Compliance

The term “compliance” means correspondence to legislation requirements and internal organization documents along with observance of self-regulatory organization standards.

Compliance

The term “compliance” means correspondence to legislation requirements and internal organization documents along with observance of self-regulatory organization standards.
  • Task
  • Value
  • Approach

The key task of compliance units

Arrangement of regulatory risk management processes and procedures, including AML/CTF/CPF processes.
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The Bank's core value

Establishment of a trust-based relationship with its clients, counterparties, partners and shareholders, the trust of which directly depends on corporate ethics. Corporate ethics presume a specific set of moral rules, the Bank's Code of Ethics, that are observed by employees in relation to clients, counterparties, partners, shareholders and towards each other.
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Approach and internal procedures

Our Bank's approach and internal procedures guarantee compliance with legislation requirements, self-regulatory organization standards, they enable us to promptly respond to any changes to minimize reputation and regulatory risks.
The Bank participates in dedicated committees and professional and international associations.
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Formation of the corporate code of ethics

The Bank's Code of Ethics is a minimal and mandatory standard for all of its employees and a benchmark for our clients, counterparties, partners, shareholders and other stakehoholders who share our values.
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The VTB Code of Ethics covers all areas of its activity and reflects its requirements and expectations in relation to employee conduct.

The principles of corporate governance

The Bank places a special focus on the principles of corporate governance, developing open, trust and respect-based relationships with clients, counterparties, employees, shareholders and ensuring compliance with international ethical norms and principles of open and honest business.
Our Bank’s absolute value is respect for and strict observance of human rights, support of the principles of:
  • the Universal Declaration of Human Rights,
  • Convention on Human Rights and fundamental freedoms,
  • Declaration of Fundamental Principles and Rights at Work,
  • International Labor Organization Conventions and other international documents on human rights.


ESG-based principles

In our daily activity our employees are guided by the rule of “Do more than you formally should”, which is fully reflected in our ESG-based principles and approaches:
  • Social responsibility;
  • Sustainable long-term development;
  • Caring about the environment;
  • Implementation of best corporate governance practices.

Counteracting money laundering, terrorism financing and financing proliferation of weapons of mass destruction

AML/CTF and CPF

The Bank uses all available resources in the area of counteracting money laundering, terrorism financing and financing proliferation of weapons of mass destruction
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In order to ensure timely identification of threats connected with money laundering and terrorism financing, control risks and prevent undesirable consequences the Bank has created an AML/CTF and CPF system.

AML/CTF and CPF system

In order to ensure timely identification of threats connected with money laundering and terrorism financing, control risks and prevent undesirable consequences the Bank has created an AML/CTF and CPF system with the following elements in VTB Group:
  • Application of the Know Your Customer principle;
  • Identification of operations subject to so-called “mandatory control”;
  • Identification and prevention of suspicious operations;
  • Education and training of employees.


Consolidated AML/CTF/CPF Policy

VTB Group has developed a Consolidated AML/CTF/CPF Policy for these purposes, which determines unified standards and approaches to fulfillment of Russian and international AML/CTF management requirements.


In its AML/CTF/CPF activity the Bank is guided by

  • the legislation of the Russian Federation and the regulations of the countries of the location of our branches;
  • Recommendations and comments from the Central Bank and Rosfinmonitoring;
  • Best practices of international organizations: o Groups for development of AML financial measures (FATF); o The Eurasian Group on Combating Money Laundering and Financing of Terrorism (EAG) o Wolfsberg Group; o Basel Committee on Banking Supervision.
The Bank's Management puts special focus on observance of AML/CTF/CPF requirements by all Bank employees, clients, counterparties and partners for transparent business processes and preventing use of Bank products and services for the purpose of AML/CTF/CPF. Being a market leader in new anti-money laundering management technologies the Bank takes part in Rosfinmonitoring projects, developing proposals for legislative initiatives and submitting proposals for improvement of regulatory AML/CTF/CPF requirements.
VTB develops solutions and approaches for implementation of such requirements in collaboration with other financial market participants.
The Bank of Russia distinguishes our Bank as an institution that inputs significant efforts to achieve a common goal and ban individuals that aim to perform shadow operations and evade taxes from the financial sector.

Сountering corruption, prevention and settlement of conflicts of interest

Countering corruption is one of VTB’s priorities. Our Bank has a zero tolerance policy towards corruption in any form and materialization.

Anti-Corruption Policy

In order to form a zero tolerance policy for corruption the Bank has developed and implemented and Anti-Corruption Policy that is mandatory for all employees.
This Policy reflects the Bank’s and the Bank management’s commitment to high ethical standards of open and honest business for improvement of the corporate culture, compliance with best corporate governance practices and maintenance of the Bank's immaculate reputation.
Employees report all identified or potential violations of the Bank's Anti-Corruption Management Policy to the Compliance Hotline.
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Anti-Corruption Management Plan

The Bank has developed and implemented an Anti-Corruption Management Plan based on the National Anti-Corruption Management Plan of the Russian Federation.


