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- Considering its global footprint, BANK OF AFRICA is regulated, supervised and monitored by the relevant authorities in each of the countries where it conducts business. Therefore, BANK OF AFRICA is committed to ensuring that the most stringent regulatory requirements are implemented by its international network.
- As a socially responsible Banking Group, BANK OF AFRICA is mindful of and sensitive to financial institutions’ role in:
- Fighting money laundering;
- Combating the financing of terrorist activities, proliferation of weapons of mass destruction and acts threatening international peace by enforcing sanctions and embargoes programmes;
- Preventing corruption and fraud;
- Preventing conflicts of interests and market abuse;
- Protecting customers and treating them fairly;
- Contributing to tax transparency through data exchange for tax purposes;
- Protecting individuals’ Personal Data.
With regard to these important topics, BANK OF AFRICA has developed a Group-Wide Compliance Framework founded on an approach that is:
- Board-sponsored;
- Ethics-and-values-led;
- Outcomes-based;
- By-design;
- Holistic ;
- Risk-sensitive ;
- Collaborative ;
- Adaptive ;
- And Human-centred.
Our Group understands and acknowledges the domestic and transnational money laundering threats to which financial institutions are exposed, and is fully aware of the economic and social consequences they can have on customers and communities, and the wider society.
Preventing money laundering, which the Group has zero tolerance for, is paramount to disrupting criminal activities and safeguarding the integrity of the financial system, both domestically and internationally. Therefore, Our Group is resolutely committed to implementing and maintaining a robust AML System in accordance with the most stringent regulatory requirements worldwide.
Pursuant to applicable regulations and best practices, Our AML framework is risk-based and capitalizes on the following:
- A comprehensive set of policies and procedures covering all business lines and customer categories and covering all AML related processes including, but not limited to, risk assessment, CDD, EDD, excluded customers, transactions monitoring and STR/SAR;
- A dedicated organization comprised of sufficient resources whose competencies and skills in the fields they are responsible for are demonstrated through their education, professional experience and certification by international organisations such as ACAMS and ICA;
- An appointed Group-wide Head of AML with the appropriate level of independence, seniority, oversight, and access to senior management and Board of Directors;
- Effective AML tools for managing KYC data, Screening and Transactions Monitoring;
- An appropriate and permanent oversight at HQ level over all subsidiaries and branches;
- A multi-channel training and awareness programme on AML requirements (face-to-face, webinars and e-learning);
- A solid relationship with regulators and competent authorities by supporting their efforts in preventing and fighting financial crime, and by extension, predicate offences themselves;
- Regular reportings to senior management, the Board of Directors and regulators;
- An ongoing cooperation with our business partners.
At BANK OF AFRICA, we take AML very seriously and we expect our customers, business partners, providers, and all actors within the financial eco-system where we operate, to do the same.
BANK OF AFRICA is fully committed to applying international sanctions and embargoes aimed at preventing and combating criminal activities; Terrorism, Proliferation and their financing, and serious violations of human rights.
Our Sanctions & Embargoes Compliance framework encompasses the Sanctions & Embargoes programmes enforced by: The United Nations Security Council, CNASNU (Morocco local list), OFAC (USA), European Union, United Kingdom and France.
Moreover, each Group entity undertakes to comply with Sanctions imposed by the country in which they operate.
In order to comply with its obligations under applicable Sanctions Regulations, BANK OF AFRICA has adopted a Sanctions Compliance Policy which indicates, inter alia, the following measures:
- Real-time screening of all incoming and outgoing cross-border transactions against the aforementioned Sanctions lists;
- Screening of new customers in the onboarding process;
- Daily screening of the customers base
- Control of trade finance transactions
The Group prohibits establishing or maintaining a business relationship with or executing a transaction involving sanctioned individuals, entities, organizations or countries.
At BANK OF AFRICA, we refuse to be, directly or indirectly, involved in transactions with sanctioned individuals, entities or countries. We expect our business partners to do the same.
As business ethics are enshrined in BANK OF AFRICA's CSR Charter, our Group has put in place fundamental principles that govern the way in which it conducts its business with regard to its employees, clients and society as a whole. These fundamental ethical principles are built around loyalty, integrity, professionalism, confidentiality and compliance with regulations. In the same spirit, BANK OF AFRICA actively contributes to the fight against corruption and, in so doing, ensures the integrity of the business it does with companies and individuals in Morocco and around the world.
Furthermore, as a UN Global Compact participant since 2016, BANK OF AFRICA has made anti-bribery & corruption part of its strategy, culture and day-to-day operations. The Group stands for a “Zero Tolerance” Policy towards corruption and, in doing so, it strictly prohibits “any act that consists of offering, promising, giving, accepting or soliciting an undue advantage of any financial or non-financial value, directly or indirectly, regardless of the place or places, in violation of applicable laws, to induce or reward a person to act or not to act in the course of his or her duties”.
Therefore, BANK OF AFRICA’s Anti-bribery and corruption system was built according to the globally recognized ISO 37001 (Anti-Bribery Management System). This certification, obtained in 2019 and renewed in 2022, translates our commitment towards anti-bribery & corruption, and ensures that the efforts around ABC are sensible and proportionate to the nature of risks associated with our business.
