What are the compliance cultural concepts advocated and adhered to by Western Securities?

First, all employees should establish the business philosophy of compliance management and compliance culture. We must make all employees realize that compliance management and compliance culture construction are a major matter in operation and management. It is not the regulators who ask me to do it, but we should do it ourselves, and we must do it consciously. Because compliance has a positive relationship with core elements of bank operations such as cost control, risk control, and capital returns, compliance can create value for banks, and an effective compliance culture will be able to eliminate compliance risks invisibly. Compliance management and compliance culture construction are the need to standardize operating behaviors, curb violations of regulations and disciplines, prevent cases, comprehensively prevent risks, and improve the level of operation and management; it is the urgent need to improve the institutional management system and prevent risks from the source; it is the urgent need to implement The scientific outlook on development is an important guarantee for achieving a new round of development goals for rural credit cooperatives. The concept and awareness of compliance must penetrate into the blood of all employees in the company, and penetrate into every position and every business operation link, so that all employees can abide by laws, rules and standards when carrying out business management work, and strive to cultivate employees' Compliance awareness, promote compliance concepts such as "everyone is responsible for compliance", "active compliance", and "compliance creates value" throughout the bank, and advocate moral value standards or codes of conduct and ethics of honesty, trustworthiness, and integrity. Corporate culture. Second, establish and improve the organizational mechanism for compliance management. We must fully understand the importance of establishing a compliance department, strive to overcome difficulties such as few people, heavy tasks and tight time, set up an independent and strong compliance department, and attach great importance to the construction of the compliance department. Compliance professionals must have both strong professional qualities and strong personal qualities. Personnel with a high degree of professionalism, corresponding technical qualifications and business capabilities must be selected and enriched into the compliance management team to cultivate and create a high-quality professional team. The compliance management organizational mechanism must implement a top-level responsibility system, implement the responsibility system at all levels, clarify the hub position of the compliance department in the company, and define the relationship between the compliance department and the business department: the first step for business departments to implement effective self-compliance control Line of defense, the second line of defense for the compliance department to implement professional compliance management before and during the event; as the main channel connecting the bank’s internal management and external regulatory rules, the compliance department decomposes regulatory rules, risk warnings and regulatory opinions to Each business department or other back-end support department, each business department actively seeks support and help from the compliance department, proactively provides compliance risk information or risk points, and cooperates with the compliance department's risk monitoring and assessment; the compliance department must provide construction Provide compliance opinions to help business departments manage compliance risks, provide compliance support for banking business and product innovation, and minimize legal risks caused by business innovation. Third, formulate a good system with strong execution capabilities. For a long time, there has been a lack of a unified, complete, comprehensive and scientific compliance risk management regulations and operating rules internally. Many system regulations are rough, general, and vague, and lack operability. When the system is implemented, there is a problem of "replacing trust with trust". management, replacing systems with habits, and replacing disciplines with human feelings" and other bad phenomena. Compliance management calls for scientific, reasonable and complete rules and regulations and operating procedures. It is necessary to strengthen the execution of rules and regulations to reverse the long-term situation of unclear responsibilities and difficulty in implementing responsibilities. In terms of identification, quantification, evaluation, resolution, etc., timely, necessary, scientific and reasonable improvements must be made to past rules, regulations and operating methods. Rules and regulations should not be static for many years. When formulating rules and regulations, they must be targeted , it should be concrete and operable. In the formulation of business regulations and operating procedures, it is necessary to clarify the normative requirements for the sorting, integration and revision of internal systems. The new system must have necessary compliance estimates and solve the institutional basis of compliance risk management at the source. The way in which administrative agency rules and regulations have been formulated must be changed. The relevant operating standards for business operations must no longer be stipulated in general terms. Business policies, behavioral manuals and operating procedures must be formulated for use by personnel in various positions in accordance with the sound practices of financial enterprises. Rules and regulations must cover all customers, products and services, and must cover the conduct and ethics of all employees. Through continuous revision and improvement at the institutional level, clear working standards for compliance with the law have been established in everything, and strict compliance management disciplines have been implemented everywhere, so that operating in accordance with the law and compliance has become a conscious behavior of the entire bank's employees. Fourth, strengthen compliance training for employees. Senior managers, compliance managers and other personnel are the three levels in the construction of compliance culture.

