Regulatory Requirements for Greek Credit Institutions

Corporate Governance

The Hellenic Corporate Governance Code is a voluntary code that facilitates the formulation of corporate governance policies and practices for listed companies. Credit institutions must adopt a Code of Ethical Conduct based on generally accepted principles such as:

• Diligence: Acting with care and attention to detail
• Efficiency: Using resources effectively and efficiently
• Responsibility: Taking ownership and accountability for actions
• Professional Secrecy: Maintaining confidentiality and respecting client relationships

Registration and Oversight of Senior Management

The Board of Directors (BoD) members and senior managers are proposed by the nomination committee to ensure suitability criteria including:

• Honesty: Acting with integrity and transparency
• Integrity: Maintaining a strong moral compass and ethical behavior
• Independence of Mind: Making decisions based on objective reasoning
• Diversity: Bringing unique perspectives and experiences to the organization

A “fit and proper” assessment is conducted by the BoG/ECB for BoD members and senior managers to assess their repute, knowledge, skills, experience, and ability to act with honesty and integrity. The overall composition of the BoD must reflect an adequately broad range of experience.

Remuneration Requirements

Credit institutions should apply remuneration policies for staff whose professional activities have a material impact on their risk profile, in line with CRD IV (as amended) and Law 4261. The policy should:

• Promote sound and effective risk management: Encourage responsible decision-making and prudent risk-taking
• Be gender neutral: Ensure fairness and equality in remuneration practices
• Set out the ratio between fixed and variable remuneration: Establish a clear balance between guaranteed income and performance-based rewards

AML/KYC

Greek credit institutions are subject to the AML/CFT legislation that implements EU Directives and Decision on money laundering and terrorist financing prevention. They must adopt an AML policy and procedures including:

• Model risk management practices: Identify, assess, and mitigate potential risks
• Customer due diligence: Verify customer identity and conduct ongoing monitoring
• Reporting: File suspicious activity reports and comply with regulatory requirements
• Employee screening: Conduct thorough background checks on employees
• Record-keeping: Maintain accurate and up-to-date records
• Internal control: Establish effective internal controls to prevent money laundering
• Compliance management: Ensure ongoing compliance with AML/CFT regulations

By following these regulatory requirements, Greek credit institutions can maintain a strong reputation, ensure the integrity of their operations, and protect themselves against potential risks.