Compliance Risk Management Regulation - 21.12.2015

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Formatted: English (United States)
COMPLIANCE RISK MANAGEMENT

REGULATION
Zagreb, NovemberDecember August 2015

Compliance Risk Management Regulation
Document data
Name Compliance Risk Management Regulation Formatted: English (United States)
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Version 1.0 Formatted: English (United States)
Official document number, Formatted: English (United States)

enactment date
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SKDD-CCP Smart Clear d.d. 1

TABLE OF CONTENTS
1. GENERAL PROVISIONS .................................................................................................... 33

Definitions of terms ............................................................................................................... 33
Area of application ................................................................................................................ 44
2. ORGANISATIONAL STRUCTURE, PURPOSE AND OBJECTIVE OF THE COMPLIANCE
MONITORING FUNCTION ...................................................................................................... 55
Person performing compliance monitoring tasks ................................................................. 55
Relation with other organisational units of SKDD-CCP and Employees of the Service
Provider ................................................................................................................................. 55
Purpose and objective of the Compliance Monitoring Function .......................................... 55
3. POSITION OF THE COMPLIANCE MONITORING FUNCTION WITHIN SKDD-CCP AND
ITS RELATION WITH OTHER SKDD-CCPs CONTROL FUNCTIONS ................................ 66
Measures for ensuring independence .................................................................................. 66
Relation with other SKDD-CCPs control functions ............................................................. 66
4. ANNUAL WORK PLAN ........................................................................................................ 66
Adoption method................................................................................................................... 66
Contents of the Plan ............................................................................................................. 66
Operative Work Plans ........................................................................................................... 77
5. REPORTING SYSTEM ........................................................................................................ 77
Semi-Annual Report on the Activities................................................................................... 77
Annual Report on the Activities ............................................................................................ 87
Special reports ...................................................................................................................... 88
Participation at staff meetings .............................................................................................. 88
6. TASKS OF THE HEAD OF COMPLIANCE MONITORING ................................................ 88
Procedure of Compliance Risk identification and assessment ............................................ 99
Advising the Management Board and other responsible persons ................................... 1010
Evaluation of the effects of changes in Relevant Regulations on SKDD-CCPs business
operations ......................................................................................................................... 1010
Verification of compliance of new services or new procedures ....................................... 1111
Prevention of conflict of interest ....................................................................................... 1111
Recommendation for Harmonisation................................................................................ 1111
Procedures as recommended by the Compliance Monitoring Function.......................... 1111
Training of SKDD-CCPs Employees ............................................................................... 1212
7. FINAL PROVISIONS ........................................................................................................ 1212
Right to access data and information ............................................................................... 1212
Validity of the Regulation .................................................................................................. 1212

Pursuant to the provisions of the Articles of Association of SKDD-CCP Smart Clear d.d.
(hereinafter: SKDD-CCP), on the _______ meeting held on ________ the Management
Board of SKDD-CCP adopts the following:
Compliance Risk Management

REGULATION
1. GENERAL PROVISIONS
Definitions of terms
Article 1
The following terms used in the Compliance Risk Management Regulation (hereinafter: the
Regulation) shall have the following meaning:
1. Compliance Monitoring Function is a control function of SKDD-CCP which

organisationally belongs to the organisational unit 02 Compliance Monitoring
(Organisational structure with job description and schedule of SKDD-CCP
employees).
2. Supervisory Authorities are ESMA (European Securities and Markets Authority) and
the Croatian Financial Services Supervisory Agency.
3. EMIR is:
- Regulation (EU) No 648/2012 of the European Parliament and of the Council of 4

July 2012 on OTC derivatives, central counterparties and trade repositories,
- Commission Implementing Regulation (EU) No 1249/2012 of 19 December 2012 Formatted: English (United States)
laying down implementing technical standards with regard to the format of the records Formatted: English (United States)
to be maintained by central counterparties in accordance with Regulation (EU) No
648/2012 of the European Parliament and of the Council on OTC derivatives, central
counterparties and trade repositories,
- Commission Delegated Regulation (EU) No 148/2013 of 19 December 2012

supplementing Regulation (EU) No 648/2012 of the European Parliament and of the
Council on OTC derivatives, central counterparties and trade repositories with regard
to regulatory technical standards on the minimum details of the data to be reported to
trade repositories,

Council with regard to regulatory technical standards on indirect clearing
arrangements, the clearing obligation, the public register, access to a trading venue,
non-financial counterparties, and risk mitigation techniques for OTC derivatives
contracts not cleared by a CCP

to regulatory technical standards specifying the details of the application for

registration as a trade repository,

to regulatory technical standards specifying the data to be published and made
available by trade repositories and operational standards for aggregating, comparing
and accessing the data,

to regulatory technical standards on capital requirements for central counterparties,

