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9. Compliance Function

1.Compliance Staff must have a sound understanding of the Central Bank laws and other relevant laws, Regulations, rules and standards, relevant to the Company's business and keep abreast with their development and any amendments thereof. The professional skills of compliance Staff must be maintained through regular and systematic education and training, including courses on real cases relating to money laundering, financing of terrorism and proliferation financing.
 
2.The compliance function must have access to any member of Staff and all records and data of the Company, and if applicable, the Company's Affiliates and Subsidiaries, which are required to comply with the Central Bank's requirements.
 
3.A consistent approach to compliance across the Group may be achieved through the establishment of a Group compliance function accountable to the Board of the Controlling Shareholder, or through compliance functions established in each entity (or branch) and accountable to those entities' Boards and also reporting to the Group's head of compliance.
 
4.The compliance function must be assigned responsibility for the following, at a minimum:
 
a.Establishing a compliance policy and a compliance plan. The compliance policy must define the responsibilities, competencies and reporting duties of the compliance function. The compliance plan must set out the planned activities of the compliance function which take into account all relevant areas of the activities of the Company and exposure to compliance risk.
 
b.Assessing the adequacy of the measures adopted by the Company to prevent non-compliance with Central Bank Laws and Regulations.
 
c.Maintaining a corporate culture that is based on responsible conduct and compliance with internal and external obligations.
 
d.Identifying, assessing, monitoring, mitigating, reporting on, and addressing regulatory obligations and the risks associated therewith.
 
e.Conducting on-going training on regulatory obligations for Staff responsible for high risk activities.
 
f.Enabling confidential reporting by Staff regarding any breach of legal or regulatory obligations or internal policies.
 
g.Addressing any instances of non-compliance and ensuring that disciplinary action is taken, along with the required reporting to the Central Bank.