Compliance

BOCOM BBM pursues compliance with all internal and external laws applicable to the institution, and with all laws, regulations and recommendations issued by the bodies and agencies responsible for the markets in which it operates, in order to mitigate the operational, financial and reputational risks inherent in the nature of its business.

BOCOM BBM holds the conviction that in order to achieve its shareholders’ objectives it must operate in accordance with ethical principles shared by all employees and by its management. Its actions must be based on integrity, reciprocity, loyalty and transparency, as well as respect for individuals and valorization of their privacy, personality and above all their dignity. We believe in the importance of social and corporate responsibility. We engage with the communities and especially with the countries in which we operate. This attitude assures the long-term sustainability of our business.

We have a Code of Conduct & Ethics comprising the concepts and guidelines to be observed in our professional activities in order to achieve ever higher objectives, reflecting our cultural identity, and our responsibilities and commitments to the markets in which we operate and the people with whom we interact.

In this context Compliance acts independently and impartially as a pillar of the institution’s governance framework, ensuring that its business activities are conducted in accordance with the highest ethical and professional standards. Its three main fronts are regulatory compliance, anti-money laundering and combating the financing of terrorism (AML/CFT), and prevention of corruption.

Regulatory compliance aims to prevent and mitigate the risk of non-compliance with rules and regulations, and with the ethical and conduct guidelines. It does so, among other things, by issuing internal normative documents, performing constant and timely surveillance of the institution’s compliance with the legal and regulatory framework, and training staff to disseminate a compliance culture.

In the context of AML/CFT, Compliance enforces such processes as Know Your Customer (KYC), Know Your Employee (KYE), Know Your Supplier (KYS) and Know Your Partner (KYP), as well as constant monitoring of transactions performed by our clients and prior analysis of new products and services. In this way, Compliance seeks to ensure that BOCOM BBM’s structure is not used to lend a legitimate appearance to funds of illicit origin and acts to prevent such funds from entering the formal economy.

The same surveillance procedures apply to both AML/CFT and the prevention of corruption, protecting BOCOM BBM from inadvertently becoming involved in illicit activities or relationships that could be considered corrupt practices, and hence assuring mitigation of the reputational and legal risks arising from such issues.

In order for Compliance to carry out its activities satisfactorily, it must be sponsored by top management, which must be involved in addressing the issues concerned and disseminating the highest standards of integrity and ethical conduct as part of the institution’s culture. BOCOM BBM’s compliance framework therefore includes a Compliance Committee, which reports directly to the Board of Directors. The committee meets every quarter or on demand to approve the annual compliance program, examine regulatory requirements, discuss matters relating to institution-wide compliance, and establish AML/CFT guidelines. The committee’s appreciation of cases relating to these matters serves as a basis for a final opinion supporting or denying submission to the regulatory authorities of the suspicions raised.

POLICIES

BOCOM BBM’s policies are devised to establish, formalize and disseminate its guidelines, rules and objectives, as well as its philosophy, strategic decisions, lines of action and characteristics. They are the means for the Board of Directors and Executive Committee to convey BOCOM BBM’s culture, values and principles to all staff.

BOCOM BBM’s key policies are available in the Downloads section.

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WHISTLEBLOWER CHANNEL

Email: hotline@bocombbm.com.br

Tel: +55 21 2514-7788

+55 11 3704-0511

Postal address:

Av. Barão de Tefé, 34 – 20º andar. Rio de Janeiro – RJ. CEP: 20220-460

A/C: Gerente de Compliance

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