Council with regard to regulatory technical standards on requirements for central
counterparties,
- Commission Delegated Regulation (EU) No 285/2014 of 13 February 2014

Council with regard to regulatory technical standards on direct, substantial and
foreseeable effect of contracts within the Union and to prevent the evasion of rules
and obligations.
4. Service Provider is Sredinje klirinko depozitarno drutvo, dioniko drutvo

(Central Depository and Clearing Company Inc.) (hereinafter: SKDD), which provides
services to SKDD-CCP, in accordance with the Agreement on Business and
Technical Cooperation concluded between SKDD and SKDD-CCP.
5. Employee is SKDD-CCPs employee and an employee of the Service Provider who

performs business activities and participates in SKDD-CCPs business processes.
6. Relevant Regulations are regulations which regulate SKDD-CCPs business

operations and which are stated in the List of Relevant Regulations, as Annex I to this Formatted: Font color: Auto, English (United States)
Regulation. The List of Relevant Regulations is not final and will be updated when
necessary. Peron Responsible for Compliance Monitoring is SKDD-CCPs Formatted: English (United States)
employee appointed by SKDD-CCPs Management Board as a person responsible
for performing the tasks of the Head of Compliance Monitoring position.
7. Compliance Risk is a risk of enunciating possible measures and penalties and a risk
of a significant financial loss or loss of reputation that SKDD-CCP may suffer due to
noncompliance with regulations, standards and internal documents.
Area of application
Article 2
The Regulation defines:
organisational structure, task, purpose and objective of the Compliance Monitoring

Function;
position of the Compliance Monitoring Function within SKDD-CCP and its relation
with other SKDD-CCPs control functions and Employees;
annual work plan and reporting system;
tasks of the Head of Compliance Monitoring;
role of SKDD-CCPs Management Board related to the risk of noncompliance;

Employees procedures as recommended by the Compliance Monitoring Function.
Provisions of this Regulation shall also apply to Employees of the Service Provider who
perform business activities and participate in SKDD-CCPs business processes.
2. ORGANISATIONAL STRUCTURE, PURPOSE AND OBJECTIVE OF THE COMPLIANCE

MONITORING FUNCTION
Person performing compliance monitoring tasks
Article 3
Compliance monitoring tasks in SKDD-CCP are performed by the Person Responsible for
Compliance Monitoring the Head of Compliance Monitoring who possesses an appropriate
level of expertise, experience and independence in their activities.
Person responsible for compliance monitoring:
a) supervises and coordinates implementation of the Compliance Monitoring Function in SKDD-

CCP,
b) supervises work of SKDD-CCPs Employees and Service Providers Employees who perform
tasks in SKDD-CCP, with regard to compliance with EMIR and other Relevant Regulations,
c) responsible for updated preparation of periodical reports and the evaluation of adequacy of
Compliance Risk management,
d) performs other tasks defined in this Regulation and other SKDD-CCPs official documents,
d)e) monitor and, on a regular basis, assess the adequacy and effectiveness of the Formatted: Font: 11 pt, No underline, Font color: Auto,
measures put in place to mitigate legal risk that can rise from potential conflicts of law. English (United States)
Relation with other organisational units of SKDD-CCP and Employees of the Service Formatted: English (United States)
Provider
Article 4
The Compliance Management Function cooperates with Service Providers Employees who
perform SKDD-CCPs tasks, as well as with all organisational units of SKDD-CCP and their
Employees who, by having deep knowledge of business processes of an individual
organisational unit and specific, expert knowledge which cannot be expected from the Head
of Compliance Monitoring to have, enable evaluation and continuous Compliance Risk
monitoring within an organisational unit where they are employed.
Purpose and objective of the Compliance Monitoring Function
Article 5
The purpose and objective of the Compliance Monitoring Function is to ensure alignment of
SKDD-CCPs business operations with regulations, regulatory principles, standards and
internal documents, so as to ensure stability of SKDD-CCPs business operations.
SKDD-CCPs business operations are based on relevant regulatory principles, high Formatted: Font color: Auto, English (United States)
international standards and market protocols, which have been taken into consideration
during the preparation of SKDD-CCPs rules and procedures. These principles, international
standards and market protocols have been incorporated in the provisions of SKDD-CCPs
rules and other documents which regulate rights and obligations of SKDD-CCP, its members
and relevant third parties.
3. POSITION OF THE COMPLIANCE MONITORING FUNCTION WITHIN SKDD-CCP AND ITS Formatted: English (United States)
RELATION WITH OTHER SKDD-CCPs CONTROL FUNCTIONS
Measures for ensuring independence
Article 6
The Compliance Monitoring Function is an integral part of SKDD-CCPs internal control

system which consists of 3 (three) independent control functions:
1. Risk Management Function;

