Description of the Business Line or Department
The Compliance Service Unit (CPLE) is responsible for the definition and consistency of the compliance risk prevention and control system, and for coordinating the framework aimed at preventing, identifying, assessing and controlling reputational risk.
In conjunction with the Business Units and other Service Units (BU/SUs), CPLE performs the following tasks with respect to compliance risk:
- defining and implementing the overall normative framework of the Compliance service and monitors its implementation;
- defining procedures and implementing a framework to ensure compliance with respect to compliance risks;
- awareness-raising among Group employees regarding compliance risk and the strengthening of the compliance culture within the Group;
- mapping and analysing Group compliance risk and general vigilance regarding issues likely to harm the Group's reputation or that of one of its activities;
- performing the second-level control and supervision of the framework, including independently assessing compliance risk management within the entities/activities with a major impact on the Group's risk profile, and individually with respect to regulated employees, in compliance with the applicable regulations;
- monitoring relations with supervisory and regulatory authorities, and representing the Societe Generale Group to these authorities, not including supervisory and regulatory authorities where the Legal function (SEGL/JUR) organises and coordinates the monitoring of these relations, in particular the Autorite de Controle Prudentiel et de Resolution (ACPR) and the European Central bank (ECB);
- consolidating and monitoring significant compliance events in the entities
Summary of the key purposes of the role
The main Chief Operating Office (COO) functions in CPLE/LDN are concentrated in a central COO team within UK Central Compliance. Some COO activities, generally those with a more specialised focus, are also undertaken within other UK Wholesale Banking Compliance (CPLE/LDN) teams. There is strong operational alignment between the Central COO team and those undertaking COO activities within the specialised teams.
The COO functions as a whole ensure the effective operational functioning of the UK Compliance department across a wide variety of topics (including governance, budgets and financial control, operational and conduct risk (OCR) management, permanent supervision and control frameworks, management information (MI) and reporting, facilities, access profiles and other technology support. This requires regular interaction with Compliance Management, UK and Paris-based Compliance staff and other internal stakeholders.
The UK Wholesale Banking GLBA Advisory Compliance COO (CPLE/LDN GLBA COO) sits within the CPLE/LDN GLBA Advisory Compliance team. They provide dedicated COO support on Global Banking and Finance (GLBA)-specific issues and topics within the remit of the CPLE/LDN GLBA Advisory Compliance team as well as working alongside the Central COO team on more transversal topics.
Summary of responsibilities
The detailed tasks are as follows:
- Transversal: Ensure that a high standard of governance applies in CPLE/LDN, supporting CPLE/LDN management in their understanding of the risks and the effectiveness of the Compliance oversight. This includes:
- Organisation of the governance over services provided by CPLE/LDN to other internal stakeholders/entities, ensuring that meetings are organised, held and minuted, reporting is complete, etc.
- Organising and participating in meetings with the other COOs within Compliance to keep abreast of business initiatives and central compliance initiatives
- Follow up on monthly and other regular/ad hoc updates for Compliance Risk Items (i.e. Compliance incidents, audit recommendations, permanent supervision and other controls, etc.)
- Supporting the development and maintenance of the Annual Compliance Plan
- Assisting with operational support to other CPLE/LDN teams on GDPR and related personal data protection topics (including creation and maintenance of Data Processing Records, Privacy Impact Assessments, Legitimate Interest Assessments, the CPLE contract inventory and data protection permanent supervision controls)
- Providing support on other transversal matters within CPLE/LDN as appropriate
- UK GLBA Advisory Compliance-specific: Ensure that a high standard of governance applies within the CPLE/LDN GLBA Advisory Compliance Team, supporting GLBA Advisory Compliance Team management in their understanding of the risks and the effectiveness of their oversight. This includes:
- Organisation of the governance over services provided by the CPLE/LDN GLBA Advisory Compliance Team to GLBA, ensuring that meetings are organised, held and minuted, reporting is complete, etc
- Follow up with the GLBA Compliance Advisors on action items logged against team members to ensure timely completion of actions and on the Training Plan
- Produce MI for GLBA UK OCR Dashboards in coordination with the relevant Paris Compliance stakeholders
- Produce MI to assist CPLE/LDN GLBA Advisory Compliance Team management to demonstrate proper management of GLBA risks e.g. to support monthly SMR meetings within CPLE/LDN
- Assist CPLE/LDN GLBA Advisory Compliance Team management in development of team plan
- Other management information and reporting tasks as required
Operational Risk Management:
- Transversal: Assist the Central COO Team in:
- Permanent Supervision: ensuring the smooth functioning of the SG permanent supervision applications and provide support to Compliance users, liaise with application business owner / IT to resolve issues, performing reviews of Compliance permanent supervision controls (in particular those undertaken by the CPLE/LDN GLBA Advisory Compliance Team) as scheduled. Escalating and / or providing status reports to management on an as needed basis, working with Compliance stakeholders to assess and revise permanent supervision controls, on at least an annual basis
- Other Permanent Control Transformation and other operational risk management projects as required.
- UK GLBA Advisory Compliance-specific: Liaise with CPLE/LDN SMCR Compliance & Advisory Team regarding queries related to certified persons within GLBA
Communications and Facilities:
- Transversal: Assist the Central COO Team in:
- Providing general support to users (who have responsibility for maintaining their own pages) of the UK Compliance SharePoint site
- Supporting the Compliance team and control the access to technology systems used by Compliance, including liaising with IT on setting up new joiners’ profiles and access rights
- Reviewing and challenging inappropriate system access profiles.
- Liaising with Bangalore experts to resolve POPS issues.
- According to Compliance policy, validating and facilitating requests from other parties, such as security passes, equipment changes, etc.
- UK GLBA Advisory Compliance-specific: Keep the CPLE/LDN GLBA Advisory Compliance Team information in UK Compliance SharePoint site up to date
Budgets and Financial Control:
- Transversal: Assist the Central COO Team in facilitating the Compliance budget and reforecasts for the UK, including headcount, consulting, travel, etc.:
- Ensure that the cost centre framework is fit for current purpose and work with UK Finance to make required adjustments.
- Working with relevant UK and Paris stakeholders, collect and document the annual budget for headcount, consulting, IT budgets, travel, training, and any other discretionary costs
- UK GLBA Advisory Compliance-specific: Support CPLE/LDN GLBA Advisory Compliance Team Management in tracking travel and training budget consumption within the team
Other tasks and activities as requested by management
Level of Autonomy and Authority
The post holder is responsible for the coordination and delivery of the defined activities, which requires enough autonomy to make the right decisions to achieve timely delivery and to ensure coordination of the effort of various teams and other stakeholders in order to do so. UK GLBA Advisory Compliance Team-specific activity is undertaken within a compliance advisory framework determined by the UK Head of Wholesale Banking GLBA Advisory Compliance
This level of autonomy is correlated with the capacity to report to management about risks, issues encountered and proposed solutions. Significant decision making related to issues and risks is reserved to the relevant Compliance management team/body (within UK GLBA Advisory Compliance Team and/or CPLE/LDN more broadly).