PDF (3.77 Mo) - Le CrÃ©dit Agricole

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Crédit Agricole S.A.Update of the 2011 registration document - A03Related partiesThe main related-party transactions entered into as of 30 June 2012 are described in note 2.3 to the interimcondensed consolidated financial statements.Internal controlGROUP INTERNAL CONTROL COMMITTEESIn keeping with the principles applied by the Group, during the first half, Crédit Agricole S.A.’s InternalControl Committee and the Group’s Internal Control Committee (the body that oversees all internal controlsystems), held periodic meetings chaired by the Chief Executive Officer of Crédit Agricole S.A.The purpose of the Committee is to reinforce cross-functional actions to be implemented within the CréditAgricole Group. It is responsible for reviewing internal control issues common to the Group as a whole(Crédit Agricole S.A., subsidiaries of Crédit Agricole S.A., the Regional Banks, resource pooling entities) andto ascertain the consistency and effectiveness of internal controls on a consolidated basis. The InternalControl Committee, a decision-making body the decisions of which are executory, is responsible mainly forcoordination of the three control functions: Risk Management and Permanent Controls, Compliance, andControl and Audit-Inspection.RISK MANAGEMENT AND PERMANENT CONTROLSThe Group Risk Management and Permanent Controls Department is responsible for overall riskmanagement and for the Group's permanent control system.In addition to its ongoing responsibilities, in the first half of 2012, this department worked on the followingmatters:- coordination and support of Group entities in the roll-out of the approaches put forward with a view toBasel III;- involvement in industry works and impact studies on CRR 1 and CRD 4 (Basel III), due to beintroduced in early 2013;- work on a stress test exercise required by the IMF (FSAP) from all French banks, finalised in June2012;- enhancing of the corpus of Risk management and Permanent Control procedures (updating of theprocedure concerning the alert system relating to operational risks at Crédit Agricole Group,management of major client concentration risk etc.);- adoption of an updated reference framework of permanent control indicators taking into accountliquidity risk in particular;- formalisation of the Recovery and Resolution Plan (risks, crisis scenarios, management proceduresetc.) for presentation to the ACP and supervisory authorities.COMPLIANCE RISK PREVENTION AND CONTROLThe Group Compliance Department devises Group policies relating to compliance with legal and regulatoryrequirements, ensures that they are disseminated accordingly and oversees their observation.In the first half of 2012, the Group Compliance Department launched a number of projects relative tocustomer protection. The initial subjects addressed and shared by all Group entities include optimisingprocedures for New Products/New Activities (“NAP”) and implementing the ACP recommendation onhandling complaints. More specifically, a project dedicated to customer protection was set up, involving theCrédit Agricole S.A. departments in charges of customer relations for the Regional Banks. The aim of thisPage 106 sur 237
Crédit Agricole S.A.Update of the 2011 registration document - A03project is to combine the regulatory aspects and relational commitments made by the Regional Banks in theroll-out of the Group project.At the same time, the Group Compliance Department has taken steps to enhance application of the MiFIDDirective concerning updating customer qualification and protecting fragile persons investing in the financialmarkets.In the area of financial security, the persistence of global political and economic crises necessitates thepermanent upgrading of procedures within Group entities, particularly in terms of embargos and freezing ofassets. In France, the Group Compliance Department took part in industry works on the implementation ofan identification form for beneficial owners and a formalised specific procedure, in accordance with thedemands of the EU’s Third Money Laundering Directive, which will be rolled out within Group entities duringthe autumn of 2012. Concerning tools, deployment in ongoing of the tool for detecting unusual transactionswithin international retail banking subsidiaries (Albania, Romania, Bulgaria), as well as for the filtering tool forSwift payment flows (regulations concerning embargos and freezing of assets).As regards fraud prevention, the renewal of the questionnaire on the roll-out of procedures in all Groupentities helped to enhance steering by the Compliance Department. This system is now in place at allentities. Efforts will continue in the second half of the year in terms of the management and roll-out ofsteering tools and tools to fight identity and document fraud. Work is also underway to temporarily extend thescope of existing detection tools in respect of fighting money laundering. In addition, a benchmark of markettools specialising in fraud prevention is in the process of being set up.The Group has also pursued a variety of training initiatives, including the roll-out of the new version of theCompliance e-learning module and the creation of a two-day training programme dedicated to fraudprevention.Lastly, the Group’s relevant business lines are engaged in an active regulatory watch of currentdevelopments in Europe and the United States. In particular, the plan for complying with FATCA regulationsis steered by the Group Compliance Department.PERIODIC CONTROLSGroup Control and Audit has the exclusive responsibility of carrying out periodical controls of the CréditAgricole Group through its audits and through oversight of the Crédit Agricole S.A. Group Control and Auditfunction, which reports to it.During the first half of 2012, Group Control and Audit conducted on- and off-site audits of a number ofentities and units, and namely on the means of calculating economic capital (Basel II - Pillar 2), corporategovernance and management of payment methods, filtering of international payment flows, ExchangeTraded Funds (ETFs), the creditor insurance subsidiary CACI, foreign subsidiaries of which Credit AgricoleSerbija, Cariparma (control and credit risk) and Centea (following its acquisition by Crédit Agricole deBelgique), the system for managing liquidity and loans eligible for refinancing at the Regional Banks,workplace safety and critical infrastructures at SILCA, and a number of other financial, regulatory andtechnological issues.Through the relevant Group subsidiaries’ Internal Control Committees, which are composed ofrepresentatives of each entity’s senior management and internal audit department as well as theirPermanent Controls and Compliance Officer, in overseeing the control and audit function, Group Control andAudit ascertains that audit plans are successfully carried out, that risks are properly managed, and, moregenerally, that each entity’s internal control systems are adequate.Page 107 sur 237
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