Guaranteeing transparent ethics and governance

The Compliance Department
BNP Paribas Real Estate is committed to conducting its activities in compliance with laws and regulations, and in accordance with the highest standards of ethics. As a major player in the real estate sector, our International Executive Board has made integrity and reputation a priority. This allows us to maintain our reputation for honesty, quality and integrity at a high level. Complying with the laws, regulations and professional standards specific to their activity is an essential requirement for all BNP Paribas Real Estate employees.

Performance

Employees who have completed the annual compliance and ethics training courses

2020

93 %

2019

90 %

2018

92 %

2017

90 %

2016

89 %

Significant incidents resulting in a major corrective action plan

2020

11,6 %

2019

5,8 %

2018

10,0 %

2017

10,7 %

2016

5,8 %
Our International Executive Board has made integrity and reputation a priority.
We strive to inspire the trust of our customers. To do this, we regularly train and support our employees so that they understand our compliance policies and act in the best interests of our clients.

Fabrice BLIN

Chief Compliance Officer

Our compliance and ethics commitments

As a member of the BNP Paribas Group, we believe that the success of BNP Paribas Real Estate depends directly on the behaviour of each employee. The BNP Paribas Group Code of Conduct aims to provide employees with a framework for making decisions and actions based on professional expertise, integrity and a deep sense of ethical responsibility. Although there can never be strict rules that apply to all situations, our Code of Conduct is given to each employee upon arrival and is intended to be used with personal judgement to ensure that the spirit of the Code is always respected.
The BNP Paribas Group’s Code of Conduct defines:
  • Our mission and values: what we represent and the key principles that guide our actions and decisions
  • Rules of conduct: specific rules shared and implemented by all employees, in accordance with our values and ethical standards
  • Code of Conduct in Practice: clear guidelines and expectations for employees on how to apply the Code.
Through this code, BNP Paribas Real Estate defends its values of expertise, proximity, responsibility and innovation development.

Compliance and ethics procedures

Financial security

Our compliance procedures to ensure financial security are extremely important to our operations and aim to protect against money laundering, prevent corruption and terrorist financing, and comply with ever-changing financial requirements, including international financial sanctions and embargoes.
These procedures are described in the BNP Paribas Group Code of Conduct and are based on:
  • our ethical values and principles of exemplary conduct
  • the laws in the countries in which we operate
  • European regulations
  • recommendations from international organisations

The Ethical Alert Right

BNP Paribas Real Estate has set up an ethical alert right procedure for all employees when they are wondering about possible shortcomings within the company. Each employee, in any business activity they carry out or of which they are aware, must ask themselves the question of compliance with ethical principles. If they have any doubts, they refer them to their hierarchy. If the employee does not wish to do so, they can then place themselves within the framework of the ethical alert right system and contact the compliance officer of their entity. Anonymity is guaranteed and protection against any retaliation measures is ensured.

The Risk Department

Against a backdrop of increasingly complex regulatory requirements and tighter controls, the BNP Paribas Group has centralised risk. In November 2015, the Risk Department of BNP Paribas Real Estate, “RISK RE”, was created and covers the 6 business lines and the 13 countries where the company operates. Totally independent from the business lines, it is organised around four dedicated teams:
  • Real Estate Development (office and residential real estate in France and abroad): to support the development of the business within the fiscal, regulatory and legislative framework in force, in line with the Group’s risk policy and in compliance with financial performance criteria.
  • Investment Management: to support the development of the business when launching new investment funds, when selecting and allocating assets, and to analyse the risks for the various real estate funds under management in connection with local
  • AIFM risk managers. Operational Risk covering the 6 business lines: to analyse and challenge the effectiveness and quality of the control system mainly through supervision missions and to provide independent reports and alerts on critical issues of concern.
  • Data Protection: to monitor compliance with the GDPR in regard to the regulations in force and the rules defined by the BNP Paribas Group, to inform and advise the teams that process data on their obligations, to provide advice on request concerning the impact assessment relating to data protection and verifying its execution, acting as a contact point for the supervisory authority in France on questions relating to processing.
RISK aims to be a partner of our business lines by contributing to their sustainable development, but also a gatekeeper to ensure the compatibility between the risks taken and the risk appetite of the Group and its strategy.

Murielle Baiges

Chief Risk Officer

Risk RE is the Group’s second line of defense for the relevant risk management activities of its direct responsibility: financial risks, market risks, operational risks, risks linked to data protection.
As such, RISK RE is integrated into the governance of BNP Paribas Real Estate and is a member of the business decision-making committees. The Risk Director is a member of the International Executive Committee, the Central Functions Committee and the Internal Control Committee.
Risk monitoring (anticipation, evaluation, alerts, monitoring of action plans targeted by the business lines) is ensured through the production of quarterly and annual reviews intended for managers of BNP Paribas Real Estate and BNP Paribas group.