2. Compliance Monitoring Function;
3. Internal Audit Function.
Independence of the Compliance Monitoring Function is ensured by it being systemised as a

separate function independent from other functions and organisational units.
Relation with other SKDD-CCPs control functions
Article 7
The Head of Compliance Monitoring actively cooperates with other SKDD-CCPs control
functions in such a way that control functions inform each other on the findings relevant for
risk monitoring from their scope of responsibility.
Informing referred to in paragraph 1 of this Article is performed by submitting regular reports

on the findings relevant for risk monitoring, organisation of regular meetings, etc.
4. ANNUAL WORK PLAN
Adoption method
Article 8
By 31 March at the latest, the Head of Compliance Monitoring adopts an annual work plan
(hereinafter: the Plan) which is based on a documented risk assessment. By 15th December Formatted: No underline, Font color: Auto, English (United
the Head of Compliance Monitoring adopts annual work plan for the following year States), Superscript
(hereinafter: the Plan) which is based on a documented risk assessment. Formatted: English (United States)
The Head of Compliance Monitoring submits the Plan to SKDD-CCPs Management Board
for approval.
Contents of the Plan
Article 9
The Plan includes:
period of application of the Plan;

objective of the Plan;

relation with other SKDD-CCPs control functions;
the list of SKDD-CCPs organisational units to be included in the control;
description of planned control methods and procedures;
the list of risks to be controlled;
the list of business areas to be controlled;
calculation of capacity of the Compliance Monitoring Function;
risk identification;
estimation of the effects of changes in Relevant Regulations on SKDD-CCPs
business operations.
Operative Work Plans
Article 10
Based on the Plan, the Head of Compliance Monitoring delivers adopts Operative Work
Plans.
5. REPORTING SYSTEM
Semi-Annual Report on the Activities Formatted: Font color: Auto, English (United States)
Article 11
The Head of Compliance Monitoring prepares a Semi-Annual Report on the Activities and
submits it to SKDD-CCPs Management Board which then re-examines the adequacy of
procedures and efficiency of the Compliance Monitoring Function and supervises the
Compliance Risk management.
The Report from the previous paragraph of this Article contains:
report on the implementation of the Plan;

summary of the most important facts determined while conducting compliance
monitoring activities;
illegitimacies and irregularities, as well as defects and weaknesses determined while
conducting compliance monitoring activities;
report on the implementation of proposals and recommendations for the elimination of
illegitimacies and irregularities, as well as defects and weaknesses determined while
conducting compliance monitoring activities;
information on performed verification of compliance of new services and new
procedures with Relevant Regulations, standards, codes and internal documents, as
well as the evaluation of their impact on SKDD-CCPs exposure to risks;
estimation of costs of introducing measures and implementing proposals and
Recommendations for Harmonisation of the Compliance Monitoring Function;
defining of upcoming regulations that affect SKDD-CCPs business operations;
assessment of SKDD-CCPs compliance with valid Relevant Regulations, standards
and internal documents.
Based on the report from paragraph 1 of this Article, SKDD-CCPs Management re-examines
at least once a year SKDD-CCPs policy concerning compliance and its continuous
implementation, so as to evaluate the scope in which SKDD-CCP efficiently manages its

Compliance Risk. The Management Board is responsible for defining the Compliance Risk
management rules and adopting appropriate measures for eliminating noncompliance.
Annual Report on the Activities
Article 12
The Head of Compliance Monitoring prepares an Annual Report on the Activities and
submits it to SKDD-CCPs Management Board.
The report from the previous paragraph of this Article, in addition to the data stated in Article
11 of this Regulation, contains also a report on met obligations in the area of the
management of conflict of interest, in accordance with the provisions of the Regulation on
Measures for the Prevention of Conflict of Interest.
Special reports
Article 13
The Head of Compliance Monitoring prepares a special report which is submitted to SKDD-
CCPs Management Board and Supervisory Board in case illegitimacy in business operations
and/or potential noncompliance that jeopardises SKDD-CCPs business safety is determined,
primarily referring to illegitimacy or noncompliance that would lead to sanctions to SKDD-
CCP which might result in losing work permits or severe criminal and material sanctions.
The Head of Compliance Monitoring prepares a special report which is submitted to the
Supervisory Board in case illegitimacy and/or potential noncompliance is determined which is
not directly connected with the safety of SKDD-CCPs business activities, but which can have
big impact on SKDD-CCPs business operations in general.
Participation at staff meetings
Article 14
Person responsible for compliance monitoring participates at staff meetings held in SKDD-
CCPs Management Board, in accordance with the provisions of the Reporting Regulation.
6. TASKS OF THE HEAD OF COMPLIANCE MONITORING
Article 15
The Head of Compliance Monitoring performs the following tasks:
evaluates adequacy and efficiency of measures and activities in order to identify

