Complaints about non-compliance decisions: 2018 annual report on committee operations
A Bank of Russia committee was launched on 28 January 2018 to look into complaints about decisions as regards ex-members of corporate governing bodies, other executives and major shareholders in financial institutions whereby they are found in breach of qualification / business reputation legislation. In 2018, as many as 225 complaints were registered.
During the specified period, the committee reviewed and redressed 77 complaints and dismissed 81. 14 complaints were returned due to a lack of subject matter (no information on the party submitting the complaint (grievant) in the database). 30 complaints were not reviewed due to their non-compliance with the established requirements; 23 complaints were pending as of 31 December 2018.
The Bank of Russia notes that the committee decides to redress complaints when the grievant provides adequate evidence that they were not involved in decisions or actions (or inactions) that had negative implications for the financial institution in question. Such evidence can include, for instance, documents defining the authorities and responsibilities of the grievant, such as: job descriptions; orders on the division of authority between managers; regulations on the financial institution’s management bodies, structural units, committees and commissions; as well as internal control regulations and other documents.
When redressing a complaint, the committee also takes into account the evidence provided by the grievant confirming that he or she took effective measures within its competence to prevent the trigger event in the financial institution’s activity.
The committee was set up following the entry into force of Federal Law No.