2013 Annual Report
148 2013 Annual Report Attachment
SOCIAL/PRODUCT
COMPLIANCE
Materiality and Responsibility
The responsibility for Social/Product Compliance lies with every area in the Bank
that deal with topics in connection with laws and regulations for social, product
supply, product labeling and marketing communication issues. This is of material
importance for the Bank because this is an area of interest for specialists and
scholars, i.e., the Bank's capacity to influence stakeholders on these topics;
also for the associated reputational risks; for the topic's association with laws
and regulations; and because it can bring significant risks to the Organization.
Positive Impacts - reduction of potential conflicts among the Bank and its
clients; a fair exchange of services for consumers; reduction of the risk of
reputational damage to the Bank; increased reliability.
Negative Impacts - conflicts and controversy between the company and
its clients.
Control mechanisms
In order to identify and minimize impacts, the Corporate
Affairs Vice President's Office keeps the branch network
updated about any legal actions in an effort to improve the
compliance with the laws and Court determinations. The
officers in charge also sit in FEBRABAN meetings to stay
abreast of how to adapt to laws and Court determinations.
The Bank also conducts the Legal Action Forum with
meetings every two months with the Branch Network
and the Marketing and Security areas, in which infraction
notices, fines and valid Court injunctions are addressed.
In the meetings the groups discuss the best way to service
and refer any issues of noncompliance with laws and Court
determinations and the consequences thereof.
Indicators Consolidation
Monetary value of significant fines and the total
number of non-monetary sanctions for non-compliance
with laws and regulations G4-508
In 2013 we had no fines in connection with this topic.
However, the Bank was sued 10 times with claims for
indemnity due to alleged discriminations; in one of them
the Bank was ordered to pay R$20,000 in damages;
in another suit the Bank received a favorable determination
and 8 actions are still pending judgment.
Monetary value of significant fines for non-compliance
with laws and regulations concerning the provision
and use of products and services G4-PR9
In 2013, the value of fines and sanctions in connection with
products such as credit cards and checking accounts was
approximately R$ 87 million.
The amount of fines and sanctions in connection with
security in the operation of branches was approximately
R$ 130 million.
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