Compliance and integrity

Compliance and integrity are integral elements of corporate culture at the EIB Group. They are the shared responsibility of all EIB Group staff and members of the governing bodies. Ethical and compliant behaviour is embedded in the relevant policies, procedures, practices.

The Office of the Chief Compliance Officer (OCCO) is a key independent control function within the EIB Group for ensuring the integrity of staff, management and activities. OCCO’s central responsibility is to safeguard integrity and to minimise compliance and reputational risk by defining and developing an adequate compliance policy framework and ensuring its enforcement, issuing opinions on operations with risk scoring and ensuring ongoing monitoring, but also examining all cases of alleged breaches of the Staff Code of Conduct.

In line with these priorities, the ‘EIB Group Anti-Money Laundering and Combating Financing of Terrorism Framework’ (‘EIB Group AML-CFT Framework’) establishes the key principles regulating AML-CFT and related integrity issues in EIB Group activities. The Framework should be read in conjunction with other relevant EIB Group policies and guidelines.

OCCO has been coordinating an extensive revision of the existing EIB Codes of Conduct and of the Whistleblowing Policy, considering best practices and standards set by the EU and other international financial institutions, while incorporating the principles of EU legislation. The revision process aims to identify the core ethical values that are shared and applied throughout the EIB Group and to strengthen compliance at Group level with rules and effective enforcement.

OCCO is the responsible service for compliance and integrity topics, as defined in its Terms of Reference which follow the standards and guidelines issued by the European Banking Authority and Basel Committee for Banking Supervision. Both OCCO’s Terms of Reference and the Integrity Policy and Compliance Charter of the EIB Group are modelled on Best Banking Practices, which are being revisited and further codified as part of an EIB working group. With OCCO in charge of regulatory compliance, it has taken an active role in the Best Banking Practices working group.

Combating tax avoidance

The EIB Group, supported by the expert OCCO tax team, is committed to maintaining a stringent policy of combating tax fraud, tax evasion, and aggressive tax avoidance. One of the most significant developments monitored by the EIB tax team in coordination with other services relates to good tax governance proposals and initiatives at the EU and international levels. The EIB Group supports the adoption of the EU Anti-Tax Avoidance Package, whose purpose is to create a strengthened level of protection against corporate tax avoidance throughout the EU. The EIB Group welcomes the EU list of non-cooperative jurisdictions for tax purposes, adopted at the ECOFIN meeting in December 2017. This list will be incorporated into the EIB policy framework. Furthermore, OCCO organised the international conference ‘Tax – Compliance – Ethics: International Taxation – Role for International Financial Institutions?’ on 5 October 2017. The conference demonstrated that tax remains a high priority item on the international policy agenda and is a worldwide issue calling for global action and responses.

The Compliance function coordinates and oversees the implementation of the Market Abuse Framework. Adding to the policy-making and awareness-raising dimensions, a consultation dimension is growing, as EIB services increasingly consult OCCO on the implementation of the Market Abuse Framework.

Reinforcing the Group approach

In line with its Terms of Reference, the remit of the Group Chief Compliance Officer is to identify, assess, advise on, monitor and report on the compliance risk of the EIB Group. The EIB and EIF are further strengthening the cooperation between their Compliance functions with the objective of achieving closer alignment across the Group. The reinforcement and consistency across the Group will be achieved by adopting Group policies and exchanging on best practices and respective business knowledge.