Organizational Model - Compliance Office

The main duties of the Compliance Office are to:

1. Oversee compliance with the law and all norms and regulations (internal and external) related to the activities of the Bank and associated companies, their functional structures and all employees of the Banco Comercial Português Group;
2. Support management of the Business, Product and Customer areas and units in the applicability and conformity of their activities and functions in the face of applicable regulation;
3. Ensure the suitability of internal norms and regulations with respect to changes in legislation in force, assisting the different areas of the Bank in adapting their specific norms;
4. Support and promote compliance related training activities and programmes;
5. Ensure compliance with the best international practice regarding "know your customer" and "due diligence" including in particular, the installation of digital tools (filters) with a view to detecting operations involving entities subject to embargos and international sanctions.

The referred duties are assured in a continuous manner, including constant monitoring of the various Areas of the Bank so as to guarantee, at all moments, complete knowledge and compliance of the applicable rules by all Bank employees.

In particular, regarding the matter of Money laundering, and with the objective of ensuring that all employees have the necessary training, the Compliance Office implemented a series of concrete actions, the most significant of which are:

• The publication of Compliance Manual on the Group Intranet;
• The inclusion of a Compliance module on Anti-Money Laundering in the induction training for new employees, and ;
• An e-learning training programme for all employees of the Group which reached 1200 employees in 2005 and is expected to reach another 3000 in 2006.

The Compliance Office has its own representatives in the different business areas in Portugal and subsidiaries and stockholdings of the Group in other countries.