Management of conflicts of interest

Any display of corruptive conduct may be the reason for a conflict of interest. Bank employees are obliged to independently assess the possibility of a conflict of interest in their work.
In case of identification of a conflict of interest, including potential cases, information about such conflicts of interest must be provided by employees to the compliance unit on a mandatory basis.
The Bank expects its clients, counterparties and shareholders to comply with established principles and requirements for management of conflicts of interest and anti-corruption management, which aredocumented in contractual relationships in accordance with the current market practice.

Countering unfair practices on financial markets

Control in financial markets is an important area in any credit institution. Countering market manipulation and insider trading is a necessary condition for protecting a competitive environment, financial service consumer interests and mutual trust among market participants.

Control in financial markets

The Bank's compliance unit continuously monitors observance of established rules and actively prevents any potential market manipulation actions, including distribution of unreliable information, performance of transactions by arrangement and misuse of insider information.
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Measures for reduction of potential risks

VTB takes into account Russian and international legislation requirements in its activity and implements measures for reduction of potential risks of:
  • abuse on financial markets and transactions with insider information;
  • market manipulation.
The Bank ensures confidentiality of its insider information and information of its clients and counterparties, controls related requirements and restrictions for such information, conducts preventive action for such possible violations in the area of illegal disclosure of insider information and market manipulation and establishes respective internal rules and procedures that are mandatory for employees.
The Bank participates in working groups of professional associations of the Russian Federation.

FATCA and CRS

The Bank's internal procedures are compliant with FATCA/CRS requirements.
The Foreign Account Tax Compliance Act (FATCA)
The Bank acts as a financial institution complying with the requirements of the Foreign Account Tax Compliance Act (FATCA).
FATCA identifier
The Bank has an assigned FATCA identifier (Global Intermediary Identification Number, GIIN): 3FZXN5.00000.LE.643.
The Common Reporting Standard (CRS) of the Organization for Economic Cooperation and Development (OECD)
The Bank complies with the Common Reporting Standard (CRS) of the Organization for Economic Cooperation and Development (OECD) for automatic exchange of information about financial accounts. The respective standard norms were included in the legislation of the Russian Federation (Chapter 20.1 of the Tax Code of the RF, RF Governmental Regulation No. 693 dated 16 June 2018).

Regulatory risk management

Regulatory risk management system.

The Bank has estanlished a functioning regulatory risk management system.
All Bank employees participate in regulatory risk management within the framework of their activity while the compliance unit organizes the regulatory risk management system, monitoring and reporting.
VTB performs an annual high quality assessment of internal processes from the perspective of regulatory risk exposure and efficiency of existing control methods, it also develops and implements measures for mitigation of identified risks. Our Bank uses quarterly monitoring of key indicators that enables timely identification and proactive management of regulatory risks for high-risk areas.
The Bank has a regular collective authority body for regulatory risk management that reports to the Bank’s Management Board, the President and Chairman of the Management Board and conducts regular reviews and approves decisions on the most important issues related to regulatory risks.
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Compliance hotline for bank employees

The Compliance Hotline enables employees to send reports about known facts or justified suspicions of violation of the legislation of the Russian Federation and internal Bank regulations.
All bank employees are aware of the Hotline and its possibilities.
Confidentiality and security
The Bank ensures confidentiality and security of personal data of employees that submit reports and we guarantee non-application of corrective action to employees that dutifully notify about violations/potential violations committed by other Bank employees.
Notification about committed/potential violations
Notification about committed/potential violations may be provided in the following manner:
  • electronic form on the internal Bank corporate portal website;
  • dedicated email channel (including anonymous reports);
  • hard copy (including anonymous reports).
Reviewing reports the compliance
When reviewing reports the compliance unit aims to perform a complete, comprehensive and objective analysis of the circumstances that served as the basis for the report.
Corrective measures are applied when violations are detected.
The Bank provides a reply on the results of reviewing a report to the respective employee sender.

Feedback

The Bank has a zero tolerance policy for any violations and abuse and will take action against unreliable reports tarnishing the reputation of the Bank’s employees.

Information about committed or potential violations and abuse

You can report information to the Bank about committed or potential violations and abuse on the following subjects:
  • corruption;
  • conflict of interest;
  • misuse of insider information and market manipulation.
Dedicated Bank units ensure the review of each received report. Identified cases will be promptly and carefully reviewed, responsible individuals will be held liable for committed acts.
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