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Internal control system in the bank holding company JSC Belagroprombank

 

Internal control system in the bank holding company JSC Belagroprombank

Internal control system includes internal control, internal audit, organizational pattern, the local regulatory acts of JSC Belagroprombank (“LRA”) defining the strategy, the policy, the methods, the internal control procedures, as well as the powers and responsibilities of the management bodies and officials. JSC Belagroprombank (“the Bank”) has designed and approved the LRA - the Regulations on the Internal Control Management and Implementation in JSC Belagroprombank and in the bank holding company JSC Belagroprombank describing the internal control system of the bank holding company on the consolidated basis.
 
The key objectives of internal control in the bank holding company 
  • efficiency and orderliness of business and financial performance;
  • soundness of assets;
  • observance of contractual liabilities;
  • compliance with the legislation of the Republic of Belarus, the LRA, local regulatory acts of the participants of the bank holding company.
The key tasks of internal control management and implementation in the bank holding company
  • development and adoption of review procedures taking into account the nature and volume of banking and other operations (transactions) and other activity;
  • clear distribution of powers and responsibilities related to internal control management;
  • timely reporting to the Bank’s management bodies, the Chairman of the Board, the official responsible for internal control in the Bank, committees under the Supervisory Board of the Bank, as appropriate,  on the problems encountered, frauds and drawbacks in the bank holding company activity which may lead to adverse consequences, with the purpose of taking remedial action;
  • ensuring the continuous involvement of the Bank’s management bodies in managing and operating of the internal control system in the bank holding company;
  • management of the effective coordination between the Bank and the participants of the bank holding company.
 
Principles of management of the internal control system in the bank holding company
  • complex approach to internal control system management;
  • responsibility for the efficient functioning of internal control system of the bank holding company;
  • comprehensive approach to internal control system management;
  • consistency and continuity of internal control;
  • methodological unity;
  • diversification of the types of control depending on the functional accessory of the monitored objects, the current need and  complexity of the tasks assigned;
  • priority for use of software control tools, if given an equal choice between automated and non-automated  control;
  • implementation of measures on the avoidance of conflicts of interest and events triggering it;
  • continuous monitoring and improvement of the internal control system;
  • monitoring of performed operations using the CCTV surveillance system.
 

The organizational pattern of the internal control system in the bank holding company

 
 Internal control in the bank holding company consists of three macrolevels:
  • the level of the Bank;
  • the level of the Bank over the activity of the participant of the bank holding company;
  • the level of the participant of the bank holding company. 
The subjects of the internal control system at the level of the Bank:
  • General Shareholders’ Meeting of the Bank;
  • Revision Committee of the Bank;
  • Supervisory Board of the Bank;
  • Committees under the Supervisory Board of the Bank;
  • Management Board of the Bank;     
  • Standing collegial bodies of the Bank;
  • Independent directors – members of the Supervisory Board of the Bank;
  • Official responsible for the internal control of the Bank;
  • Internal Control Department;
  • Internal Audit Department;
  • Other subdivisions (within the area of their competence);
  • The Bank’s management and employees at all levels within their competence.
 
The subjects of the internal control system at the level of control by the Bank over the activity of the participant of the bank holding company:
  • General Shareholders’ Meeting of the Bank;  
  • Supervisory Board of the Bank;
  • Committees under the Supervisory Board of the Bank;
  • Management Board of the Bank;
  • Deputy Chairmen of the Board, Executive Directors;
  • The Bank’s representatives in joint stock companies;
  • The Bank’s authorized persons;
  • The Bank’s representatives in Revision committees of the participants of the bank holding company;
  • Centre for implementation of investment projects;
  • Internal Audit Department;
  • Other subdivisions of the Bank (within the area of their competence).
 
The subjects of the internal control system at the level of the participant of the bank holding company:
  • General Shareholders’ Meeting of the joint-stock company;
  • Supervisory Board of the joint-stock company;
  • Revision committee of the participating companies of the bank holding company;
  • Heads of the participant of the bank holding company of all levels;
  • Employees of the participant of the bank holding company.
 
Internal control system in the Bank is implemented in the following directions:
  • Control over achievement of strategic target goals;
  • Control over the efficiency and effectiveness of the financial and operating activities of the Bank when performing banking and other operations (transactions) and other activity;
  • control over soundness of the Bank’s asserts and investments;
  • control over the validity, completeness, impartiality and timeliness of accounting record-keeping, preparation and submission of accounting (financial), prudential and other statements (for outside and internal users);
  • control over the distribution of powers and responsibility;
  • monitoring compliance by the Bank and its employees with the legislation of the Republic of Belarus, the LRA, including during transactions with insiders;
  • monitoring management of appeals of individuals and legal entities;
  • monitoring compliance with the legislation of the Republic of Belarus related to banking, commercial and other secrecy protected by law, and with the information disclosure requirements set by the National Bank;
  • Control over the efficiency of the risk management system;
  • Control over the performance of information systems, management of dataflow (receipt and transfer of information), information security;
  • Control over avoidance of conflict of interest (triggering events) in the Bank’s activity;
  • Internal monitoring of internal control system;
  • Control over the activity management on prevention of money laundering, financing of terrorist activity and financing of proliferation of weapons of   mass destruction;
  • Control over efficiency of the activity of the participating companies of the bank holding company and compliance thereof with the requirements of the legislation of the Republic of Belarus and with the local regulatory and legal acts.
 
Information on the appointment of the officer responsible for internal control at JSC Belagroprombank
 
The officer responsible for internal control at the Bank: Inessa Melchakova, Head of Internal Control Department (appointed on 13.06.2016 by the Order of the Bank with the consent of the Supervisory Board of the Bank).
While the official responsible for internal control at the Bank is temporarily absent (vacation leave, temporary incapacity, business trip), or when there is a vacant position of  the Head of ICD, the functions of the official responsible for internal control at the Bank shall be performed by a substitute employee who  obtains the relevant powers, rights and obligations and who is responsible for  proper performance of the functions assigned to him (one of the deputies of the Head of Internal Control Department: Yury Delikatny; Mark Vasiliuk).
 

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