Lack of legal compliance of internal regulations and the ensuing risk of legal or regulatory sanctions, material losses or reputation risk is one of the areas threatening the banking activity. By monitoring compliance with both internal and external regulations, Bank Millennium considers it to be particularly important:
- Preventing money laundering and financing of terrorism;
- Ensuring consistency of Bank Millennium’s internal normative acts with generally binding laws as well as recommendations issued by supervisory authorities,
- Counteracting and managing conflicts of interest,
- Observance of ethical principles,
- Restricting personal transactions and protecting confidential information related to Bank Millennium, financial instruments issued by the Bank as well as information connected with purchase/sale of such instruments.
- Monitoring and ensuring compliance of the investment products covered by MiFID II.
Bank Millennium undertakes appropriate actions for the purpose of ongoing and continuous tracking of changes occurring in generally binding legal regulations as well as recommendations and guidance given by supervisory authorities, both national as well as of the European Union.
In order to ensure compliance of the Bank’s operation with the generally applicable laws, the Compliance Department undertakes a number of activities such as: informing about changes in law, periodically reviewing all internal normative acts binding at the Bank in terms of compliance with applicable laws and standards, analysing new products and services, measuring compliance risk in processes operating at the Bank, issuing opinions, participating in key implementation projects, or staff training.
The scope of actions undertaken by the Group may generate a conflict of interest between these actions and the interests of Customers. The Group’s main principle is to take all reasonable steps to identify a conflict of interest between the Group and its Customers, as well as between individual Customers, and also to establish rules ensuring that such conflicts have no adverse impact on Customers’ interests.
The Bank Millennium Group undertakes also appropriate actions to ensure conduct concerning personal transactions, which is compliant with standards and laws. These actions and measures are meant to, according to the circumstances, to restrict or prevent performance of personal transactions by Relevant Persons in situations, which may cause a conflict of interest or be involved with access to confidential information or to data about Customers’ transactions. Shares of Bank Millennium are admitted to public trading on the Warsaw Stock Exchange. Such status requires special attention and observance of the obligation to maintain highest standards for transparency of financial markets. The policy of Bank Millennium Group is to maintain strict control as regards protection of the flow of Confidential Information (including in accordance with the requirements of Regulation No. 596/2014 of the European Parliament and of the Council of 16 April 2014 on abuses on the Market Abuse Regulation MAR). The Bank prohibits the use and disclosure of Confidential Information in any form. Purchasing and selling the Bank’s shares, derivative rights concerning the Bank’s shares or any other financial instruments thereto related is forbidden during closed periods.
The Anti-Money Laundering and Counter Terrorism Financing Programme (AML/CTF), applied by Bank Millennium, is a comprehensive system of identification of threats related to money laundering crimes.
Actions launched under this programme include in particular:
- application of financial security measures to Customers, depending on the degree of risk and based on „Know your Client” or KYC principle – the key concept of the program,
- transaction registration and reporting,
- identification of suspected transactions,
- cooperation with the General Inspector of Financial Information.
Bank Millennium adjusts its reports to the analysis of suspected transactions on the on-going basis, taking into account up-to-date patterns (sectors, cash-flow routes, Customer behaviour) for effective identification and reporting of transactions suspected of money laundering.
Our internal procedures, organisational solutions and employee training programmes ensure efficient operation of the Programme.
Bank Millennium with view to protecting Customers who invest their funds in investment products with varied degree of risk strictly monitors compliance of these products, their offering and handling process with relevant internal regulations, laws and external guidelines – on the domestic and European Union level.
A specific compliance monitoring program also covers consumer loans and insurance products addressed to consumers.
The Bank has mechanisms and internal regulations allowing for anonymous reporting of violations of law and internal regulations and ethical standards (so-called whistleblowing) to the Chairman of the Management Board and in the case of notification concerning a Member of the Management Board – to the Supervisory Board. The Bank will verify each application, ensuring that the reporting person will be protected by acts of repressive, discriminatory and unfair nature.
By 25 May 2018 the Bank aligned its activity in all key areas with GDPR. The Bank’s approach is based on an assessment of risk involved with processing of personal data and its impact on the rights and freedoms of data subjects. In the project the Bank adjusted its internal data processing processes and also built new information processes, which it made available to data subjects. For this purpose the Bank implemented processes for handling enquiries and requests resulting directly from the rights of data subjects introduced by GDPR and was working on transparency of presented information about processed data.