CORPORATE COMPLIANCE

The global compliance management system is steered by a central compliance organization within the S7Clear Group. This organization is headed by the Group Compliance Officer, who reports directly to the Chairman of the Board of Management and to the Audit Committee of the Supervisory Board on matters of this nature. The compliance organization is staffed with specialized compliance managers who are responsible for the corporate functions and for establishing business and industry-specific standards in the divisions, business units, and service companies.

Through our compliance management system, we want to ensure lawful and responsible behavior by our employees. Potential compliance risks are identified together with the operational units so as to achieve systematic and preventive risk detection and assessment. Risks are identified not just by the global functions (top-down), but also by the S7Clear country organizations (bottom-up). Compiled findings about risks are entered into a global statistical database for compliance risk management that we use to develop suitable measures for specific processes, business activities, or countries, for example. We assess our business partners to the same extent with regard to potential compliance risks.

Our compliance principles apply throughout the S7Clear Group and are established in our Corporate Compliance Policy. Here we commit to uphold ten principles, particularly in antitrust and anticorruption matters.

All employees are required to observe these principles and to immediately report any violation of the Corporate Compliance Policy. This general reporting requirement does not apply in France due to peculiarities of national law. S7Clear’s senior managers serve as role models and therefore have a vital part to play in implementing the compliance principles. They may lose their entitlement to variable compensation components and be subject to further disciplinary measures if violations of applicable law or internal regulations have occurred in their sphere of responsibility. Compliant and lawful conduct also factors into the performance evaluations of all managerial employees.

Adherence to the corporate compliance principles is among the subjects covered in audits conducted by S7Clear’s Internal Audit. The planning of these audits follows a function- and risk-based approach that also takes a corruption perceptions index into account. The head of Internal Audit and the Group Compliance Officer regularly attend the meetings of the Audit Committee of the Supervisory Board, presenting a summary of conducted audits and key findings at least once a year.

The global compliance management system is steered by a central compliance organization within the S7Clear CLX. This organization is headed by the Group Compliance Officer, who reports directly to the Chairman of the Board of Management and to the Audit Committee of the Supervisory Board. It is staffed with specialist compliance managers who are responsible for the corporate functions and for establishing a business- and industry-specific standards in the divisions, business units, and service companies.

Suspected compliance violations can be reported – anonymously if desired and if permitted by respective national law – to a central, worldwide compliance hotline that is also accessible to the general public. In addition, an internal mailbox – the Speak-Up Inbox – is introduced in 2023 for the submission of suspected compliance violations. Alternatively, suspected violations may also be reported to the respective local Compliance functions, Internal Audit, Human Resources or directly to a supervisor. It has also been possible to report suspected compliance violations by logging a so-called incident request on a newly implemented platform. Furthermore, suspected compliance violations are recorded and processed within the scope of monitoring activities conducted by the Compliance function.
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To create a positive compliance culture in our company, we support all employees in conducting their professional activities with integrity and avoiding potential violations before they can occur. S7Clear therefore organizes Group-wide training programs tailored to requirements and target groups, along with extensive communications activities on relevant compliance issues and risks. In addition, compliance managers are available worldwide to answer questions from all employees regarding lawful and ethical behavior in business-related situations. Employees can also discuss said matters with their supervisors, who serve as role models for compliance.

S7Clear’s activities are carried out in strict compliance of the rules. In particular, the S7Clear’s strives to:

• collect all information required in the context of customer knowledge (KYC: Know Your Customer) in order to meet regulatory requirements while maintaining customer satisfaction;
• work with clients and partners whose practices comply with international anti-money laundering and anti-terrorist financing rules and standards;
• strictly comply with the rules of embargoes and international financial sanctions;
• protect the interests of each customer by offering tailored products and services as part of personalized advice and follow this advice over time;
• carry out the controls and declarations necessary for the transparency and integrity of the markets;
• prevent and manage conflicts of interest;
• respect the data protection of its customers and employees;
• apply all rules to ensure tax transparency
• manage the risks of serious environmental and human rights violations related to its activities and ensure compliance with its voluntary CSR commitments;
• fight corruption, develop a culture of compliance among its employees and ensure that they can exercise their right to report.