Our ABC system embodies a set of Business Ethics principles, including:
- Zero tolerance to all forms of bribery and corruption
- Accepting gifts and entertainments is prohibited
- Employees, customers, providers and business partners are encouraged to use the whistleblowing mechanism to raise ethic-related issues
- Conflicts of interest must be avoided, and when they exist, they must managed effectively
- Procurement must be undertaken ethically pursuant to the ABC Policy and the Responsible Procurement Charter
- Due diligence must carried out on employees, customers, providers and business partners
- Contractual commitments on anti-bribery and corruption must be formalised with employees, customers, providers and business partners
- Training and awareness efforts must be conducted continuously
Our ABC Policy is applicable to all group entities and is designed to ensure their compliance with applicable laws and regulations, including Bank Al-Maghrib’s Directive n° 1/W/2022 relating to the prevention and management of corruption risks.
We strongly believe that cooperation in the field of ABC with our business partners, including correspondent banks, is a Key Success Factor to ensure social and economic development of communities in which we operate.
We expect that our customers and business partners have the same “zero risk-appetite” to bribery and corruption.
For all ethical whistleblowing, requests for information or suggestions for improvement, please contact us:
- By e-mail: droitalerteethique@bankofafrica.ma
- By telephone: +212 5 22 49 81 61
- By post: Group Compliance, 140 avenue Hassan II, Casablanca Morocco (if sent by post, the letter must be marked "Courrier confidentiel" and directed to the Head of Compliance).
For more information on our ethics and anti-corruption policy, please refer to :
- Our Code of Conduct (attached)
- Our Anti-Corruption Policy (attached)
- Our Code of ethics for pre-judicial Debt Collection (attached)
1. Code of ethics
BANK OF AFRICA has adopted rules of good conduct and sound governance of its activities and businesses, which must be observed in the various entities of the BANK OF AFRICA Group to preserve its good reputation and to ensure the application of the best rules of ethics and professionalism by all of its staff.
In this respect, a Code of Ethics has been put in place that draws its sources from the legal and regulatory corpus that governs the Group and its entities: it establishes the fundamental principles that should govern the behaviour of BANK OF AFRICA employees towards all stakeholders, clients, suppliers, regulators; staff, etc.
2. Whistleblowing policy
BANK OF AFRICA has implemented a whistleblowing system; in line with the ISO 37001 standard on anti-corruption management systems. It allows employees to express themselves when they feel they have good reason to consider that an instruction received, an operation under consideration or more generally a particular situation does not comply with the fundamental rules and principles governing the conduct of the BANK OF AFRICA entity's activities.
The use of the whistleblowing mechanism in good faith is applicable to all BANK OF AFRICA Group employees as well as to its various commercial partners, suppliers, service providers, subcontractors, etc.
The application of the whistleblowing system is limited to the following fields:
Infringements of competition rules;
Conflicts of interest;
Insider trading;
Falsification of documents, accounts, or audit reports;
Theft, fraud, or misappropriation of bank property;
Corruption;
Discrimination;
Sexual harassment.
Ethical alerts can be made via the various channels provided for this purpose, namely:
1/- By telephone, via the dedicated line below:
Telephone number accessible from outside: 05 22 49 81 61
Internal extension: 81 61
2/- By post, by sending the duly completed ethics alert form, in an envelope marked “confidential”, to the attention of:
Pôle Compliance Groupe 140, avenue Hassan II Casablanca
3/- By e-mail via the droitalerteethique@bankofafrica.ma address.
3- Prevention of corruption
Given the diversity of geographical contexts encountered, and the importance of the investments made by the BANK OF AFRICA Group, the latter must be particularly vigilant in the fight against corruption. Strengthening the integrity approach is therefore a major challenge for the Group, which does not accept any form of corruption, whether active or passive.
This approach is based on clear principles, set out in the Group's Code of Ethics, included in a specific policy on the prevention of corruption. It is a reference document presenting all the principles of action that everyone should observe in their daily decision-making and in their relations with stakeholders.
CODE OF DEONTOLOGY AND ETHICS
RESPONSIBLE PURCHASING CHARTER
ANTI-CORRUPTION GUIDE
ANTI-CORRUPTION POLICY
BANK OF AFRICA acknowledges tax evasion as a criminal offence that has harmful effects on societies and does not tolerate all forms of tax evasion.
We are fully committed to complying with all applicable regulations designed to prevent tax evasion and its facilitation in the jurisdictions in which we, our clients, our suppliers and our business partners operate.
Therefore, we are fully committed to complying with the USA’s Foreign Assets Tax Control Act (FATCA) and the OECD’s Common Reporting Standard where these regulations are applicable.
We support all the efforts aimed at bolstering tax transparency and helping the relevant tax authorities prevent unlawful tax evasion.
We are confident that our employees, customers, suppliers and business partners share the same willingness to contribute to the fight against tax evasion worldwide.
Our business partners must be mindful of our:
- zero tolerance approach on tax evasion
- commitment towards tax transparency and exchange of information
