Page 82 - ACCESS BANK ANNUAL REPORTS_eBook

applicable to its business. The Conduct and Compliance effective standards globally, including a globally consistent
function, including all staff of Access Bank Plc and its sub- approach to knowing our customers.
sidiaries are committed to high standards of integrity and
fair dealing in the conduct of business. The Bank’s com- With respect to Compliance Risk, the Bank’s appetite for
pliance risk management philosophy is deepened by the Compliance Risk continues to be defined as follows; Zero
effective convergence of risk management through the tolerance for payment of fines and other penalties associ-
‘Three Lines of Defense’ model. ated with regulatory infractions and non-compliance with
laws, standards and rules. The primary compliance objec-
Effective Compliance Risk Management in Access Bank and tive is to be among the top three (3) most compliant banks
its subsidiaries will continuously be coordinated in the fol- in all the jurisdictions we have our business operations. The
lowing manner: Bank shall continuously aim to minimize the following com-
pliance risk indicators:
• Where a business unit is subject to regulatory
requirements, it will comply with those • Reported exceptions by auditors, regulators and
requirements. The business unit will further external rating agencies;
establish and maintain systems of internal • Frequent litigations;
control to monitor and report the extent of • Payment of fines and other regulatory penalties;
compliance with those requirements with the and
support of the Conduct & Compliance function. • Unresolved customer complaints.

• In the absence of regulatory requirements for all The Bank shall not compromise its reputation through un-
or part of a business unit, certain minimum ethical, illegal and unprofessional conduct in the market
standards of conduct is established and place. The Bank shall also maintain a zero appetite for asso-
maintained by that business unit to the extent ciation with disreputable persons and/or entities.
required as determined by the management of
that business unit. Our aNtI-MONey LauNDerINg PrOgraMMe

Accountability for ensuring compliance with regulatory re- Access Bank Plc has a Board approved AML/CFT pro-
quirements and minimum standards rests with the Group gramme. This is contained in the Bank’s Compliance Man-
Managing Director and the Board of Access Bank Group, ual which is reviewed and updated on an annual basis. Our
while the enforcement thereof is the responsibility of the Compliance Manual contains the policies approved by the
respective Group Heads (1st line of defense). Board. Some of these are the Politically Exposed Persons
(PEP) Policy; Compliance Risk Management Policy, Compli-
To assist in the discharge of this obligation, Access Bank Plc ance Charter etc.
maintains an independent Conduct & Compliance Function.
The Conduct & Compliance function develops systems of Board members and all levels of staff are trained at least
control that are required to ensure there is adequate pro- once every financial year on Anti-Money Laundering Com-
tection of the Bank, empowers the first line of defence and bating Financing of Terrorism Know your Customer and An-
ensures timely reporting of breaches and other regulatory ti-Bribery and Corruption (‘AML/CFT/KYC’) as stated in the
non-compliances to the Board and Executive Management Bank’s policy. New employees also undergo the same train-
of the Access Bank Group. ing as an induction course. The Bank organizes and ensures
that staff attend webinars, conferences, workshops and
For independent assurance, the Conduct & Compliance trainings as part of its bankwide awareness program. Tests
function together with other Risk Management functions are conducted during such trainings to ensure employees
and the Group Internal Audit to ensure that the necessary understand the content and scope of the trainings.
synergies are achieved in the management of the Bank’s
compliance risk. All Access Bank staff sign the Annual Compliance Attesta-
tion message to affirm that they have read and understood
OUR COMPLIANCE RISK APPETITE the policies and procedures of the Bank relating to ethics,
code of conduct, AML/CFT, Anti-Bribery and Corruption
Access Bank Plc aims to be compliant with all applicable etc.
laws and regulations, internal company rules and policies
governing its operations and established good business The Bank has designated a Non-Executive Director who is
practices. Access Bank Plc ensures that this requirement is responsible for the Access Bank Plc Anti Money Laundering
embedded in the culture of its business operations. / Combating Financing of Terrorism (AML/CFT) program.
Enhanced global AML and sanctions policies, incorporating With the Executive Compliance Officer and escalation
the Bank’s risk appetite, are effectively in use in the Bank. protocol for compliance risk in place, the Enterprise-wide
The policies adopt and seek to enforce the highest or most Risk Management Committee (ERMC) and the Board via

82 Access BAnk Plc
Annual Report & Accounts 2017