Compliance management continues to be an important function at People’s Leasing. Our risk assessment process oversees our compliance risk exposure, along with legal, financial, operational, and reputational risks.

The compliance culture

Compliance is deeply steeped in the culture of People’s Leasing. The Board and Senior Management take the lead in establishing an environment wherein ethics, integrity, transparency, and accountability play a key role. This has the effect of the Company’s employees taking ownership towards their responsibilities and carrying out their functions with compliance in mind, adhering to all applicable laws and regulations.

People’s Leasing has not been subject to fines or action imposed by regulators due to instances of non-compliance for the period under review.

The compliance function

A stand-alone compliance function with a direct reporting structure to the Integrated Risk Management Committee (IRMC) of the Board ensures that it has a significantly higher level of independence from the business and other support functions of the Company.

People’s Leasing takes a preventive approach towards compliance by creating a culture that deters potential breaches before they occur. Various interrelated processes define the comprehensive compliance management system of the Company. Internal audit carries out regular investigative activities, monitors compliance, carries out random checks, and makes recommendations that are implemented by the heads of respective divisions.

For the period under review, the Company faced challenges in implementing changes to the Company’s operating procedures and practices to ensure compliance with new Directions and circulars issued by regulatory authorities. This was primarily due to the high costs involved for the implementation of systems, combined with the challenging nature of breaking away from industry-wide practices. The Company and the broader financial services sector will continue to face challenges in the coming years in the form of continuous regulatory changes to suit modern transaction methods, developments in technology, and increased monitoring and reporting functions.

Compliance controls

Internal Audit regularly conducts audits in areas deemed susceptible to fraud and unethical practices. The findings of these audits are reported to the Board Audit Committee and Integrated Risk Management Committee, who evaluate and recommend corrective measures as necessary.

A Whistle-Blower Policy promotes ethical behaviour and an effective compliance culture within the Company’s activities. It provides a mechanism for employees to report possible risks and violations of laws and regulations.

The HR Policy ensures that the ethical work culture of the Company is upheld through the recruitment of employees with a high level of integrity as well as enabling the periodical rotation of staff.

An Anti-Money Laundering (AML) and Know Your Customer (KYC) Policy and procedure manual are in place, covering all aspects of anti-money laundering. Relevant staff members are provided with the necessary training for KYC,
AML, combatting the financing of terrorism, and customer risk profiling to ensure compliance with the relevant laws and regulations.

Compliance technology

People’s Leasing incorporates the usage of technology wherever possible to update compliance monitoring and testing mechanisms in line with current industry practices.

The Company uses a customer screening software system to assess customers prior to onboarding against sanctioned lists, adverse media exposure, and other potential risks and liabilities.

Compliance training

As part of the preventive measures taken to ensure compliance is upheld within the Company, employees are provided with adequate training. To this effect, the Human Resources Department establishes a training plan that incorporates internal and external training opportunities. For the period under review, compliance staff members received training to ensure they remain up to date on changes in laws and regulations and international best practices.

Further, the Compliance Department has carried out extensive training programmes for staff members in the executive grades who are exposed to AML/TF risks, during the reporting period.

Compliance-related regulatory developments

The following compliance-related regulatory developments occurred during the period under review:

• Finance Business Act Direction No. 01 of 2018 – Financial Customer Protection Framework
• Regulations No. 01 of 2018 – Amendments to Sri Lanka deposit insurance scheme – Regulation No. 01 of 2010
• Finance Business Act Direction No. 02 of 2018 – Loan to value ratio for credit facilities granted in respect of motor Vehicles
• Finance Business Act Direction No. 03 of 2018 – Capital Adequacy requirements
• Finance Business Act Direction No. 04 of 2018 – Valuation of immovable properties
• Circular No. 01 of 2018 – Credit Ratings
• Finance Business Act Direction No. 05 of 2018 – Amendments to Directions on Loan to Value Ratios for Credit Facilities Granted in Respect of Motor Vehicles
• Finance Business Act Direction No. 06 of 2018 – Amendments to Directions on Loan to Value Ratios for Credit Facilities Granted in Respect of Motor Vehicles
• Finance Business Act Direction No. 07 of 2018 – Outsourcing of Business Operations
• Finance Business Act Direction No. 08 of 2018 – Amendment to Direction on Structural Changes
• Finance Business Act Direction No. 09 of 2018 – Measures to Curtail Import of Motor Vehicles
• Finance Business Act Direction No. 10 of 2018 – Maximum Rate of Interest on Microfinance Loans
• Amendments to the Rules for Financial Institutions (Customer Due Diligence) Rules, No. 01 of 2016 – Extraordinary Gazette No. 2092/02, 8 October 2018
• Guideline No. 01 of 2018 – Minimum Compliance Standards for Payment-related Mobile Applications
• Circular No. 06 of 2018 – Establishment of a National Quick Response Code Standard for Local Currency Payments
• Guideline No. 04 of 2018 on identification of Beneficial Ownership
• Guideline No. 05 of 2018 on implementing United Nations (Sanctions in relation to Democratic People’s Republic of Korea)
• Guideline No. 06 of 2018 on Suspicious Transactions Reporting
• Guideline No. 07 of 2018 on implementing United Nations (Sanctions in relation to Iran)