Highlights in 2010

Societe Generale further reinforced the Group’s resources for compliance risk prevention and management in 2010.
The Compliance Department’s headcount in Paris increased once again in 2010, bringing the total number of staff to 80.
The number of compliance professionals rose throughout the Group and particularly in Russia where full-time staff numbered 63, including 41 employees dedicated to antimony laundering.
Ethics and compliance seminars were also organised for key managers, providing the ideal opportunity for them to share their experience and expertise.

New structure

At the end of 2010, the Direction de la déontologie went on to become the Direction de la conformité (Compliance Department), effective as of early 2011.
The resulting changes to its structure are intended to improve the coordination and management of the Group’s Compliance function and strengthen its permanent supervision. The changes made throughout 2010 led to:
  • the creation of a Head of Regulatory Relations, responsible for coordinating relations with regulators on the subject of compliance issues;
  • the setting up of a dedicated “Know Your Customer” due diligence department in charge of group-wide policy and procedure which were previously handled by the anti-money laundering and anti-terrorism financing unit.

New IT application for mapping compliance risks

Following the installation of a new application at the end of the first half of 2010, the training of its first users began in the second half and will continue in 2011, followed by the go-live phase.
This application will allow for the global mapping and assessment of compliance risks across Societe Generale Group and the follow up of action plans.

Embargo and sanction policy

A Code of Conduct has been established which sets out Group procedure for embargos and sanctions. This will be followed by the dissemination of a Group Instruction at the start of 2011.

Professional certification

As part of the reforms to the regulatory framework for financial services, the French securities regulator (AMF) has introduced a professional certificate requirement for all investment service providers, effective as of July 1, 2010.
To meet this requirement, in 2010 Societe Generale introduced a system for checking that employees to which this certification requirement applies have the necessary level of knowledge.