La politique de conformité (document en anglais)

POLICY COMPLIANCE

1. PURPOSE

The Board of Directors of the Bank International of Crédit adopted the following Compliance Policy.

Function ethical of the company can provide detailed advice on the principles outlined in this policy compliance.

The purpose of the compliance policy is to promote honest, ethical conduct and ensure compliance with laws, regulations, rules, and professional standards and the code of conduct of the company and group policies in order protect the integrity of the financial market.

Employees at all levels must take diligently; efficiently and as much as they can to their responsibilities. They are required to act with loyalty to the company, in which case the legitimate interests of clients and stakeholders prevail, and behave honestly, independently, impartially, with discretion and without regard to their own interest.

As required, this compliance policy:

• Identify key issues related to compliance risks;

• Expose the principles established by the Board of Directors;

• introduce the ethics function, its independence and its objectives;

• require the preparation of a compliance charter;

• Institute the implementation of a program of learning.

2. SCOPE

This policy approved by the local Board of Directors applies to all employees of the Company without restriction to all service providers acting for or on behalf of the company.

3. STATEMENT OF POLICY

3.1. Ethic function

Executives of the company set up the ethics function, to oversee the implementation, the implementation of the policy and ensure compliance monitoring. The procedure and the limits of the scope of the ethics function evolve over time, depending on the state of the organization and the risks inherent in the company.

Function independently and ethics will be required, in particular:

• Ensure compliance with all laws, regulations, rules, and professional standards;

• Assist senior management to ensure compliance with ethical rules;

• Identify and assess compliance risks, as outlined below;

• Assist senior staff in the management and control of these risks;

• Report significant issues directly to senior management, and

• Inform and educate staff

The Company defines the compliance charter status of the ethics function, its organization and the role and responsibilities. All employees will be made aware of the charter.

3.2 Compliance risks

Compliance policy consists of all measures, actions and options decided to limit the risk to an acceptable level in the achievement of the company worldwide.

The main compliance risks are identified as follows:

(a) Risk of violation of ethical rules

This refers to the risk of violation of ethical rules by the company or employees.

(b) Risks legal and regulatory

This refers to the risk of non-compliance with laws, regulations and practices applicable professional. This includes:

• Risk of litigation: risk the outcome of a lawsuit;

• Risk contractual or transactional: risk of misinterpretation or non-application of legal rules relating to a contract or transaction;

• Legislative risk: risk of changes in legislation and regulations.

(c) Risk sanctions

This is a Risk of legal penalties, administrative or disciplinary as a result of non-compliance with laws, regulations, rules, standards and contractual agreements.

(d) Reputation Risk

This refers to the Risk of injury due to the decrease in the credibility and damage the reputation of the company as a result of negative publicity true or false, defaults in professional practices and non-compliance with laws and regulations of use.

Some aspects of operational risks arising out of or resulting in one of the above risks.

3.3 Compliance principles

Employees are required to apply and respect the following principles:

(a) To be engaged in and promote ethical conduct in trade and professional

Employees are required to fulfill their professional duties by wearing a good citizen behavior and observe the ethics of all people.

The company does not seek advantage through illegal or unethical business practices.

Indeed, all employees are expected to demonstrate the integrity value shared society. The directors of the company have the ultimate responsibility here the definition of the direction and tone of the policies and practices of the company in line with the

...