Description of the Business Line or Department
Societe Generale International Limited is a wholly owned subsidiary of Societe Generale (SG) and is a global leader in the execution and clearing of exchange traded derivatives (ETD) primarily on behalf of institutional clients. SGIL also provides over the counter (OTC) products and prime brokerage services. SGIL owns several exchange licenses and Clearing Houses Licenses across the UK and Europe.
SGIL’s business and associated processes are fully integrated within the SG framework and in certain circumstances services are outsourced to either the Societe Generale London Branch (SGLB) or to the SG Paris Headquarters. However, as a separately regulated legal entity in the UK it is required to meet its own obligations to the UK regulator. SGIL is a solo regulated firm and is regulated by the Financial Conduct Authority in the UK.
Compliance for SGIL consists of two distinct functions. One is the Compliance Advisory team which works directly with the business line(s). The second is Central Compliance which performs Compliance tasks transversal to the legal entity, acts in an oversight and control capacity, in particular as it is in charge of overseeing the performance of the Service Level Agreement signed for the Compliance function with SG London Branch, and coordinates with the Compliance Advisory teams and the various Compliance functions within SG.
This role is in the SGIL Central Compliance function, supporting the various activities under its remit, which include (but are not limited to) developing and updating the firm’s Compliance manual, following the completion of the Compliance programme, filing regulatory and exchange reports, participating in governance meetings, ensuring timely and complete staff regulatory and exchange registrations, assisting with the collation of documentation for audit and regulatory enquiries, appropriately challenging the Compliance service providers, working to create alignment with SG processes, policies, and procedures when feasible and preparing unique process documentation when it is not.
The Compliance Function for SGIL is part of the Group Compliance Service Unit and is responsible for the definition and consistency of the compliance risk prevention and control system, and for coordinating the framework aimed at preventing, identifying, assessing and controlling reputational risk across the entire Group.
In conjunction with the Business Units and other Service Units (BU/SUs), Compliance performs the following tasks with respect to compliance risk:
defining and implementing the overall normative framework of the Compliance service and monitors its implementation;
defining procedures and implementing a framework to ensure compliance with respect to compliance risks;
awareness-raising among Group employees regarding compliance risk and the strengthening of the compliance culture within the Group;
mapping and analysing Group compliance risk and general vigilance regarding issues likely to harm the Group's reputation or that of one of its activities;
performing the second-level control and supervision of the framework, including independently assessing compliance risk management within the entities/activities with a major impact on the Group's risk profile, and individually with respect to regulated employees, in compliance with the applicable regulations;
monitoring relations with supervisory and regulatory authorities, and representing the Societe Generale Group to these authorities, not including supervisory and regulatory authorities where the Legal function (SEGL/JUR) organises and coordinates the monitoring of these relations, in particular the Autorite de Controle Prudentiel et de Resolution (ACPR) and the European Central bank (ECB);
consolidating and monitoring significant compliance events in the entities.
Summary of the key purposes of the role
Assist with tasks specifically under the remit of the SGIL Central Compliance Team covering the following areas (non exhaustive):
Maintenance of all SGIL specific or SGIL impacted normative documentation, including manuals, policies and process documentation;
With Compliance Advisory ensure completion of the annual Compliance Risk Assessment with robust check and challenge of all responses provided by the business and provide the SMF16 with a detailed synthesis of all risk ratings and action plans;
Coordination of all SGIL management information required for reporting across the various SGIL governance committees including the Risk and Control Committee and Board Risk and Audit Committee. Providing full interrogation of information provided and proactively challenging and checking such information with stakeholders;
Filing of all regulatory returns and other documentation with the FCA whether as part of BAU or on an ad hoc basis;
Coordination and participation of all Service Level Meetings with SGLB stakeholders, minute taking in meetings, management of information from those meetings and ensuring flow of information into the Service Management Committee which oversees all outsourced service providers within SGIL;
Oversight of all licencing requirements for SGIL across Exchanges and clearing houses (CCP’s) whether in the UK or Europe including staying abreast of relevant permissions from each exchange and providing advice to the business as to relevant requirements.
Coordination and ownership of all Questionnaires for SGIL emanating from Regulators, Exchanges or CCP’s while obtaining input from various business units and service units within SG.
Summary of responsibilities
Assist the SGIL Central Compliance Team on all core Compliance responsibilities to support the SMF 16 in managing regulatory risk within SGIL:
Assist in the production of regulatory and exchange filings – SGIL Central Compliance is responsible for maintenance of exchange and clearing house licenses and coordination of response to the exchanges or CCP’s related to these memberships (including annual questionnaires; approval of new accesses; maintenance of authorised persons);
reviewing of all SGIL policies and updating them as necessary, or in reviewing policies written by SG London Branch to make sure that the subsidiary specificities are appropriately covered. Maintaining the SGIL Compliance manual on an on-going basis.
Oversee completion and maintenance of compliance issues and breach logs for reporting to the FCA and SGIL Governance Committees (CASS, transaction reporting, customer complaints, Regulators and exchanges enquiries and responses,) and ensuring that all incidents and breaches are timeously inputted into the relevant Compliance Tools;
In coordination with other SG locations, ensure that staff registrations for regulatory purposes, as well as market access are accurate, complete, and processed on a timely basis;
Ensure that all internal audit findings and work on the implementation of open Compliance audit recommendations to completion with appropriate escalation to relevant governance committees;
Ensure that all Corrective Action plans from CTL Reviews done on the SGIL entity are analysed and tracked to completion with escalation to the SMF16 as required;
Represent SGIL Central Compliance in relevant projects impacting the entity;
Ensuring all relevant system accesses whether internal or external are in place for the SGIL Central Compliance Team;
Completion of all relevant controls that are required to be undertaken by the SGIL Central Team;