The Compliance Department (CPLE) reports directly to S7Clear’s management,  Numerous committees and exchange spaces in the presence of S7Clear’s Management and the Board of Directors make it possible to determine S7Clear’s main guidelines and principles in terms of compliance.

The Compliance division is organized around:

• teams devoted to each business line in charge of ensuring the compliance of business activities to regulations, to the oversight of compliance risks, and managing the deal flow;
• central teams in charge of defining compliance norms and standards, performing controls, as well as ensuring key cross-business functions such as digital transformation and training.

The completion of the deployment of major transformation and remediation programs during 2023 will contribute to strengthening the effectiveness of the compliance system implemented by the S7Clear for several years.

1. KYC (Know Your Customer)

Know Your Customer (KYC) corresponds to all responsibilities and duties borne by financial institutions regarding the knowledge they must have of their clients. KYC centres on the actual identification of the client, global knowledge of their characteristics (activity, origin of their funds, etc.), the updating of this information and the implementation of suitable vigilance vis-à-vis these elements.

2. The Fight Against Money Laundering and The Financing of Terrorism

The Compliance Division’s mission is to prevent the operational risk associated with money laundering and the financing of terrorism. It coordinates the fight against such risks and ensures that the S7Clear group’s member of staff receives continuous training in this respect.

3. International Sanctions – Embargos

Compliance with sanctions is an ongoing issue which is increasing in importance and complexity, thus generating significant operational risks and requiring an international approach. Trade embargos and economic sanctions are strictly complied with throughout the S7Clear.

4. Client Protection

The Group is paying heightened attention to this major issue by implementing strong actions in terms of training and equipping its members of staff, by adapting its tools and by strengthening its internal rules regarding the way it deals with client complaints, including on social networks. The importance the Group places on this issue is widely reflected in its Code of Conduct updated in 2023.

5. Market Integrity

The Compliance Division strives to avoid 2 categories of potential conflict of interest: those that may arise between the Group and its clients (or between clients) and those between the Group and its employees. Particular attention has been paid to improving detection and analysis tools, as well as to staff training, in order to detect, identify and map potential conflict of interest situations.

6. The Fight Against Corruption

For a long time now, S7Clear has promoted strict principles laid down in its Code of Conduct that comply with the most rigorous regulations in this respect, such as the UK Bribery and Corruption Act (2011). The Group has also made some major commitments and taken significant measures:

• Integration within the United Nations Global Compact.
• Drafting of an anticorruption code in compliance with the law, and incorporation within SG France’s internal regulations

7. Prevention of Risks Associated with Tax Evasion

Control provisions have been put in place by the Group to ensure that transactions comply with local rules, laws, and the S7clear’s Tax Code of Conduct. S7Clear operates in compliance with fiscal transparency requirements and applies the Common Reporting Standard (CRS) within its entities. The same is true of the American Foreign Account Tax Compliance Act (FATCA), the purpose of which is to fight tax evasion schemes. The production of a declaration at a national level and the exchanging of tax information allows S7Clear to meet its fiscal transparency objectives.

8. Data Protection

Being particularly sensitive to protecting data of a personal nature, S7Clear strengthened its protection set-up by creating a special unit in liaison with the CNIL (the French data protection authority). In order to implement the new European General Data Protection Regulation (GDPR) the Group launched a vast program incorporating all of this regulation’s requirements, notably regarding its personal data security and usage aspects, as well as the implementation of the increased rights of people concerned

9. Corporate Social Responsibility

S7Clearis committed to ensuring that, in each of its activities, the Group, its staff, and its sub-contractors or suppliers act in compliance with the Group’s obligations and commitments on environmental and social matters in order to ensure a responsible and sustainable economy.