As the grassroots operating unit of the association, it should organize and develop continuous and effective compliance risk training and education programs to incorporate the literal requirements and spirit of the laws, rules and guidelines, compliance policies, compliance awareness and compliance responsibilities applicable to the bank. substance, embedded in business policies, conduct manuals and operating procedures. In accordance with the principle of full participation, education and training for compliance managers and other personnel should be carried out. The training should focus on systematicness, pertinence, professionalism, practicality and diversity. It is necessary to strengthen the training of new laws and regulations for compliance management personnel and the cultivation of professional ethics of "seeking truth from facts, objectivity, fairness, and integrity" to ensure that employees have the necessary professional qualities; they are responsible for providing other employees with relevant information on operation execution. Training on laws, regulatory regulations, and industry standards, including compliance training and testing for new employees; it is necessary to carry out corresponding training and education in response to changes in applicable laws, rules, and standards; it is necessary to strengthen both positive and negative aspects education, vigorously promote advanced models of compliance with laws and regulations, dedication to duty, diligence and integrity, and promote integrity. At the same time, we analyze typical cases, publicly handle typical cases and those responsible for violations of regulations and disciplines, and provide warning education to employees. Through multi-level compliance training, an atmosphere of compliance culture is gradually formed throughout the jurisdiction to ensure that relevant internal and external regulations are implemented. Fifth, strengthen inspection and supervision of compliance operations. From the perspective of sustainable development, bank compliance operations must achieve an effective combination of internal control and external supervision. On the one hand, we should strengthen information disclosure, improve transparency, and use social forces to supervise business operations; on the other hand, we should strengthen on-site inspections and off-site supervision to further promote self-discipline construction. When performing inspection and self-regulatory supervision functions, the division of responsibilities of various departments must be clear and they must cooperate closely to form synergy. The supervisory department is responsible for taking the lead in organizing the verification and handling of disciplinary violations and case clues; the business department is responsible for the operational risk inspection of operating institutions, special inspections of credit legal person customer business, special governance activities for personal loan operational risks, and various businesses that the department is responsible for. Implement rectification measures and strengthen system sorting and improvement; the personnel department is responsible for inspecting the exchanges and job rotations of personnel in important positions, and implementing the "compulsory leave" system; the security department is responsible for investigating and handling cases of fraud, theft, robbery, etc., and carrying out gun management, Special inspections of management systems such as escort, warehouse keeping and business organization video surveillance. It is necessary to carry out targeted rectification of key businesses, key links and key departments. The first is to manage key businesses. For fake car loans, fake housing mortgage loans, fake mortgage loans, fake pledge loans, illegal bill business, using false information to obtain and misappropriate credit funds, creating fake procedures and fake seals, etc. to steal corporate and personal deposits, and use transactions within the system We will focus on rectifying issues such as theft of funds from interbank current accounts and loopholes in the management of new businesses such as other intermediaries. The second is to manage key links. Focus on management of key links such as authorized credit, teller security certification cards, important blank voucher management, vaults and tail boxes, inquiry and reconciliation, rotation and vacation of important personnel, video inspection, and firearms and ammunition management. The third is to manage key departments. Focus on management of credit management, corporate business, personal business, financial accounting, security, legal affairs, personnel and other departments. Sixth, establish an effective incentive and restraint mechanism for compliance operations. In the past, due to insufficient attention to compliance risk management, the incentive and restraint mechanisms were relatively lacking, the rewards were small, and the punishments were light. Under normal circumstances, as long as there are no losses or cases, measures such as education and rectification within a time limit are often taken against violators, and severe punishment is rarely carried out. For those who cause losses or cases, the penalties are not severe enough, and the disciplinary effect is limited. Compliance culture requires that banks must have clear responsibility and accountability systems, as well as corresponding incentive and restraint mechanisms, to create an atmosphere in which all employees are naturally responsible for their careers and positions, and fully embody the bank's advocacy of compliance. values ??of regulating and punishing violations. First, it is necessary to establish and implement a regular evaluation mechanism for compliance operations and a reporting system for major violations. Failure to report or late reporting, false reporting, concealment, or omission of major or unexpected compliance incidents shall be punished based on the relevant circumstances and The degree of adverse effects, etc., will be dealt with seriously in accordance with relevant regulations of the state or the association. If the responsible person takes the initiative to report violations or reduce hidden risks, the punishment may be reduced or exempted as appropriate. The second is to establish a compliance accountability system and implement compliance responsibilities.

Those who have done well in compliance work or who have contributed to reporting or resisting violations must be protected, praised or rewarded; penalties for violations must be intensified, the cost of violations must be increased, and those who have or concealed violations, resulting in financial losses and economic cases, shall be strictly punished. Hold managers at all levels accountable. The third is to establish a re-supervision system for inspectors, and put forward rectification opinions for managers at all levels, compliance department personnel, and supervisory personnel who have not discovered problems that should be discovered in daily compliance risk management work, and should be punished if they are not punished. Those who fail to do so will be held jointly and severally liable and severely punished.