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Corporate Governance

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Corporate Governance

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Our Approach to Ethics & Risk Governance

Bank of Sydney (BOS) is an Authorised Deposit Taking Institution (ADI) supervised by the Australian Prudential Regulation Authority (APRA) under the Banking Act 1959. BOS is also supervised by the Australian Securities & Investments Commission (ASIC), Australian Transaction & Reports and Analysis Centre (AUSTRAC) and other government agencies.

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At BOS we recognise that we have responsibilities to all of our stakeholders, including, but not limited to:

  • Customers
  • Employees
  • Government/Regulators
  • Shareholders
  • Communities in which we operate
  • Suppliers & Contractors
  • The Environment

Accordingly, BOS is committed to the highest standards of corporate governance and we continually review our governance practices. This ensures full compliance with legal requirements and ensures our business model is aligned to the constant change that occurs within the external environment of which we operate. BOS's approach to corporate governance aims to achieve superior customer satisfaction through the execution of our core values of:

  • Courage
  • Ownership
  • Passion
  • Respect
  • Urgency

Our Board of Directors and staff are responsible for upholding the goals and values to which BOS aspires.

BOS corporate & risk governance structures have been developed to support BOS customer- focused operations while providing clear guidance on how authority is exercised at the Bank, including Board oversight of key controls. The Board, with the assistance of delegated Board Sub-Committees of Risk, Remuneration & Audit determine the most appropriate corporate governance practices.

BOS Board delegations and committee charters are regularly reviewed.

  Risk Management

BOS’s risk management philosophy principles focus on embedding a standardised “Three Lines of Defence” philosophy. Key aspects to the Three Lines of Defence philosophy include:

Ownership of risk at the business level
Business heads are responsible for identifying risks within their business units and ensuring that they are managed appropriately.

Understanding worst case outcomes
BOS’s risk management approach is focused on understanding the consequences of worst case scenarios which may impact on BOS and determine whether they can be tolerated.  This is achieved by undertaking periodic stress testing of certain risk systems and Management being aware of emerging risks which could influence BOS’s risk profile.

Risk management independence
BOS places significant importance on having a strong independent Risk & Compliance function. The Chief Risk Officer has unfettered access to the Board and subcommittees and reports directly to the Chief Executive Officer. 

Focus on customers and long term strategy
Effective risk management is more than just a robust framework with controls. BOS's risk culture, which is less tangible, is equally important and all staff respect the need to adhere to the Banks values. BOS businesses are customer focused, placing significant emphasis on building premium customer orientated, sustainable relationships as opposed to short term focus purely on profitability.

  Compliance

BOS is committed to achieving regulatory compliance excellence within the external environment of which it operates. Robust compliance can only occur if sound compliance and risk management practices are embedded in responsibilities and performance across the organisation.

BOS “does things right” via the prudent development, approval and execution of various policies and procedures required by law.   The Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) (AML/CTF Act) is a principal piece of legislation BOS complies with.

All BOS employees are provided induction training and regular refresher training to ensure compliance with BOS policies and procedures. Examples of such training include:

  • Anti-Money Laundering and Counter Terrorism Financing
  • Privacy & Confidentiality
  • Code of Conduct
  • Conflict of Interest Policy
  • Whistleblower Policy
  Key AML/CTF review

Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) Overview

Money laundering is the concealment of money which was made by carrying out illegal activities.  Terrorism financing involves the use of money raised from legitimate sources, such as donations and business profits as well as money from illegal sources to fund terrorism.  

The Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) (AML / CTF Act) imposes a number of obligations on ‘Reporting Entities’ (people who provide ‘Designated Services’) in order to identify money-laundering and terrorism-financing and to regularly report to ‘AUSTRAC’(the Australian Transaction Reports and Analysis Centre) which is Australia’s anti-money laundering and counter-terrorism financing regulator.

Bank of Sydney, ACN 093 488629 (BOS) is a Reporting Entity under the AML / CTF Act as it provides a number of Designated Services.

As a Reporting Entity, BOS complies with the AML/CTF Act and has an AML / CTF Program in place. BOS complies with its Program which is also supported by other policies and procedures to meet its obligations and to protect BOS against money laundering and terrorism financing risks likely to impact BOS.

General obligations covered in the BOS AML/CTF Program include:

  • Board approval and oversight;
  • Appointment of an AML / CTF Compliance Officer;
  • Independent review;
  • Risk identification, management and mitigation;
  • AUSTRAC Feedback;
  • Reporting obligations – including the identification and reporting to AUSTRAC of:

    Cash transactions of AUD $10,000 and above;
    Suspicious matters; and
    Details of IMT’s (wire transfers) regardless of the amounts.
 

  • Procedure for the collection and verification of ‘Know your Customer’  (KYC) customer identification details;
  • Ongoing customer due diligence;
  • Employee and contractors due diligence; 
  • AML / CTF risk awareness training program for employees; and
  • Record keeping.
  Sanctions

Sanctions impose restrictions on activities that relate to particular countries, goods and services, or persons and entities aimed at limiting the adverse consequences of the situation of international concern, seeking to influence those responsible for giving rise to the situation of international concern and/or to penalise those responsible.

Sanctions generally refer to ‘measures used by governments or international organisations including a complete or partial interruption of economic relations however not involving the use of armed force’. These measures are mainly put into place in situations of international concern, including ‘the grave repression of the human rights or democratic freedoms of a population by a government, or the proliferation of weapons of mass destruction or their means of delivery, or internal or international armed conflict.’ 

BOS complies with applicable sanctions regulations and has systems and processes in place in relation to customers, trade transactions and international money transfers to ensure it is not dealing with any prescribed persons or prohibited jurisdictions or with any previously identified undesirables.

  FATCA 

The United States Government introduced the Foreign Tax Compliance Act (FATCA) which came into effect on 01/07/2014. FATCA aims to prevent tax evasion by US tax residents who hold foreign accounts by requiring financial institutions to report details and interest income to the US Internal Revenue Service (IRS). 


Australia has signed an Intergovernmental Agreement (IGA) with the US. This agreement sets out rules to enable Australian financial institutions, including BOS, to be reporting to the Australian Taxation Office (ATO) who in turn will pass the information to the IRS. FATCA affects US citizens, US tax residents and certain types of organisations that are controlled by US citizens or US tax residents. To comply with FATCA, BOS asks customers to declare their US tax status. Information collected and disclosed is treated in accordance with the BOS Privacy Policy


  Code of Banking Practice
In line with Bank of Sydney's policy to further improve the products and services offered to its customers, the Bank has adopted the Australian Bankers Association’s voluntary Code of Banking Practice to reinforce the Bank’s duty towards delivering the systems and processes required to meet Best Practice standards set out by the Code.
 
Being a member of the Australian Banker’s Association, Bank of Sydney aims at reaching the highest banking practice standards, ensuring that customers receive all the relevant information they require when making their financial decisions for their personal or business needs. 
 
Features of the code include:
  • Continuously working towards improving the standards of practice and service in the banking industry,
  • Promoting informed decisions about our banking services,
  • Providing general information in plain English about the rights and obligations that arise out of the banker and customer relationship in regards to banking services, and
  • Monitoring external developments relating to banking codes of practice, legislative changes and related issues
Copies of the Code of Banking Practice are available to download here, by post or at any of our branches across Australia.
 
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