and assess the Compliance Risk to which SKDD-CCP is exposed or could be
exposed, in accordance with the provisions of Articles 16 and 17 of this
Regulation;
administer and is responsible for the implementation of prepares policies and
procedures for Compliance Risk management established by senior management
and the board;
advises the Management Board and other responsible persons so as to achieve
compliance with EMIR, other Relevant Regulations and requirements of
Supervisory Authorities;

advises on the method of application of relevant laws, regulations, standards and

rules, and informs on recent developments in these areas;
estimates the effects that changes in Relevant Regulations will have on SKDD-
CCPs business operations, in accordance with the Plan;
verifies compliance of new services or new procedures with relevant laws and
regulations, as well as with changes to regulations;
supervises Employees work related to the compliance with EMIR and other
Relevant Regulations, which also includes Employees obligation to inform the
Head of Compliance Monitoring on circumstances important for supervision, upon
request by the latter;
regularly reports to the Management Board on compliance of SKDD-CCP and its
Employees work with the provisions of EMIR and other relevant laws and
regulations;
identifies and manages conflicts of interest, monitors and supervises the
implementation of measures introduced for the prevention of conflict of interest, in
accordance with the provisions of the Regulation on Measures for the Prevention
of Conflict of Interest;
supervises and ensures that relevant persons who participate in the Compliance
Risk management are not included in the provision of services and do not
participate in business activities that they supervise, and that each possible
conflict of interest of these persons is identified and eliminated in an appropriate
manner;
receives and records documentation on complaints of SKDD-CCP's members
and/or their clients, and supervises procedures, fulfilment of deadlines and
measures undertaken based on these complaints, in accordance with SKDD-
CCPs Complaints Handling Regulation;
submits Recommendations for Harmonisation;
trains Employees,
monitor and, on a regular basis, assess the adequacy and effectiveness of the Formatted: Font color: Auto, English (United States)
measures put in place to mitigate legal risk that can rise from potential conflicts of
law.. Formatted: English (United States)
Procedure of Compliance Risk identification and assessment
Article 16
Identification and assessment of SKDD-CCPs Compliance Risk is conducted in accordance

with the Plan, generally once a year, and is expressed with a risk level which may be low,
medium and high.
In case adoption of a new regulation or amendment to an existing regulation significantly

affects a previously assessed risk level, in addition to the annual identification and
assessment of Compliance Risk stated in paragraph 1 of this Article, an extraordinary
Compliance Risk identification and assessment is performed.
In case a low risk is determined where no measures and/or sanctions have been foreseen,
potential financial loss is low, and the risk of reputation loss is negligible, no significant
actions of a competent SKDD-CCPs organisational unit have to be undertaken.
In case a medium risk is determined where measures and/or sanctions might be imposed on
SKDD-CCP, while a potential financial loss and the risk of reputation loss is moderate,
measures and actions for the purpose of harmonisation have to be proposed without delay.
In case a high risk is determined where measures and/or sanction are certain, and a
potential financial loss and the risk of reputation loss is high, measures and actions for the
purpose of harmonisation have to be proposed and SKDD-CCPs Management Board

informed without delay.
Article 17
Identification and assessment of the Compliance Risk is done based on the Questionnaire
for Compliance Risk Assessment (hereinafter: Questionnaire), which is submitted by the
person responsible for compliance to SKDD-CCPs Employees and Service Providers
Employees performing SKDD-CCPs tasks, not later than the beginning of October, for risk
assessment for a year following the year in which the Questionnaire is submitted.
Upon receiving filled out Questionnaires, the person responsible for compliance analyses
them and if needed, requests additional information from SKDD-CCPs Employees or
Service Providers Employees performing SKDD-CCPs tasks. After the conducted detailed
analysis and any additional explanations, the person responsible for compliance prepares a
Compliance Risk Identification and Assessment, which represents the basis for the
preparation of the Plan of the Compliance Monitoring Function for the following year. The
Plan of the Compliance Monitoring Function for the following year is submitted to SKDD-
CCPs Management Board and constitutes an integral part of SKDD-CCPs Business Plan
for the following year.
The person responsible for compliance may, regardless of the annual risk assessment,
request risk assessment at any time if circumstances indicate existence of risks which have
not been stated in the Questionnaire or if it is clear that due to changed circumstances, the
submitted assessment does not correspond to the actual situation.
Advising the Management Board and other responsible persons
Article 18
The person responsible for compliance advises the Management Board and other
responsible persons on the method of application of Relevant Regulations, and informs
about recent developments in these areas.
Article 19
In order to perform activities mentioned in the previous Article, the person responsible for
compliance monitors, on a daily basis, regulatory news published on official websites of the
Official Gazette, Government of the Republic of Croatia, Parliament of the Republic of
Croatia, Supervisory Authorities, EUR-Lex (eur-lex.europa.eu) and PRE-Lex (ec.europa.eu),
follows professional journals and literature, as well as other available sources of the
European legislation, for the purpose of recording Relevant Regulations, informing SKDD-
CCPs Employees and Service Providers Employees performing SKDD-CCPs tasks thereof,
so as to ensure timely implementation of regulations relevant to SKDD-CCPs business
operations.
Publications in regulatory news are submitted via e-mail to SKDD-CCPs Employees and
Service Providers Employees performing SKDD-CCPs tasks, in the form of Information,
Enquiry or Recommendations on Relevant Regulation, depending on the impact of regulatory
news on SKDD-CCPs business operations.
Evaluation of the effects of changes in Relevant Regulations on SKDD-CCPs business

