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KEY POSITIONS IN BANK RISK PROFILE
- General Management (General Manager and Deputy General Manager) - Manager of the Business Development Department - Manager of Treasury & Capital Markets Department - Manager of the Back office - Manager of Legal Department - Manager of Internal Audit Department - Manager of the Department of Global Risk Control (CRO) - Manager of the Accounting Department - Manager of Information Technology Department - Manager of Administration and Human Resources Department - The Responsible for Anti-Money Laundering and Terrorism Financing, Data Protection, and Client Services
KEY POSITIONS SUITABILITY ASSESSMENT PROCEDURES
Time and type of the suitability assessment: The assessment of the individual suitability of key function holders shall be initiated for the reasons indicated below: Procedure: 1. When the Nominations and Remuneration Committee becomes aware of the candidacy of the individual for a key position subject to this procedure, the Secretary of the Committee will send a communication to the candidate explaining and requesting the information to be provided and completed. 2. Once received all required documentation, the Committee shall meet with the candidate in person. In case there is no possibility to meet the candidate in person, the candidate's information will be circulated by electronic mail or any other means, which allows for keeping a documentary trial. The committee usually analyzes the following information: Specific suitability criteria applicable to the Key function holders: a. Requirements for honorable business and professional conduct. The intention is to analyze the professional career of the candidate, positions held, and relationships with regulatory and supervisory authorities if such exist. This will be performed through completing a questionnaire honorable and good management questionnaire made for this purpose, delivered prior to the candidate, along with providing any other information requested. In case the candidate for the position of Director, the proposing Shareholder will present the candidate to the Board of Directors with an introduction letter supporting the suitability of the candidate. b. Knowledge and experience requirements. A detailed review of the candidate's curriculum vitae will be performed by requesting the candidate the career record which includes a criminal certificate, in order to check that has no cause or prohibitions and that must be fulfilled in order to check the adequacy of the education received by the candidate for complying with the requirements set by the entity for the said position. In the event of any doubts about any of the credentials submitted, a confirmation will be requested from the institution where the studies were conducted. A whole examination of the candidate's professional history will be performed to verify the candidate’s suitability for the said position and that the candidate’s professional skills are adaptable to those required for the position. In the case of positions related to internal control or when the evaluation Committee deems it appropriate, the candidate’s professional references would be checked. The verification of professional references will always be made with the knowledge of the candidate. c. Evaluation of potential conflict of interest For the evaluation of possible conflict of interest, the candidate is required to sign a document that certifies no conflict of interest where he/she declares the non-existence of a conflict of interest and it will be confirmed in the interview with the candidate. 3. If the Committee deems it necessary, and once all the documentation is evaluated, an interview may be required with the candidate. 4. The minimum quorum for holding a Committee formal meeting shall be two members. 5. All decisions are taken by a simple majority vote, and more than half of the Committee’s members present vote in favor. 6. The decisions adopted by the Committee will be recorded in the Minutes of the meetings and will be kept, along with any other information, in the file of the Committee, under the custody of the Committee’s Secretary. 7. After the evaluation of the candidate’s suitability is completed, the Committee shall draft its conclusions in a report which will be submitted to the Board of Directors. 7.1. In the case of General Management or similar: 7.1.1 In the case that the Committee’s conclusions were in favor of the candidate's suitability: The Board of Directors itself will appoint the candidate after receiving the candidate’s acceptance. 7.1.2 In case the Committee’s conclusions were not in favor of the candidate’s suitability. The Board of Directors will decide on the search process for a new candidate. 7.2. In the case of key position holders: 7.2.1. In the case that the Committee’s conclusions were in favor of the candidate's suitability, the Secretary of the Committee will forward the candidate evaluation report to the Board of Directors. Following this, the Board of Directors will officially appoint the candidate to the position after receiving the candidate’s acceptance. 7.2.2. In the case that the Committee’s conclusions were not in favor of the candidate’s suitability, the Board of Directors will forward the Committee’s evaluation report to the General Management.
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