Functional structure of Aresbank
The Bank’s organisational structure aims to guarantee an adequate level of control to ensure sufficient segregation of duties.
The Bank’s highest hierarchical body is the Board of Directors. The General Management is composed of the General Manager and the Deputy General Manager and reports directly to the Board of Directors.
The Secretary to the Board of Directors has the special task of co-ordinating the activities of the General Management and the Board of Directors and assisting the Board of Directors in discharging its responsibilities in the interests of the Bank and its shareholders.
The Bank is functionally organised into the following departments reporting hierarchically as follows:
To the General Management:
Internal Control Areas
1. Global Risk Control
2. Regulatory Compliance {Prevention of Money Laundering and Financing of Terrorism, Data Protection and Customer Service} 3.
3. Internal Audit
Business Development Areas
4. Correspondent Banking {Representative Offices} 5.
5. Operations
6. Domestic Banking {Branches and Commercial Branches}
Back office areas
7. Foreign trade, financing and guarantees
8. Operations
Corporate management areas
9. Accounting
10. Administration and Human Resources
11. Treasury and Capital Markets
12. Information Technology Department
13. Legal Department
The Local Branches report functionally to Business Development on the operational activities of the business carried out by the branches.
In support of the specialised departments, where lines of responsibility are clearly defined, the Bank has a number of inter-departmental committees in place to guide, contribute to or share responsibility for decision making in respect of business development and risk management. The committees involved in the control, monitoring and evaluation of the Bank’s risks are mainly the following:
– Administration and Procurement Committee.
– Commercial Committee.
– Assets and Liabilities Committee (ALCO).
– Internal Control Body (OCI) – Special Committee for the Prevention of Money Laundering.
– Credit, Investment and Risk Committee
– New Products Committee
– Technology Committee
As part of the Bank’s control function, the Internal Audit Department reports functionally to the Audit Committee. The Global Risk Control Department (under the responsibility of the CRO) and the Regulatory Compliance, Organisation, Methods and Digitalisation Department report functionally to the Risk and Compliance Committee.
The Bank complies with legal regulations on information security, privacy and personal data protection by implementing organisational and technical measures. The Bank has also appointed a Data Protection Officer in compliance with the GDPR, Regulation (EU) 2016/679.
The Bank is responsible for handling customer complaints with care. The Customer Care service, composed of staff in the Compliance, Organisation, Methods and Digitalisation Department, has been assigned the Customer Protection function, thus avoiding any conflict of interest.
Criteria for the prevention of conflicts of interest
Employees must avoid situations of conflict between their personal interests and those of the Bank or its customers. To this end, they shall inform their line manager of any business or shareholding relationship that is potentially compromising or conflicting in this respect.
Employees shall not engage in any transaction, business or contract on behalf of the Bank with clients, natural or legal persons, in which the employee or close relatives have a direct or indirect interest, or which are in direct competition with the Bank, without the written authorisation of the Head of their Division or Directorate General and the Director of Human Resources.
Employees may not provide professional services, whether paid or unpaid, to other entities competing with the Bank, regardless of the relationship on which they are based, without the express authorisation of the General Management and the Director of Human Resources.
Employees engaged in other professional activities as consultants, accountants, lawyers, advisers or administrators in matters outside the Bank must notify the Human Resources Director in writing of this circumstance as soon as it may arise, and in the event of a conflict they must give priority to the performance of their duties within the Bank.
In cases where a conflict of interest may arise between a Unit and its clients, or between current and prospective clients of the Bank, advice should be sought from the Divisional Manager, General Management or Human Resources Manager to ensure fairness and impartiality.
When Divisional Directors, General Management or the Human Resources Director need advice on this matter, they should seek it from their line manager.