Guaranteeing transparent ethics and governance

Employees who have completed the annual compliance and ethics training courses

End of 2020 Target
90 %
2019
90 %
2018
92 %
2017
90 %
2016
89 %

Significant incidents resulting in a major corrective action plan

End of 2020 Target
5,0 %
2019
5,8 %
2018
10,0 %
2017
10,7 %
2016
5,8 %

The Compliance Department

BNP Paribas Real Estate is committed to conducting its activities in compliance with laws and regulations, and in accordance with the highest standards of ethics.  As a major player in the real estate sector, our International Executive Board has made integrity and reputation a priority. This allows us to maintain our reputation for honesty, quality and integrity at a high level.  Complying with the laws, regulations and professional standards specific to their activity is an essential requirement for all BNP Paribas Real Estate employees. BNP Paribas Real Estate’s Compliance Department ensures that the company and its employees respect them.
Fabrice BLIN,
Chief Compliance Officer

As a major player in the real estate sector, our International Executive Board has made integrity and reputation a priority. 
We strive to inspire the trust of our customers. To do this, we regularly train and support our employees so that they understand our compliance policies and act in the best interests of our clients.

Our compliance and ethics commitments

As a member of the BNP Paribas Group, we believe that the success of BNP Paribas Real Estate depends directly on the behaviour of each employee. The BNP Paribas Group Code of Conduct aims to provide employees with a framework for making decisions and actions based on professional expertise, integrity and a deep sense of ethical responsibility.  Although there can never be strict rules that apply to all situations, our Code of Conduct is given to each employee upon arrival and is intended to be used with personal judgement to ensure that the spirit of the Code is always respected.

The BNP Paribas Group’s Code of Conduct defines:

  • Our mission and values: what we represent and the key principles that guide our actions and decisions
  • Rules of conduct: specific rules shared and implemented by all employees, in accordance with our values and ethical standards
  • Code of Conduct in Practice: clear guidelines and expectations for employees on how to apply the Code.
    Through this code, BNP Paribas Real Estate defends its values of expertise, proximity, responsibility and innovation development.

The importance of our clients’ interests

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At BNP Paribas Real Estate, we always seek to put our clients at the centre of our focus.  We constantly strive to serve their best interests with diligence, fairness, neutrality and discretion, within the framework of laws and regulations. Protecting our clients is indeed our fundamental duty, and is essential to maintain their trust. We are committed to providing products and services that best meet their needs and expectations, ensuring transparency, preventing and managing conflicts, and respecting professional secrecy and client confidentiality.

Zero tolerance for corruption

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For BNP Paribas, corruption is completely unacceptable under any circumstances.  It must not be tolerated and must be actively fought. The participation of an employee in an act of corruption is professional misconduct.  The participation of a partner in an act of corruption must result in the immediate termination of the commercial relationship. The prevention and detection of corruption are an essential part of BNP Paribas Real Estate’s compliance system. Whatever the circumstances and interests at stake, the fight against corruption is the responsibility of all BNP Paribas Real Estate employees

Professional ethics

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Compliance ensures that the personal private interests of employees do not take precedence over their professional responsibilities. BNP Paribas Real Estate has implemented strict rules of professional conduct, which are part of the Group’s Code of Conduct, with the aim of protecting the Group and its employees against the risks of corruption, market abuse and conflicts of interest. For example, BNP Paribas Real Estate prohibits the practice of giving or receiving gifts and instead donates some of the amounts usually allocated to this practice to charitable organisations.

Compliance and ethics procedures

Financial security

Our compliance procedures to ensure financial security are extremely important to our operations and aim to protect against money laundering, prevent corruption and terrorist financing, and comply with ever-changing financial requirements, including international financial sanctions and embargoes.

These procedures are described in the BNP Paribas Group Code of Conduct and are based on:

  • our ethical values and principles of exemplary conduct
  • the laws in the countries in which we operate
  • European regulations
  • recommendations from international organisations

The Ethical Alert Right

BNP Paribas Real Estate has set up an ethical alert right procedure for all employees when they are wondering about possible shortcomings within the company. Each employee, in any business activity they carry out or of which they are aware, must ask themselves the question of compliance with ethical principles.  If they have any doubts, they refer them to their hierarchy.  If the employee does not wish to do so, they can then place themselves within the framework of the ethical alert right system and contact the compliance officer of their entity.  Anonymity is guaranteed and protection against any retaliation measures is ensured.

The Risk Department

Against a backdrop of increasingly complex regulatory requirements and tighter controls, the BNP Paribas Group has centralised risk. In November 2015, the Risk Department of BNP Paribas Real Estate, “RISK RE”, was created and covers the 6 business lines and the 13 countries where the company operates. Totally independent from the business lines, it is organised around four dedicated teams:

  • Real Estate Development (office and residential real estate in France and abroad): to support the development of the business within the fiscal, regulatory and legislative framework in force, in line with the Group’s risk policy and in compliance with financial performance criteria.
  • Investment Management: to support the development of the business when launching new investment funds, when selecting and allocating assets, and to analyse the risks for the various real estate funds under management in connection with local
  • AIFM risk managers.
    Operational Risk covering the 6 business lines: to analyse and challenge the effectiveness and quality of the control system mainly through supervision missions and to provide independent reports and alerts on critical issues of concern.
  • Data Protection: to monitor compliance with the GDPR in regard to the regulations in force and the rules defined by the BNP Paribas group, to inform and advise the teams that process data on their obligations, to provide advice on request concerning the impact assessment relating to data protection and verifying its execution, acting as a contact point for the supervisory authority in France on questions relating to processing.

RISK aims to be a partner of our business lines by contributing to their sustainable development, but also a gatekeeper to ensure the compatibility between the risks taken and the risk appetite of the Group and its strategy.

Risk RE is the Group’s second line of defense for the relevant risk management activities of its direct responsibility: financial risks, market risks, operational risks, risks linked to data protection.

As such, RISK RE is integrated into the governance of BNP Paribas Real Estate and is a member of the business decision-making committees. The Risk Director is a member of the International Executive Committee, the Central Functions Committee and the Internal Control Committee.
Risk monitoring (anticipation, evaluation, alerts, monitoring of action plans targeted by the business lines) is ensured through the production of quarterly and annual reviews intended for managers of BNP Paribas Real Estate and BNP Paribas group.