operations

Article 20
The person responsible for compliance analyses the effect of new or modified regulations on
SKDD-CCPs future business operations and required changes that have to be introduced in
internal documents and methods of operation.
Evaluation of the effects of changes in Relevant Regulations starts with the identification and
assessment of the Compliance Risk to which SKDD-CCP is exposed or might be exposed
due to changes in Relevant Regulations, in accordance with the procedure described in
Articles 16 and 17 of this Regulation.
Depending on the risk level and effects that changes in Relevant Regulations have or might
have on SKDD-CCPs business operations, as well as the number of organisational units
which will be affected by these changes, the person responsible for compliance, together
with other persons within SKDD-CCP, proposes measures for implementing Relevant
Regulations in SKDD-CCPs business operations.
Verification of compliance of new services or new procedures
Article 21
The person responsible for compliance participates in the procedure for the verification of
compliance of new services or new procedures with Relevant Regulations, as well as with
changes in regulations. This verification procedure is conducted based on the corresponding
Procedure for the Introduction of New Services (change request, etc.).
Prevention of conflict of interest
Article 22
The person responsible for compliance participates in the procedure for the verification of
compliance with Relevant Regulations that define procedures and obligations of preventing
conflicts of interest. This verification procedure is conducted based on the Regulation on
Measures for the Prevention of Conflict of Interest.
Recommendation for Harmonisation
Article 23
If the Head of Compliance Monitoring determines, while performing compliance monitoring

activities, that a certain business process and/or activity or several activities have to be in
compliance with regulations or have to submit information to SKDD-CCPs Management
Board, the Head of Compliance Monitoring prepares a Recommendation for Harmonisation
which is submitted to the Management Board and competent SKDD-CCPs Employees.
The Recommendation for Harmonisation contains the designation of the business

process/activity with such an obligation, designation of the legal basis from which the
harmonisation requirement arises, description of the existing situation and deadlines for
harmonisation.
Procedures as recommended by the Compliance Monitoring Function
Article 24

The responsible person to whom the Recommendation for Harmonisation has been sent has
to confirm its receipt and send a written response within eight days from the day of receipt.
In case SKDD-CCPs Management Board accepts the Recommendation for Harmonisation,

the Head of Compliance Monitoring shall appoint Employees responsible for the
implementation of the proposed solution and determine a deadline by which the Employees
have to implement the proposed solution. After the deadline for the implementation of the
solution proposed in the Recommendation for Harmonisation expires, the Head of
Compliance Monitoring shall perform a review of the conducted procedure in accordance
with the Recommendation and inform SKDD-CCPs Management Board on the results of the
conducted review.
In case the responsible person to whom the Recommendation for Harmonisation has been
sent and/or SKDD-CCPs Management Board do not accept the Recommendation for
Harmonisation, the Head of Compliance Monitoring shall inform SKDD-CCPs Supervisory
Board without delay about the fact that the Recommendation for Harmonisation has not been
accepted.
Training of SKDD-CCPs Employees
Article 25
The Compliance Monitoring Function regularly organises and conducts training of SKDD-
CCPs Employees in areas of Compliance Risk management and conflict of interest
management.
7. FINAL PROVISIONS
Right to access data and information
Article 26
The Head of Compliance Monitoring accesses the overall documentation, records and
electronic databases so as to perform activities belonging to their responsibilities, including
the freedom to inform SKDD-CCPs Management Board and employees of SKDD-CCP,
including the persons engaged in line with Service Level Agreement SKDD-CCPs heads on
all irregularities and possible violations of regulations detected in their audits.
The person responsible for compliance monitoring shall keep confidential the information
obtained while performing their tasks and shall not make such information available to third
parties even when they stop performing their functions.
Validity of the Regulation
Article 27
This Regulation shall come into force on the date of its adoption.

