Function will continuously improve itself in line with local and global developments

The Compliance Function will seek at all time to improve itself by
  1. improving its governance,
  2. seek new and better measurement methods,
  3. continuously improving its policies and procedures, and
  4. adopting the industry’s best practice.

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