Compliance, a fundamental pillar of Sfil's trust and responsibility

As a public development bank, Sfil is fully aware of the threats and risks that corruption poses to its ability to carry out its missions, to its reputation and, consequently, to the confidence of its investors. As such, Sfil attaches the utmost importance to the fight against corruption both within the Bank itself and in the projects it refinances.

Sfil has zero tolerance for corruption. Under no circumstances can the belief that one is acting in the interest of Sfil justify, even in part, behavior that contradicts the provisions of applicable laws and its Code of Ethics and Professional Conduct.

In 2019, as part of its CSR approach and Sfil’s accession to the United Nations Global Compact in 2018, the Code was supplemented by a code of conduct on anti-corruption in line with the 10th principle of the Compact, which states: “Companies are asked to act against corruption in all its forms, including extortion and bribery”.

Sfil has adopted a system for the prevention of corruption, which aims in particular to ensure that:

• the risks of corruption have been correctly identified and analyzed
• these risks are duly governed by appropriate rules and procedures
• managers and employees exposed to these risks have been made aware of and trained in the commitments made by Sfil in the fight against corruption so that they implement the bank’s corruption prevention program in their missions.

The main rules of this corruption prevention mechanism are set out in the “Anti-Corruption Code of Conduct”.

Gifts and invitations

Sfil also strictly supervises the receipt and granting of gifts or invitations by employees, to guard against any attempt at corruption, but also to guarantee the independence and impartiality of all its employees. To this end, and as part of its duty of transparency, Sfil has a procedure in place for gifts and invitations. It complements the code of ethics and professional conduct and, in particular, the code of conduct on anti-corruption. All employees must refuse any gift or invitation from a third party that could compromise their independence of judgment or that could suggest, outside Sfil, that they could be influenced.

The following are specifically prohibited:

• the granting or receipt of a sum of money, or anything else of value, with the aim of obtaining an advantage or influencing a decision;
• the receipt or provision of a gift outside the professional context, of an unreasonable value or on too frequent a basis;
• the giving or receiving of gifts during a strategic period: calls for tenders, calls for applications, signing of agreements, renewal of contracts, voting, ongoing contract negotiations, etc.;
• the concealment of gifts or invitations (e.g. paid for by an employee from their own account)
• the granting or receipt of gifts or invitations to or from relatives of employees (e.g. accepting an invitation to an event for a relative).
• gifts and invitations offered to Public Officials when they have been solicited by the latter or as part of a refinancing operation.

Sfil pays particular attention to the protection of personal data and applies a strict policy to guarantee its protection in accordance with the European General Data Protection Regulation (GDPR). The Privacy Policy, intended to inform people outside the Sfil group with whom Sfil interacts, and the cookies policy aim to provide detailed information on how the personal data that the Sfil group collects is used and protected.

Consult the Sfil privacy policy

Consult the cookie policy

For any questions or requests to exercise rights, the Personal Data Protection Officer can be contacted by email at dpo@sfil.fr

Sfil issues rules intended to ensure the protection of its customers.

Customer protection is effective at each stage of the relationship, at the time of pre-contractual information, during the life of the contract and at its conclusion. The Compliance Department, in conjunction with the business lines, helps to ensure that the interests of the customer come first, that the customer receives the right information, that the explanations given to the customer are fair, and to prevent the risk of conflicts of interest to the detriment of the customer.

Complaints received are handled diligently by Sfil in accordance with the regulations in force.

The fight against money laundering and the financing of terrorism, as well as compliance with international sanctions and asset freezing measures against certain countries, individuals or entities, are key elements of Sfil’s compliance system.
The Bank has therefore adopted policies and procedures tailored to its activities and those of its sole subsidiary, the Caisse française de financement local (Caffil), which set out the obligations to which they are subject. Sfil and Caffil, as institutions referred to in Article L561-2 of the Monetary and Financial Code, are subject to the regulations on combating money laundering and the financing of terrorism.

This system is based on:

• the knowledge and identification of customers, business partners and, where applicable, their beneficial owners with the a priori screening of customer databases to ensure compliance with applicable laws (“KYC”) and sanctions and asset freeze measures. ;
• the monitoring of the business relationship throughout its duration;
• the surveillance of certain operations and detection of suspicious transactions;
• cooperation with the regulatory and legal authorities in the event of suspected money laundering or terrorist financing in accordance with the applicable requirements;
• permanent and periodic monitoring of the AML/CFT financial security system;
• a system of information and continuous training for the Bank’s employees.

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Ethics in everyday life means:

• Comply with laws and regulations
• Respect people: this respect requires preventing any form of discrimination or moral or sexual harassment, promoting equality, diversity and gender balance, and ensuring the protection of the personal data of Employees and business relations.
• Non-discrimination is an obligation.
• Respect commitments to society and its environment.

With the Code of Ethics and Professional Conduct updated in 2020, Sfil clearly and uncompromisingly reaffirms the imperatives of ethics and integrity that concern all of the bank’s employees.

An appendix to the Internal Regulations, the Code is the foundation of the system for preventing the risk of regulatory non-compliance. It establishes the rules of conduct applicable both within Sfil and externally (to customers, suppliers, service providers, investors and financial markets, etc.) and more generally to society as a whole. It is designed to guide and help Sfil employees make decisions in accordance with the law and ethical rules within the framework of their activities and thus spread a culture of compliance.

In particular, Sfil has set up a system for the prevention and management of conflicts of interest, designed to identify, assess, manage, mitigate or prevent potential or proven conflicts of interest within Sfil or in relation to external persons that could have an adverse impact on the exercise of their duties and responsibilities. The system has been tailored to the size, organization and activities of Sfil. It is based on seven complementary elements: the appointment of a compliance officer, a framework for conflicts of interest, training for employees, an organization based on the principle of information protection, the establishment of ethical guidelines and rules of good conduct aimed at preserving the independence of employees, specific provisions for Sfil’s corporate officers and the remuneration policy.

Training and awareness-raising

Continuous training and awareness-raising among employees and managers regarding compliance with ethical rules and Confomité control procedures, particularly with regard to AML-CFT and the fight against corruption, in the performance of their duties, are essential for Sfil.

Useful documents:

As a bank, particular attention is paid to confidential information held by Sfil and to the respect of professional secrecy by employees.

Furthermore, in its capacity as an issuer, Sfil respects the rules and recommendations issued by the stock market authorities in the field of the holding, disclosure or possible exploitation of inside information. The use of this privileged information constitutes insider trading or insider misconduct. Procedures for the identification, control and publication of privileged information in order to prevent market abuse have therefore been put in place, including in particular an ad hoc organization with regard to information barriers and the management of insider lists.