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Compliance Policy Document

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Purpose and Scope

The purpose of this compliance policy document is to ensure that Payvand Bank JSC complies with all relevant laws, regulations, and internal policies. The scope includes the bank’s activities, business processes, operations, and employees.

Key Objectives

  • Ensure compliance with all applicable laws, regulations, and internal policies
  • Identify, assess, and control compliance risk through various means
  • Develop and manage compliance risk management organization
  • Establish distribution of power for compliance risk management
  • Implement internal control and compliance reporting mechanisms
  • Interact with external authorities in accordance with legislation

Compliance Risk Management

The bank identifies, assesses, and controls compliance risk through the following means:

Methods of Compliance Risk Management

  • Development of internal documents (instructions, service orders) for employees regarding compliance risk management
  • Monitoring compliance with policy and procedure by employees
  • Collection and maintenance of an event compliance database
  • Analysis of complaints and statements from clients to identify compliance issues
  • Preparation and analysis of quantitative and qualitative indicators reflecting the level of compliance risk impact

Compliance Risk Management Organization

The Compliance Risk Service is responsible for developing and managing compliance risk, as well as coordinating the bank’s activities in compliance risk management.

Roles and Responsibilities

  • The Supervisory Board is responsible for supervising compliance risk management.
  • The Director and Deputy Director are responsible for ensuring compliance risk management.
  • All structural subdivisions (including heads and employees) are responsible for complying with this policy and relevant laws, regulations, and internal documents.

Internal Control and Compliance Reporting

Structural subdivisions must comply with relevant laws, regulations, and internal documents. They must also report violations to the Compliance Service, which will develop an internal document outlining reporting procedures.

Key Requirements

  • Structural subdivisions must comply with relevant laws, regulations, and internal documents.
  • Structural subdivisions must report violations to the Compliance Service.
  • The Compliance Service will develop an internal document outlining reporting procedures.

External Relations

The bank will interact with government bodies, state authorities, and regulatory agencies in accordance with the legislation of the Republic of Tajikistan.

Key Principles

  • Interact with external authorities in accordance with legislation
  • Ensure compliance with all applicable laws, regulations, and internal policies

Responsibility

Employees (including officials) are liable for non-compliance or improper implementation of this policy in accordance with the legislation of the Republic of Tajikistan, employment contracts, and internal regulations.

Key Consequences

  • Employees will be held accountable for non-compliance or improper implementation of this policy.
  • Employment contracts and internal regulations will govern liability for non-compliance.