Managing legal, regulatory, and ethical risks
Complying with all regulations, preventing fraud, combating money laundering and terrorist financing, providing long-term quality service to our customers, ensuring the continuity of essential activities… these actions go far beyond the sole issue of “reputational risk.”
Professional ethics
Professional ethics are an integral part of our compliance framework, whose main principles are defined by Oney and then adapted by each entity of the Group according to its specific features. Compliance with rules of conduct by employees enables each entity to carry out its activities in an honest, fair and professional manner and to best serve the interests of its customers.
Our Group has developed a Code of Conduct and Ethics to ensure customer interest, employer responsibility and corporate social responsibility.
We have implemented a system for monitoring and controlling confidential and insider information. Respect for banking secrecy and professional confidentiality is a principle with no exceptions.
Confidential (non-public) information concerning a client or a company is subject to specific monitoring. Dedicated procedures for monitoring and controlling insider information have been put in place. Continuous training and awareness of employees regarding compliance with ethical rules in the exercise of their duties are essential.
For several years, the Group has implemented training programs to ensure that the presentation, advisory and sale of financial services and insurance products are carried out by employees with the appropriate professional knowledge
Managing conflicts of interest
The Oney Group is committed to serving the interests of its customers and acting with full transparency.
A conflict of interest that is not or poorly managed could harm the Group’s image as well as individual interests. Therefore, the Oney Group implements a policy for the prevention and management of conflicts of interest.
Whistleblowing
Our ambition is to promote ethics at all times in employees’ decisions and behavior by providing clear guidelines known to all. The duties we have towards our customers and shareholders must also be applied internally among ourselves. Each employee contributes to the image of the company and must uphold it.
It is essential to maintain the trust of our customers, shareholders, partners, employees and society as a whole. However, we are aware that misconduct may occur. Employees may report potential breaches through internal whistleblowing procedures implemented within each entity, before they become major risks. The Group protects whistleblowers: they cannot be subject to disciplinary sanctions or legal proceedings, provided they act in good faith and without personal gain
To report a serious breach of the Code of Conduct, legal or safety requirements, environmental impacts, or any inappropriate workplace behaviour, please access our dedicated whistleblowing platform.
Fighting corruption and influence peddling
We are committed to combating all forms of corruption, including influence peddling and facilitation payments. This commitment is reflected in the adoption of anti-corruption rules aligned with the French law of 9 December 2016 (known as the “Sapin II” law), aimed at transparency and the fight against corruption.
These rules apply to all employees, who must exercise vigilance in identified risk situations. Any breach may lead to disciplinary sanctions. Prevention is also supported by mandatory training modules (e-learning), including practical case studies.
Customer protection
Supervision of commercial practices
Customer protection is at the heart of Oney’s activities. Through its Compliance function, the Group defines rules that comply with applicable regulations and with regulatory developments. These rules cover product approval, commercial processes (direct sales, online sales, telephone sales, etc.) and advertising.
Employees play a key role in protecting customers. They must present offers clearly, accurately and transparently, in order to build a relationship of trust with customers. Customer protection must be ensured at every stage of the customer relationship: pre-contractual information, advice, performance of the contract and termination of the contract.
The Group issues recommendations to ensure that each entity implements a clear and transparent complaints-handling procedure. Complaints are monitored and analysed on a regular basis using quality indicators (including processing times, among others), with a view to continuously improving products and services.
Oney also has an independent mediator whose contact details are clearly communicated to customers.
Protection of personal data
Protecting personal data and granting new rights in the digital age is the objective of the General Data Protection Regulation (GDPR). This European regulation is based on transparency and accountability and applies to any company processing the data of European Union residents, regardless of where the company is located.
Oney ensures that the processing of personal data complies with the GDPR and applicable French data protection regulations. Particular attention is paid to the responsible use of personal data. Employees are regularly trained and made aware of GDPR requirements, as well as of the “Privacy by Design” principle.
Information notices provide clear and detailed explanations to customers on how Oney protects their personal data across its different processes, including security, compliance, audit, marketing, communication, finance and risk.
In addition, all entities of the Oney Group provide their customers and employees with an information notice on the protection of personal data.
Financial security
We are committed to preventing financial crime, which includes combating money laundering and terrorist financing, but also complying with sanctions imposed against certain countries, persons or entities by France, the European Union, the United States or the United Nations, as well as any other applicable regulation, taking into account the geographical locations in which the Group operates.
All our companies ensure compliance with the principles and rules laid down by the applicable legislation, in accordance with the standards defined in particular by the Financial Action Task Force (FATF)¹, the United Nations or the European institutions².
The overarching principles and framework arrangements are defined by Oney and are implemented across all its entities. Operational teams are regularly made aware of financial security issues, whether these concern new forms of financial crime or legislative and regulatory developments in this area. Dedicated training materials are used by all employees of Oney Group.
The prevention of money laundering and the financing of terrorist activities is based on the principle of customer knowledge, supplemented by ongoing vigilance exercised with regard to financial activities, involving branch networks as well as Group employees directly assigned to managing these issues.
- 1. The FATF leads global action to combat money laundering and the financing of terrorism and proliferation.
- 2. Directives and regulations issued by the European Commission or the Council of the European Union.
Business continuity
Like any company, Oney Group companies may face events or major incidents that could significantly disrupt their organisation and, consequently, the quality of the services they provide.
In such circumstances, the teams responsible for business continuity identify and validate the alternative solutions to be implemented in order to:
- reduce exposure to certain events or incidents;
- manage crisis situations and limit the impact of incidents;
- ensure that the essential activities of Oney Group companies can be resumed as quickly as possible;
- maintain a minimum level of service by any available means;
- restore normal operations as quickly as possible.
All the Group’s financial institutions, together with the entities contributing to the delivery of financial activities, have developed a business continuity framework that can be activated, particularly in the event of a major incident.
All employees are involved to varying degrees and may be required to take part in implementing business continuity solutions. These solutions are based on previously identified incident scenarios. Their effectiveness is ensured through a policy of recurring tests involving Group employees, regular controls, and periodic reviews of business continuity needs, available resources, and the associated procedures.