The purpose of the Bank’s organizational structure is to guarantee an adequate level of control that assures suitable segregation of functions.

The Bank’s highest hierarchical authority is the Board of Directors. The Bank’s General Management consists of the General Manager and the Deputy General Manager. The General Management reports directly to the Board of Directors.

The Secretary of the Board of Directors is assigned the special task of coordinating the Board’s activities with the General Management and helping the Board of Directors in its responsibilities in the interest of the Bank and its shareholders.

The Bank is organized functionally into the following departments and divisions. They hierarchically report as follows:

To the General Management:

Corporate management areas:
1. Department of Global Risk Control (CRO)
2. Anti-Money Laundering and Terrorism Financing, Data Protection Department and Client Services Department
3. Internal Audit Department

Foreign trade and financing area:
4. Operations Department

Commercial area:
5. Commercial Department

Corporate management areas:
6. Accounting Department
7. Administration and Human Resources Department
8. Treasury and Capital Markets Department
9. Information Technology Department
10. Legal Department

Local Branches report functionally to the Operations Department regarding the operating activities of the business carried out by the branches

In support of the departmental specialization, where the lines of responsibilities are well defined, the bank has established inter-departmental committees to guide, contribute to, or share the decision-making responsibility when conducting its business and manage its risks.  The committees involved in the continued control, monitoring and evaluation of the Bank’s risks are, fundamentally, the following:

-     The Administration and Procurement  Committee.

-     The Commercial Committee.

-     The Assets and Liabilities Committee (ALCO)

-     The Internal Control Body on AML (OCI) - Special Committee

-     The New Products/Investment Committee

As part of the Bank’s, control function, the Internal Audit Department reports functionally to the Audit Committee. The Global Risk Control Department (whose responsibility lies with the CRO) and the Compliance, Organization, Methods, and Digitization Department report functionally to the Risk and Compliance Committee. 

The bank is observing the mandates of the laws and regulations with regard to information security, privacy, and personal data protection with the application of organizational and technical measures. The Bank has also appointed a Data Protection Officer in compliance with GDPR, Regulation (EU) 2016/679.

The Bank has a responsibility towards handling customer complaints with care. The Clients Services,  composed of a staff member in the Department of  Compliance, Organization, Methods, and Digitization, is assigned the role of the Customers Ombudsman to avoid any conflict of interest.

CONFLICT OF INTEREST CRITERIA

The employees must avoid conflict situations between their personal interests and those of the Bank’s or its clients. For these purposes, they shall inform their direct supervisors of any business or shareholders relationships that may potentially be compromising or conflictive in this respect

 

The employees shall not become involved in any transactions, businesses or contracts on behalf of the Bank with clients, individuals, or companies in which the employees or their close relatives may have a direct or indirect interest or which may be in direct competition with the Bank, without the written authorization of the Manager of their Unit or the General Management and the Manager of Human Resources.

 

The employees shall not be entitled to provide professional services, in return or not for remuneration, to other institutions competing with the Bank, regardless of the type of relationship between them, except by expressed authorization of the General Management and the Manager of Human Resources

 

The employees performing other professional activities as consultants, accountants, solicitors, advisers, or administrators for others rather than the Bank must inform the Manager of Human Resources of this circumstance in writing as soon as it may arise, and in the event of a conflict arising, priority must be given to the exercise of their functions at the Bank

In the event of a conflict of interests between a Unit and its clients, or between current and prospective clients of the Bank, it would be convenient to seek the advice of the Manager of the Unit, General Management or the Manager of Human Resources in order to ensure that fairness and impartiality are maintained.

 

In the event of the Unit Managers, General Management, or the Human Resources Manager requiring advice in respect to this matter, they must seek the advice of their corresponding supervisor in hierarchical order.