- Good afternoon, Ilyas! We are happy to welcome you back. You have previously told our esteemed readers what compliance is and the history of its origins. Today we would like to ask you to talk about the role of compliance in the Corporation.
- Good afternoon, thank you for your interest in the subject of compliance.
I would like to start by saying that with the emergence of international standards and extraterritorial laws, regulatory requirements and regulatory impact measures, as well as the active growth of international sanctions, it becomes especially important to have the ability to respond in a timely manner. In other words, compliance is an integral part of internal control for any organisation, with the objective of preventing and/or reducing compliance risks within the organisation. Compliance risk is the risk of regulatory sanctions, financial loss and reputational damage to the organisation as a result of non-compliance with laws, policies, regulations, rules and codes
The International Compliance Association (UK) defines the concept of "compliance" as the ability to act in accordance with established rules, norms, requirements and internal standards.
In brief, the role of compliance at the Corporation is to ensure that employees of the Corporation comply with the requirements of legislation, both local and international, that may affect the Corporation's business, as well as internal policies and regulations.
- Ilyas, can you identify the main goals and objectives of compliance in your work?
- The main goals and objectives may include - preventing the Corporation from violating legislation, including international legislation, affecting the Corporation's operations, and minimising the risk of the Corporation being involved in processes that may lead not only to financial losses, but also to the loss of public confidence in regulators, shareholders, counterparties and so on, i.e. minimising compliance risk.
- Ilyas, do you have a conflict of interest as a compliance controller when performing your functions?
- I would like to point out that this is a very good and correct question.
First and foremost, the Compliance controller is accountable to the Board of Directors of the Corporation; therefore, the term of office and dismissal of the Compliance controller is based on a resolution of the Board of Directors of the Corporation.
Secondly, a compliance controller cannot hold a part-time position in other structural divisions of the Corporation.
All of these provisions are set out in the Corporation's internal documents to ensure that the Compliance controller does not have a conflict of interest in the performance of his or her duties.
- Ilyas, can you tell us in more detail about your functions within the Corporation? And if highlighting the main ones, what would you point out?
- If we talk about the core functions within the Corporation, we need to look at the direction of the Corporation's core business, and that is investing in alternative asset classes such as hedge funds, private equity, real estate and infrastructure. Therefore, as part of due diligence for investments, there is a need for compliance due diligence, using all available sources, including official internet resources of regulators in relevant jurisdictions, including international commercial databases.
In addition, it can also be noted the following compliance controller processes that are carried out in the Corporation, such as - identification and minimization of risks associated with a conflict of interests, measures aimed at combating corruption, monitoring the security of confidential and insider information, consideration of issues of ethical behavior of employees, monitoring and preparation of timely reviews of changes and/or additions according to anti-corruption legislation, development of internal policies and rules within the competence of compliance, including participation in the approval of internal documents and/or business processes of the Corporation's divisions, conducting training for employees on compliance issues.
All of the above processes overlap in one way or another with the business processes of other divisions of the Corporation, and therefore it is very important to inform each employee about their importance and significance in order to prevent possible compliance risks.
- Ilyas, thank you for the detailed information about the role of compliance in the Corporation, we wish you great success in your work and effective compliance risk management!