Description of the internal control system
The internal control system is a set of internal control process, organizational structure, local legal acts (hereinafter referred to as LLA), defining the policy, methods and procedures of internal control, as well as the powers and responsibilities of the management bodies of JSC Belagroprombank (hereinafter referred to as the bank), collegial bodies, divisions and officials of the bank, ensuring the achievement of the goals of internal control.
The bank has approved the Internal Control Policy, including compliance control, at JSC Belagroprombank.
The main objectives of internal control, including compliance control, are:
- creating conditions for sustainable development of the bank;
- minimizing the risk of financial losses;
- compliance of the internal control system with the scale, nature and conditions of the bank’s activities;
- improvement of the internal control system;
- promoting the development of compliance culture;
- maintaining a culture of zero tolerance for corruption;
- preventing conflicts of interest and the conditions for its occurrence, as well as the possibility of committing crimes and other illegal actions;
- maintaining the bank’s business reputation at the proper level;
- maintaining corporate values and rules, including the principles of professional ethics, striving to improve corporate culture;
- confirmation of the bank’s commitment to the principles of open and honest business;
- ensuring transparency of activities for shareholders, third parties and regulators;
- implementation of decisions.
To achieve the goals, internal control and (or) compliance control departments ensure the organization and functioning of the internal control system in the following areas (tasks):
- achieving the strategic goals;
- ensuring the efficiency of the financial and economic activities of the bank when carrying out banking operations and other activities;
- ensuring efficient management of assets and liabilities;
- ensuring the safety of the bank's assets and investments;
- ensuring the reliability, completeness, objectivity and timeliness of accounting, preparation and presentation of accounting (financial), prudential and other reporting;
- distribution of powers and responsibilities;
- assessing the effectiveness of the risk management system;
- conducting an assessment of the effectiveness of the activities of organizations that are part of the banking holding company;
- functioning of information systems, managing information flows (receiving and transmitting information), ensuring information security;
- compliance by the bank and its employees with the requirements of legislation and regulations;
- prevention of money laundering, financing of terrorist activities and financing ин the proliferation of weapons of mass destruction;
- compliance by the bank and its employees with legislation on banking, commercial and other secrets protected by law and the requirements of the National Bank for the disclosure of information;
- compliance by the bank and its employees with legislation on personal data;
- application of economic sanctions, informing by banks the tax authorities of foreign countries with which the Republic of Belarus has concluded international treaties on improving compliance with international tax rules;
- carrying out banking operations and other activities with affiliates and insiders;
- managing conflicts of interest;
- prevention (suppression) of offenses that create conditions for corruption, corruption offences;
- dealing with appeals from citizens and legal entities;
- compliance by the bank and its employees with applicable standards of business practice.
The internal control system of the banking holding is decentralized and consists of three levels:
- in the bank;
- bank’s control over the activities of the organization participating in the bank holding company;
- in an organization participating in the banking holding company.
The implementation of the Policy norms in relation to organizations participating in the bank holding company is carried out through the bank’s influence on decisions made by such organizations, in accordance with the mechanisms as provided for by law and LLA.
The bank's board organizes an effective system of transfer and exchange of information, ensuring the receipt of the necessary information to users interested in it.
Information about the official responsible for internal control in the bank:
Inessa Fedorovna Melchakova, Executive Director of the bank is the official responsible for internal control of the bank (appointed by order of the bank in consideration with the assessment of compliance with qualification requirements and requirements for business reputation, carried out by a special qualification commission of the National Bank with the consent of the bank's supervisory board).
Yuri Mikhailovich Delicatny, Director of the Compliance Control Department has been appointed as the person replacing the official responsible for internal control of the bank during her temporary absence.