ANNEX I Formatted: Font color: Auto, English (United States)

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Formatted Table
THE LIST OF RELEVANT REGULATIONS Formatted: Font color: Auto, English (United States)
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Numbering Style: 1, 2, 3, + Start at: 1 + Alignment: Left +
Aligned at: 0.25" + Indent at: 0.5", Pattern: Clear
(Background 1)
Formatted: Font: Bold, Font color: Auto, English (United
Pursuant to Article 1(1)(6) of the Compliance Risk Management Regulation, Relevant States)
Regulations are defined as regulations which regulate SKDD-CCPs business operations Formatted: Font color: Auto, English (United States)
and which are stated in the List of Relevant Regulations that is an integral part of this Formatted: Font color: Auto, English (United States)
Regulation.
The List of Relevant Regulations is not final and will be updated when necessary. Aligned at: 0.25" + Indent at: 0.5", Pattern: Clear
(Background 1)
Regulation Formatted: Font: Bold, Font color: Auto, English (United
States)
1. Implementation of Regulation (eu) no 648/2012 of the europeanEuropean parliament Formatted: Font color: Auto, English (United States)
and of the council of 4 July 2012 on OTC derivatives, central counterparties and trade
repositories Act
2. Regulation (eu) no 648/2012 of the europeanEuropean parliament and of the council Aligned at: 0.25" + Indent at: 0.5", Pattern: Clear
of 4 July 2012 on OTC derivatives, central counterparties and trade repositories (Background 1)
3. Decision on the documentation that is be attached with the Central Counterparty
Qualifying Holding Acquirement NotificiationNotification Formatted: Font: Bold, Font color: Auto, English (United
States)
4. Regulation (eu) no 575/2013 of the europeanEuropean parliament and of the Formatted: Font color: Auto, English (United States)
Ccouncil of 26 June 2013 on prudential requirements for credit institutions and Formatted: List Paragraph, Numbered + Level: 1 +
investment firms and amending Regulation (EU) No 648/2012 Numbering Style: 1, 2, 3, + Start at: 1 + Alignment: Left +
(Background 1)
5. Commission delegated Regulation (EU) No 153/2013 of 19 December 2012
supplementing Regulation (EU) No 648/2012 of the European Parliament and of the Formatted: Font color: Auto, English (United States)
Council with regard to regulatory technical standards on requirements for central Formatted: List Paragraph, Numbered + Level: 1 +
counterparties Numbering Style: 1, 2, 3, + Start at: 1 + Alignment: Left +
(Background 1)
Formatted ...
Council with regard to regulatory technical standards on capital requirements for Formatted: Font color: Auto, English (United States)
central counterparties Formatted: Font color: Auto, English (United States)
Formatted ...
Formatted ...
Council on OTC derivatives, central counterparties and trade repositories, with regard Formatted: Font color: Auto, English (United States)
to regulatory technical standards specifying the data to be published and made Formatted: Font color: Auto, English (United States)
available by trade repositories and operational standards for aggregating, comparing Formatted ...
and accessing the data Formatted ...
8. Commission delegated Regulation (EU) No 150/2013 of 19 December 2012 Formatted: Font color: Auto, English (United States)
supplementing Regulation (EU) No 648/2012 of the European Parliament and of the Formatted: Font color: Auto, English (United States)
Council on OTC derivatives, central counterparties and trade repositories with regard Formatted ...
to regulatory technical standards specifying the details of the application for Formatted: Font color: Auto, English (United States)
registration as a trade repository
Formatted ...
Formatted ...
Compliance Risk Management Regulation Formatted ...
Formatted ...
Formatted ...
Formatted ...
Formatted ...
Council with regard to regulatory technical standards on indirect clearing
arrangements, the clearing obligation, the public register, access to a trading venue, Formatted ...
non-financial counterparties, and risk mitigation techniques for OTC derivatives Formatted ...
contracts not cleared by a CCP Formatted ...
Formatted ...
Formatted ...
Council on OTC derivatives, central counterparties and trade repositories with regard Formatted ...
to regulatory technical standards on the minimum details of the data to be reported to Formatted ...
trade repositories Formatted ...
Formatted ...
11. Commission implementing Regulation (EU) No 1249/2012 of 19 December 2012
laying down implementing technical standards with regard to the format of the records Formatted ...
to be maintained by central counterparties according to Regulation (EU) No 648/2012 Formatted ...
of the European Parliament and of the Council on OTC derivatives, central Formatted ...
counterparties and trade repositories Formatted ...
12. Capital Market Act (Official Gazette 88/08, 146/08, 74/09, 54/13, 159/13,18/15) Formatted ...
Formatted ...
13. Notaries Public Act (Official Gazette 78/93, 29/94, 162/98, 16/07, 75/09) Formatted ...
14. Act on Execution of Cash Assets (Official Gazette 91/10, 112/12) Formatted ...
Formatted ...
15. Ordinance on Unified Registry of Accounts (Official Gazette 96/10, 130/10, 99/11, Formatted ...
6/13, 156/13)
Formatted ...
16. Act on Resolution of Conflicts of Law with Regulations of Other Countries in Formatted ...
Certain Relations (O.G. SFRY 43/82, 72/82, Official Gazette 53/91, 88/01) Formatted ...
Formatted ...
17. Act on the Personal Identification Number (Official Gazette 60/08)
Formatted ...
18. Ordinance on the Personal Identification Number (Official Gazette 60/081/09, Formatted ...
117/10, 125/2013, 31/2015) Formatted ...
19. Labour Act (Official Gazette 149/09, 61/1193/14) Formatted ...

