Transparency International releases new corruption perception index – Brazil remains stagnant
02/03/2021
| Through Directive Release No. 2/2021/CVM/SIN, CVM issued guidelines on the minimum elements that must compose the compliance activities and the Compliance Report provided for in arts. 19 to 22 of CVM Instruction No. 558 (“ICVM”). The purpose of the document is to present to securities portfolio manager registered with CVM the topics that must be observed by the compliance area and, consequently, appear in the Compliance Report, as well as the corresponding tests that must be included. It is important to remember that, if the compliance area does not act independently or does not carry out its activities as required by ICVM 558, the institution may suffer sanctions ranging from the issuance of an Alert Letter to, at the maximum, termination of society as a securities portfolio manager. The Report, which must be prepared by April 2021, regarding compliance activities in 2020, should observe the guidelines described in this Directive Release. Comments – Planning of internal control activities – Effectiveness of the verification, monitoring and testing of the institution’s internal controls – Minimum aspects to be considered by the compliance area – Effective participation of the Compliance Officer in testing Some topics that must be addressed by compliance Policies The compliance area should indicate whether any adjustments to policies and documents were resulted of regulatory changes, or requirements of the regulator, or if they were the result of internal changes, management decisions, or even if they were motivated by notes received in due diligence procedures. Conflicts of Interest It should be checked whether the policies to prevent possible conflicts of interest have been effectively enforced, including the exercise of external activities by administrators, employees and employees, such as participation in boards of directors, supervisors, advisors, or management committees, companies invested or potentially invested by the investment vehicles managed or administered, as well as the correct disclosure in the Reference Form of potential conflicts of interest with other activities of the institution, and its related companies. Risk management Check if the risk management policy (market, credit, liquidity, counterparty, operational) has been complied with and if it is adequate to the rules and regulations, as well as check if the market risk management policy was adequate to determine events of greater volatility during the year. |
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