The purpose of the Compliance Department and Compliance Policy
Compliance Department (or ‘Compliance’) of Veles International Limited (‘VIL’) is established to lead and coordinate the actions on identifying, assessing, advising on, monitoring and mitigating specific compliance risks, as well as reporting on these issues internally to the Board of Directors (the ‘Board’), and externally to the regulators.
Compliance activities aim to assure the commitments of VIL’s Board and senior management to always act ethically, diligently and in compliance with the current legislation, regulatory guidance and best practice. Under the Cypriot and international laws ultimate responsibility for compliance rests with the Board. It is VIL’s directors who are ultimately responsible for compliance issues and compliance culture with the Compliance Officer (Head of Compliance) being the Board’s agent aiding directors with their responsibilities, so delegated, and implementing the compliance policy on a day-to-day basis. This Compliance Policy, as adopted by the Board, must be observed by all VIL’s employees who are responsible to the Chief Executive Officer for actually doing compliance (being compliant) under the Compliance Department’s supervision and guidance.
Compliance Department is basing its activities on the relevant provisions of the Law L 87(Ι)/2017, EU Commission Delegated Regulation (EU) 2017/565 and other relevant legislation. Additionally, the relevant CySEC and ESMA Guidelines and, where applicable, those of International Organisations, are taken into account.
Compliance Department’s main objective are to ensure that
The Compliance Risk
The compliance risk is the risk of legal or regulatory sanctions, material financial loss, or loss to reputation VIL may suffer as a result of its failure to comply with laws, regulations and rules applicable to its activities, as well as VIL’s internal policies and procedures. Compliance risk includes the risk for VIL to be involved in money-laundering (‘ML’) or terrorist financing (‘TF’) activities, as well as in corruption and market abuse.
The Compliance Department’s work program has been developed on the basis of the compliance risk assessment. The identified risks are being reviewed on a regular and an ad-hoc basis to ensure that all emerging risks are taken into consideration.
Compliance culture is an integral part of VIL’s overall corporate culture and is supportive of the aims of Compliance. It is a combination of VIL’s values, ethics, principles, behaviors, practices and structures (including information flows, reporting lines) ultimately aimed at
VIL’s compliance culture is particularly focused on ethics because prescriptive rules haven’t always delivered the outcomes they want, and cannot cover every eventuality. Ethics is capable of offering core principles and reflect the fundamental interests of clients as specifically stressed above. It is the Compliance Department who should be addressed by VIL’s management and employees in every case they have any doubt or uncertainty whether there is a chance for them to behave unethically.
Responsibilities and Activities of the Compliance Department
The Compliance Department covers by its oversight and monitoring all VIL’s activities associated with, but not limited to, all investment and ancillary services which VIL is authorized to conduct. Particular monitoring activities take into account the compliance risk the respective business areas are exposed to.
When regulatory requirements prescribe VIL to implement a rule or a policy on a group level (in full or in part) Compliance will oversee implementation of and compliance with this rule or policy in the respective group entities with the full assistance of their compliance officers and senior managers. In this process, Compliance will have the right to check any related arrangement, have access to any related group premises and request any relevant document and information, with prior notification to the relevant senior manager.
Compliance Officer (Head of Compliance)
The Compliance Department is led by the Compliance Officer (Head of Compliance).
The Compliance Officer has sound level of knowledge and relevant experience and a sufficiently high level of expertise so as to be able to assume responsibility for Compliance as a whole and ensure that it is effective. The Compliance Officer should also be familiar with VIL’s business, strategies and plans.
The Compliance Officer (Head of Compliance) is appointed and replaced by the Board, is accountable to the Board and acts independently from senior management and other units when performing his/her tasks. The Compliance Officer (Head of Compliance) is adequately compensated with the respective remuneration being determined in a way that does not and is not likely to compromise his/her objectivity.
Compliance Department’s Powers
VIL’s Compliance Department, represented by the Compliance Officer or any other person duly appointed by him/her), will have the right and power to
The Compliance Department’s activities is supervised by the Board and annually reviewed by the Internal Audit with the respective report provided to the Board.
Any employee who has concerns as to the Compliance Departments’ actions can address their complaints and concerns to the Board through the Chief Executive Officer.
Compliance Policy and Compliance Department. Head of Compliance
Igor Zatseda, LL.M, FICA