Compliance

Role of the Office of the Chief Compliance Officer

The Office of the Chief Compliance Officer (Compliance Office or OCCO) is responsible for defining, implementing and overseeing the CEB’s integrity and compliance framework. OCCO identifies, assesses, advises on, monitors and reports integrity and compliance risks that could expose the Bank to regulatory sanctions, financial loss or reputational damage.

These risks may arise from non-compliance with applicable laws and regulations, internal rules and codes of conduct, or internationally recognised standards of good practice.

A preventive and risk-based approach

The Compliance Office operates through a risk-based and preventive approach, combining advisory, monitoring and investigative functions. Its activities cover both:

• the conduct of CEB staff members, governing bodies and collaborators; and
• the integrity of projects, counterparties and transactions financed or supported by the Bank.

This approach enables the CEB to anticipate and mitigate integrity risks at an early stage, while fostering a strong culture of compliance across the institution.

Advisory and control functions

OCCO plays an important advisory role, providing guidance and assistance to the CEB’s senior management and operational divisions. It continuously evaluates compliance and integrity risks related to projects and transactions and contributes to safeguarding the Bank’s reputation and financial soundness.

Complaints

The Compliance Office administers the CEB’s complaints handling mechanism related to alleged non-compliance with the Environmental and Social Safeguards Policy (ESSP). It receives and assesses complaints, conducts reviews or investigations where appropriate, and advises the Governor on findings and remedial actions, while monitoring follow-up measures to strengthen accountability and compliance across the Bank.

Chair of the Procurement Complaints Committee (PCC)

The Chief Compliance Officer (CCO) chairs the Procurement Complaints Committee (PCC), which reviews complaints relating to alleged errors or irregularities in CEB procurement procedures. The PCC assesses admissible complaints, verifies compliance with applicable procurement rules and principles, and issues a reasoned opinion to inform the Governor’s decision. Allegations of fraud or corruption are referred to OCCO for investigation, and complainants are informed of the outcome within defined timelines.

Information security and data protection

Within OCCO, the Chief Information Security Officer (CISO) is responsible for defining, planning and implementing information security and operational resilience measures. The CISO ensures that appropriate Cyber security controls are in place, regularly updates the Bank’s information security policies and guidelines, and supports the protection of sensitive information and personal data.

Alignment with international standards

The CEB’s compliance framework is aligned with international best practices applied by peer international financial institutions, including in the areas of anti-money laundering, counter-terrorist financing, tax good governance, investigations, whistleblowing, information security and data protection.

Contacts:

• General compliance matters: compliance@coebank.org
• Whistleblowing (confidential): OCCO-whistleblowing@coebank.org
• Data Protection Commissioner: Mr Billy Hawkes, DPC@coebank.org
• Data Protection Officer: DPO@coebank.org