Sustainability Policy

BCF recognises international human rights standards and is fully committed to the values and aspirations they embody. Protecting the integrity of its employees is a key priority. The Personnel Guidelines prohibit all forms of discrimination, whether direct or indirect. Line managers are responsible for ensuring that, within their area of responsibility, the working environment is healthy, conducive to work and free from any form of harassment.

An internal communication channel is available for employees to report any violation of personal rights or irregularities, such as infringements of laws, regulations or guidelines.

The Personnel Regulations and Personnel Guidelines are an integral part of the employment contract. They include rules of conduct to be followed in the fight against corruption and money laundering. Each employee is required to confirm in writing that they are aware of these policies and undertake to comply with them. These issues are also discussed during the induction day for new employees and as part of ongoing training.

More generally, BCF invests considerable resources to effectively combat money laundering and terrorist financing. It also complies with tax requirements. Customers are responsible for complying with the legal and regulatory provisions applicable to them, in particular those relating to the obligation to file tax returns and pay taxes. Customers release the Bank from any liability in this regard.

Compliance and respect for ethical rules are fundamental values at BCF. As a responsible bank, BCF places loyalty, integrity and professional ethics at the heart of its relationships with its stakeholders. Acting in compliance means ensuring that all the Bank’s actions are strictly in compliance with the provisions applicable to banking and financial activities. These provisions include applicable laws and regulations, professional and ethical standards and internal policies. The strict application of these principles is both a duty to customers and an essential foundation of BCF’s reputation and reliability.

All customer complaints are centralised within the Legal, Risk, and Compliance Division. This division is responsible for handling them and reporting them to the appropriate bodies, depending on their nature and severity: the Executive Board, the Board of Directors or, where appropriate, the Swiss Banking Ombudsman.

In the event of specific questions or complaints concerning banking and financial transactions carried out by the Bank, customers can turn to a neutral mediator: the Swiss Banking Ombudsman. The Swiss Banking Ombudsman acts as an information and mediation body, without any legal authority to impose decisions, for customers of SBA member institutions. Further information can be found at: www.bankingombudsman.ch

To combat tax fraud, BCF applies the various regulations relating to the automatic exchange of tax information. These include, in particular, the OECD Automatic Exchange of Information (AEOI) standard and the FATCA (Foreign Account Tax Compliance Act) agreement between Switzerland and the United States.

These initiatives enable the tax authorities of partner countries to obtain financial information on the accounts and assets held abroad by their taxpayers. There are two main legal bases for their implementation in Switzerland: the Swiss Federal Act on the International Automatic Exchange of Information on Tax Matters (AEIA) and the FATCA Act.

These obligations apply to both individuals and legal entities. Customer data, including information on their assets, will only be transferred if Switzerland has concluded a bilateral agreement with the country in question.

The updated list of partner countries with which Switzerland applies the AEOI can be found on the BCF website and on the website of the State Secretariat for International Finance (SIF), which also provides detailed information on the terms and conditions of the automatic exchange of information.

The Banque Cantonale de Fribourg has implemented strict measures to prevent any form of corruption within the Bank. To this end, its internal regulations formally prohibit the acceptance of money, gifts or any other direct or indirect advantage in connection with its professional activities. Only customary gifts of modest commercial value, as defined by the internal regulations, are permitted.

BCF is subject to the supervision of the Swiss Financial Market Supervisory Authority (FINMA) and thus meets all the requirements of the financial sector. It has a Legal, Risk and Compliance division whose remit falls within the scope of FINMA Circular 2017/1, “Corporate Governance – Banks”, particularly the responsibilities under the second line of defence. This framework ensures the separation of control functions and independence in decision-making. The division is made up of five structural units, including the Compliance unit, which is responsible for ensuring compliance with legal, regulatory and internal requirements and adherence to the ethical standards and rules applicable in the market in question.

The Compliance department is also responsible for the annual assessment of compliance risks, particularly with regard to combating money laundering and the financing of terrorism. On this basis, it draws up a risk-based action plan. It implements policies that aim to define the organisational rules and rules of conduct necessary to ensure effective prevention.