Formatted ...
20. Occupational Health and Safety Act (Official Gazette 59/96, 94/96 corr.114/03 Formatted ...
and 100/04 s.Art. 82 of the Act on Amendments to the Building Act expired
Formatted ...
provision of Art. 94(1), (2) and (4) of the Occupational Health and Safety Act 86/08,
116/08 s.Art. 70 of the State Inspectorate Act expired Art. 94 (3) and (5), Art. 95 Formatted ...
and Art. 96 of the Occupational Health and Safety Act 75/09); Official Gazette/143/12 Formatted ...
21. Ordinance on amendment of the Health and Safety Act (NN 154/14) Formatted ...
Formatted ...
22. Ordinance on Safety and Health Protection at Work with a Computer (Official
Formatted ...
Gazette 69/05).
Formatted ...
23. Civil Obligations Act (Official Gazette 35/05, 41/08, 125/11 s.Art. 9 of the Time for Formatted ...
Performance of Pecuniary Obligations Act expired Art. 174 of the Civil Obligations
Formatted ...
Act, 78/2015)
Formatted ...
24. Copyright and Related Rights Act (Official Gazette 167/03, 79/07, 80/11,125/11, Formatted ...
141/13, 127/14) Formatted ...
Formatted ...
25. Act on Ownership and Other Real Rights (Official Gazette 98, 137/99, 73/00,
114/01, 79/06, 141/06, 146/08, 38/09, 153/09, 143/12, 152/14, 81/2015-consolidated Formatted ...
Formatted ...
Formatted ...
Formatted ...
Formatted ...
Formatted ...
version) Formatted ...
26. Companies Act (Official Gazette 152/11 - consolidated text, Official Gazette 111/12, Formatted ...
68/13) Formatted ...
Formatted ...
27. Court Registry Act (Official Gazette 1/98, 30/99, 45/99, 54/05, 40/07, 91/10, 90/11,
Formatted ...
148/13, 93/14)
Formatted ...
28. Bankruptcy Act (Official Gazette 44/96, 161/98, 29/99, 129/00, 123/03, 197/03, Formatted ...
187/04, 82/06, 116/10, 25/12); Act on the Amendments to the Bankruptcy Act (Official Formatted ...
Gazette 133/12, 3 Dec 2012)
Formatted ...
29. Public Procurement Act (Official Gazette 90/11, 143/13) Formatted ...
Formatted ...
30. Decision on Adopting the Development Strategy for Electronic Public
Formatted ...
Procurement in the Republic of Croatia 2013 206 (Official Gazette 54/13)
Formatted ...
31. General Tax Act (Official Gazette 147/08, 18/11, 78/12, 136/12, 73/2013, 26/15) Formatted ...
Formatted ...
32. Decision on Unified Registry of Business Accounts (Official Gazette 14/02, 98/02,
10/05, 141/09) Formatted ...
Formatted ...
33. Decision on Conditions and Method of Cash Payments (Official Gazette 36/02) Formatted ...
34. Croatian Financial Services Supervisory Agency Act (Official Gazette 140/05, Formatted ...
154/11, 12/12) Formatted ...
Formatted ...
35. Financial Collateral Act (Official Gazette 76/07, 59/12)
Formatted ...
36. Credit Institutions Act (Official Gazette 117/08, 74/09, 153/09, 108/12, 54/13, Formatted ...
159/13, 19/15) Formatted ...
Formatted ...
37. Income Tax Act (Official Gazette 177/04, 73/08, 80/10 , 114/11, 22/12, 144/12,
43/13, 120/13, 125/13, 148/13, 83/14, 143/14) Formatted ...
Formatted ...
38. Act on Settlement Finality in Payment and Financial Instruments Settlement Formatted ...
Systems (Official Gazette 59/12)
Formatted ...
39. Prevention of Money Laundering and Terrorist Financing Act (Official Gazette Formatted ...
87/08, 25/12) Formatted ...
Field Code Changed ...
40. Act on Criminal Offences against Capital Market (Official Gazette 152/08)
Act on the Implementation of Regulation (EU) No 648/2012 of the European Field Code Changed ...
Parliament and of the Council of 4 July 2012 on OTC derivatives, central Field Code Changed ...
counterparties and trade repositories (Official Gazette 54/13)
Act on the Implementation of Regulation (EU) No 236/2012 of the European Field Code Changed ...
Parliament and of the Council of 14 March 2012 on short selling and certain aspects Field Code Changed ...
of credit default swaps (Official Gazette 54/13) Field Code Changed ...
41. Holidays, Memorial Days and Non-Working Days Act (Official Gazette 33/96, Field Code Changed ...
