Strategic roadmap for ethics and professional conduct (Continuous Monitoring and Compliance, Internal Audit, Legal and Risk)
Drafting and revision of policies and management processes
- Structural reorganisation
- Strengthening of mechanisms
- Drawing-up and internal validation of policy and procedure manuals
- Improvement of processes and harmonisation of management procedures
- Continued strengthening of the mechanism for checking
- Implementation of risk manuals
- Alignment with Basel II and III standards
- Bringing of the overall portfolio’s impairment rate below 12% in 2018
- Roll-out of information systems and of reporting tools that can be audited for each subsidiary
- Setting-up of a contractual documentation database
- Establishment of annual proactive dialogue with regulators
2019 et au-delà
- Instillation of a compliance culture
- Instillation of a risk culture
- Development of a culture of checking and of self-checking
- Improvement of the quality of the portfolio
- Bringing of the overall portfolio’s impairment rate below 10% in 2019
- Securing of better legal protection for the bank
Orabank is committed to acting in accordance with legislation and regulations, and to combating illegal and unsafe practices.
A system of governance that is evolving to meet our targets
We are continuing to improve our system of governance, following the guidance of the Board of Directors, which ensures the independence of the control functions, and guarantees legal and regulatory compliance.
Roll-out of our compliance procedures
The group is responsible for respecting the various laws applicable to it and, in practice, for meeting behaviour expectations that are not enshrined in law, but take the form of established standards for international institutions. For those commitments to be met, all executives and employees must comply with common ethics rules.
Compliance with Basel standards
We achieve compliance with regulatory and statutory obligations ahead of time, and we are bringing ourselves into line with Basel II and III standards, so as to take better account of risk and bolster our group’s solidity.
New supervisory and regulatory framework
The Internal Audit Division checks the compliance of CAEMC subsidiaries with the new Central African Banking Commission (COBAC) internal control regulations, and the compliance of WAEMU subsidiaries with the new supervisory and regulatory framework.
Steps taken in 2017
In 2017, the goals related to making the group’s documentation secure. Projects were run to harmonise and draw up procedures and operational guides; to update checking plans; to boost the staffs and capacities of internal control departments in the subsidiaries; to acquire a database-analysis software package for checks that are more effective and offer more; and to increase data security.
In relation to internal audit, oversight and evaluation of the implementation of internal control mechanisms have been stepped up. In addition, the integrated risk-management, checking and internal audit tool acquired and deployed on all sites will improve how audits are conducted.
WAMU Banking Commission circular on the governance of credit institutions and financial companies
Circular on the terms and conditions of employment for executives and directors
COBAC internal control regulations
Ethique et déontologie professionnelle
Orabank is committed to making a culture of ethics, professional conduct and integrity take hold.
Laid down at holding-company level, our standards are implemented in all our subsidiaries and their branches, and are widely distributed in house.
Roll-out of our compliance procedures
Our governance system also includes the appointment of a Legal Director and Professional Conduct Officer; there is also a Professional Conduct Officer in every company, who ensures the ethics principles are applied and helps with their interpretation.
To improve the quality of supplies and increase price transparency when contracts are being awarded, the group’s senior management started, in 2016, to apply the new procurement procedure approved by the Board of Directors. This procedure, available on the Intranet, has two aspects: purchasing of goods and services, and fixed assets. Any purchase for which the value of the contract exceeds CFA F100,000 must be put out to tender.
Preventing corruption and money-laundering
Orabank is committed to applying anti-corruption and transparency policies to the ways in which the company exercises influence and to the responsibilities of its executives.
Exposure to potential risk
As retail banks, Orabank companies are exposed to the risk of corruption, of money-laundering and of the financing of terrorism. Orabank helps its teams to take ownership of a culture founded on integrity and to combat practices not tolerated by our group. The Code of Professional Conduct covers the issue of preventing corruption and money-laundering, while the Ethics Charter also tackles the anti-corruption aspect.
On-line banking regulatory compliance
Since 2012, measures to combat money-laundering have been in place, such as real-time checking of blacklists when a new customer relationship is started and during transactions. We are developing a system for analysing customers’ AML/KYC profiles (anti-money laundering/know your customer).
La politique d'alerte du Groupe Orabank
In 2014, the Orabank group implemented a whistle-blowing policy, to encourage employees or any stakeholder – the “whistle-“blower” – to report any actions that could constitute serious breaches of the group’s internal procedures and rules, and/or any criminal acts that could damage its reputation and interests.
Any whistle-blower who has reported a serious violation or criminal act in good faith, in line with the procedures laid down in the policy, will enjoy Orabank’s protection against any reprisals.
Gouvernance des risques
Orabank is committed to improving its system for identifying and managing risk relating to its operations.
Our risk-management tools and processes
Since 2015, our growth model has changed significantly and the Orabank group is incorporating the management standards of international banks:
- Group and country risk maps
- Risk-management manuals
- Risk committees’ quarterly reports
- IT tools for mitigating credit risk
- Comprehensive risk-management tool (ERMAS)
- Risk class
- Customer-satisfaction evaluation
- Risk-management training sessions
- Environmental and Social Risk-Management System (SYMRES)
- Operational risk-management policy
Our risk-management bodies
Credit risk is taken into account, just like anything inherent to the bank’s operations; operational risk, market risk and, increasingly, social and environmental risk are particularly important.
The Risk Division and its committees seek to manage credit risk, market risk and operational risk.
The Risk Division is also responsible for CSR risk.
Credit and counterparty risk
Credit-risk management necessitates a robust process that enables the bank to pro-actively manage its credit portfolio, so as to minimise losses, for one thing, and to secure a return for its shareholders’ investment, for another.
Market and balance-sheet risk
The market-risk management system within the Orabank group is an element of compliance with the regulatory standards laid down by the supervisory authorities and the application of healthy market-risk management practices.
Internal operational risk
The operational risk-management system in place at group level is intended to achieve the goals of:
- identifying and measuring evaluation of operational risk;
- managing risk and assessing checks;
- managing and monitoring preventive and/or corrective measures against the major types of risk.
Steps taken in 2017
Projects were run to improve the mechanisms:
- improvement of credit-risk management for the processing of files and the monitoring of restructured debts;
- improvement of operational risk management, in particular the conclusion of the operational risk-management policy, the setting-up of database and the collation of incidents;
- conclusion and approval of the market-risk management policy and procedures manual.
The Environmental and Social Risk-Management System (SYMRES) set up by the Orabank group is used for awarding financing and is intended to pick up on potential social and environmental risk relating to any new investment submitted to the bank. Analysis of CSR risk now takes place from the opening of a credit file. A Head of CSR Risk is appointed at group level.