A specific policy, applicable to all employees, sets out best practice and the rules for preventing money laundering risks within the Bank. Upon joining the Bank, all employees receive mandatory training on the regulations in force to prevent and combat money laundering and terrorist financing.

In addition, the Bank is audited annually to ensure that its processes are in line with the legal and regulatory framework.

www.bcf.ch/fr/la-bcf/propos-de-nous/informations-juridiques

The protection of personal data is of paramount importance to BCF. The Bank is committed to the strict application of the Swiss Federal Data Protection Act (DPA), which, together with banking secrecy, protects clients from unauthorised access to their personal data. It has implemented governance principles and technical, organisational and infrastructure-related measures to ensure a high level of data security.

In particular, the Bank processes the data of its customers and business partners to fulfil its contractual, legal and regulatory obligations, and to pursue its legitimate interests, such as the development and consolidation of business relationships.

In order to meet the above obligations, BCF may outsource certain services to third parties, particularly in the areas of IT and administration. These third parties are contractually bound to protect the confidentiality and security of data. In addition, the Bank takes all reasonable measures necessary to secure data transfers to third parties. These third parties may only use subcontractors with the Bank’s prior consent.

In particular, the customer has the following rights, subject to applicable legal restrictions:
– Right of access to personal data, and to information about how the Bank processes said data;
– Right to rectify inaccurate or incomplete data;
– Right to withdraw consent at any time;
– Right to portability, i.e. the right to request, within the limits provided for by law, the return of data provided to the Bank or its transfer to a third party;
– Right to restrict the processing of personal data, in particular by opposing its use for marketing purposes;
– Right to erasure when the data is no longer necessary for the purposes for which it was collected or processed, subject to the applicable retention periods.

BCF retains personal data for as long as necessary to fulfil its legal and contractual obligations. As a general rule, documents are destroyed ten years after the end of the business relationship or after the completion of the transaction.

Internally, the obligation to maintain confidentiality, and in particular banking secrecy, is formally enshrined in employment contracts, the Staff Regulations and various internal policies. The Bank’s employees are regularly made aware of the importance of following these rules, particularly through internal training.

Detailed information on the processing of personal data and customer rights can be found in the ‘Data protection declaration’ available on the Bank’s website. Customers are also informed of the data protection provisions in the BCF General Terms and Conditions, the terms and conditions of use of the website, the terms and conditions of use of Mobile Banking, the terms and conditions of use of One, the terms and conditions of use of the financial assistant and the terms and conditions of use of Twint.

All personal and sensitive data is protected by a multi-level security system. Consequently, all of the Bank’s non-public areas are protected by an access control system, and only duly authorised persons have access to them.

Similarly, access to BCF’s IT systems is only possible with a personal ID and password specific to each employee. Each individual computer is protected by a personal password.

Access to the data is restricted to employees of the Bank or duly authorised persons on a need-to-know basis.

With regard to cybersecurity in particular, the robustness of the system is regularly assessed, and tests are conducted to verify its resilience to cyberthreats. BCF’s entire IT infrastructure is outsourced to Swisscom (Switzerland) Ltd, which applies its own security standard, ITSLB (IT Security Level Basic). This standard is based on recognised best practices in the technical, organisational and infrastructural fields.

Swisscom’s security approach covers all the IT layers used by BCF: applications, databases, services, storage, workstations, networks and servers. At each level, Swisscom ensures optimal security through rigorous management of configurations, protection systems, identities, access and control and reporting processes.

BCF customers have online access to the Bank’s General Terms and Conditions and Regulations, and to various useful documents and information, in particular:
– the “Risks Involved in Trading Financial Instruments” brochure published by the Swiss Bankers Association (SBA) providing general information on the main financial services and the risks involved in trading in financial instruments;
– a description of the financial services offered by BCF and the measures taken to protect investors;
– an information notice concerning commissions and retrocessions, explaining the scope of Article 31 of the General Terms and Conditions of Banque Cantonale de Fribourg.