Our Internal Control Department, which operates under the supervision and control of the Audit Committee, is responsible for carrying out operational transactions regarding the execution of the Bank’s activities, Bank’s communication channels and information systems, financial reporting systems, and the controls for the implementation of business processes to ensure the reliability and integrity of our system, and timely availability of the information. Thus, we aim to ensure that our activities are carried out in accordance with legal legislation and the goals, policies, and strategies set by senior management and to provide controls of risky transactions at the Bank.

We carry out internal control activities in all domestic and foreign branches of the Bank, Head Office units, and consolidated partnerships, with a risk-oriented perspective within the framework of Article 30 of the Banking Law titled “Internal Control System”, “Regulation on Internal Systems of Banks and Internal Capital Adequacy Assessment Process”, "Regulation on the Information System of Banks and Electronic Banking Services" published by BRSA and other legal regulations. We share the findings and suggestions determined within the scope of internal control activities that we conduct locally and centrally with the relevant parties through reports and follow their actions. Additionally, we carry out information technology controls to assure that information systems activities are carried out securely and within the Bank’s rules.

Our Internal Control Department controls the functional separation of duties and the sharing of powers and responsibilities to define, measure, and prevent our Bank’s risks. Evaluating the compliance of the projects, procedures, and processes created by the Bank’s business units with the internal policies and rules of the Bank and assess the possible risks they bear, express their opinions in a way to reduce and manage the risks, determine the control points, increase the effectiveness of control activities, establish and improve the auto-control and systemic control mechanisms in processes and procedures and ensure that operational risks are reduced.

Detailed information on Internal Audits can be found in the Assessments on the Functioning of Internal Systems and Operations section of our report.

Prevention of Laundering of Criminal Proceeds and Terrorism Financing

Fighting against the laundering of proceeds of crime, financing of terrorism, financing of the proliferation of weapons of mass destruction, and preventing the use of the financial system by criminals are among the main areas we focus on within the scope of ethical banking. The necessary precautions to prevent the use of the products and services offered by our bank and our subsidiaries for the laundering of proceeds of crime and financing of terrorism are taken.

Our Bank prepared a compliance program to establish corporate policies and procedures and cover risk management, monitoring, control, and training activities to ensure an effective fight against the laundering of proceeds of crime and financing of terrorism, financing of the proliferation of weapons of mass destruction, and preventing the use of the financial system by criminals pursuant to the “Law on Prevention of the Laundering of Proceeds of Crime the ” no. 5549, the “Law on Prevention of the Financing of Terrorism” no. 6145, the “Law on the Prevention of Financing the Proliferation of Weapons of Mass Destruction” no. 7262, and related regulations. These activities are carried out by the Compliance Department, under the Compliance Officer.

We act in accordance with national and international regulations and rules through the Policy Document and Implementation Principles on the Prevention of the Laundering of Proceeds of Crime and Financing of Terrorism (MASAK Compliance Policy) through the policies, procedures, and control methods established in our Bank.

The activities to ensure compliance with the legal obligations within the scope of Prevention of the Laundering of Proceeds of Crime and Financing of Terrorism and the international rules, principles, and principles on the same subject are carried out by our Compliance and Regulation Department. Our Compliance Department, under the Presidency, maintains assessment of customers, transactions, and services with a risk-based approach, informing employees about the fight against proceeds of crime and their legal and administrative obligations to eliminate risks in this regard.

In-class and e-learning training is provided to our newly recruited employees on the Prevention of the Laundering of Proceeds of Crime and Financing of Terrorism within the scope of the Orientation and Basic Training Program. In-class and e-learning training are also organized for our current employees.

Every year, we regularly provide in-class and e-learning training on “Prevention of the Laundering of Proceeds of Crime and Financing of Terrorism” to our Bank employees. All our employees are trained for forgery and fraud in banking as follows:

• 15 e-learning courses on the Prevention of E-Fraud in Banking, updated and prepared by the Banks Association of Türkiye, were assigned to employees in 2022.
• 16 e-learning courses prepared by the Secure Banking department, as well as three e-learning modules prepared by the Inspection Board, were delivered to employees via the Training Catalogue.