Ethical conduct is a core value, and forms the foundation of trust we create with our customers, our communities and each other.
Our Code of Conduct and its supporting guidelines and standards guide our people in their day-to-day business activities. All employees are trained on the Code and sign an annual statement confirming their compliance with its terms. They participate in mandatory mutual respect and financial crime fundamentals training and, as of 2019, privacy training as well. This new course reiterates the importance of safeguarding all personal information related to our customers, service providers, business partners and employees, and outlines the steps we must all take to do so.
Over the past several years, we’ve enhanced our policies and practices for addressing the risks of money laundering, terrorist financing, violation of sanctions, bribery and corruption, as well as external fraud, recognizing their ability to distort trade and inhibit economic growth.
We introduced our Financial Crime Policy in late 2017 and have since been working to operationalize it in our business, starting with our higher-risk product lines. The strengthening of our “know your customer” onboarding process for financing products was a big step forward in getting to know prospective customers better and considering additional financial crime risk indicators earlier in our relationship with them.
With the 2019 implementation of an automated risk assessment tool, our baseline due diligence process is becoming more consistent, accurate and efficient. The new tool screens all customer information collected to determine if risk indicators are present and therefore require enhanced due diligence by our experts and potential strengthened risk mitigation measures to be introduced(1).
In 2019, we also recognized that our internal due diligence practices and existing information sources don’t always provide a full picture of the underlying risks present in transactions or relationships. To remedy this, we started making more frequent use of third-party experts to conduct more in-depth analysis and, in many cases, on-the-ground direct research into the counterparties we’re being asked to work with or into specific country or industry sector scenarios where corruption and bribery are particularly concerning.
(1) In 2019, 183 transactions underwent financial crimes enhanced due diligence.