96/01, 13/02, 112/05, 59/06, 55/08, 74/11, 130/11) Field Code Changed ...
42. Act on the Verification of Signatures, Manuscripts and Transcripts (Official
Gazette 6/74, 47/09, 72/94)
Formatted ...
43. Act on Legalisation of Documents in International Traffic (O.G.SFRY 6/73, Formatted ...
Formatted ...
SKDD-CCP Smart Clear d.d. 15 Formatted ...
Formatted ...
Formatted ...
Formatted ...
Formatted ...
Formatted ...
Formatted ...
Formatted ...
Formatted ...
Formatted Table ...
Formatted ...
Formatted ...
Formatted ...
Formatted ...
Formatted ...
Formatted ...
Formatted ...
Official Gazette 53/91) Formatted ...
44. Regulation on the Manner of Keeping the Records of Personal Filing Systems Formatted ...
and the Pertinent Records Form (Official Gazette 105/04) Formatted ...
Formatted ...
45. Fire Protection Act (Official Gazette 92/10)
Formatted ...
46. Civil Procedure Act (Official Gazette 63/91, 91/92, 112/99, 88/01, 117/03, 88/05, Formatted ...
84/08, 96/08, 123/08, 57/11, 148/11, 25/13, 89/14) Formatted ...
Formatted ...
47. Enforcement Act (Official Gazette 139/10, 125/11, 150/11, 154/11, 12/12, 70/12,
112/12, 25/13, 93/14) Formatted ...
Formatted ...
48. Ordinance on the Manner and Procedure of Execution of Cash Assets (Official Formatted ...
Gazette 96/10, 99/11, 6/13)
Formatted ...
49. Ordinance on Types and Amounts of Compensations for Performing Activities Formatted ...
Stipulated by the Act on Execution of Cash Assets (Official Gazette 105/10, Formatted ...
124/11, 52/12 and 06/13) Formatted ...
50. Identification Number Act (Official Gazette 9/92 and 66/02) Formatted ...
Formatted ...
51. Ordinance on the Publication Method for the Labour Ordinance (Official Gazette Formatted ...
67/10, 146/2014)
Formatted ...
52. Ordinance on the Procedure of Selection of a Workers Council (Official Gazette Formatted ...
Formatted ...
53. Decision on the Determination of Salaries and Other Receipts of President and
Members of Companies Management Boards (Official Gazette 83/09, 3/11, 3/12, Formatted ...
46/12, 22/12, 25/14, 77/14) Formatted ...
Formatted ...
54. Regulation on Buildings Maintenance (Official Gazette 64/97)
Formatted ...
55. Act on Lease and Sale of Business Premises (Official Gazette 125/11) Formatted ...
Formatted ...
56. Ordinance on the Manner of Registration in the Court Registry (Official Gazette
Formatted ...
114/10, 22/12, 127/14)
Formatted ...
57. Regulation on Public Procurement Notices (Official Gazette 10/12) Formatted ...
Formatted ...
58. Ordinance on the Conditions for Applying the Common Procurement
Vocabulary (Official Gazette 6/12) Formatted ...
Formatted ...
59. Act on Notaries Public Fees (Official Gazette 72/94, 74/95, 87/96, 112/12) Formatted ...
60. Court Fees Act (Official Gazette 74/95, 57/96, 137/02, 26/03, 125/11, 112/12, Formatted ...
Formatted ...
61. Decision on the Manner of Opening Transaction Accounts
Formatted ...
62. (Official Gazette, No 3/2011, 35/2011, 50/2011, 89/2011, 101/2011 and 135/2011,
23/13, 10/14, 150/14) Formatted ...
Formatted ...
63. Ordinance on Types and Amounts of Compensations and Administrative Fees Formatted ...
of the Croatian Financial Services Supervisory Agency (Official Gazette 146/11,
Formatted ...
Official Gazette 52/12, Official Gazette 65/12, 69/12, 145/12, 112/13, 156/13, 40/14,
66/14,120/14, 151/14) Formatted ...
Formatted ...
64. Ordinance on the Calculation, Amount and Collection of Compensations Paid Formatted ...
Formatted ...
Formatted ...
Formatted ...
Formatted ...
Formatted ...
Formatted ...
Formatted ...
Formatted ...
Formatted ...
Formatted ...
Formatted ...
to the Croatian Financial Services Supervisory Agency for 20145 (Official Formatted ...
Gazette 1561/134, 6940/145)
Formatted Table ...
65. Ordinance on Amendments to the Ordinance on Types and Amounts of Formatted ...
Compensations and Administrative Fees of the Croatian Financial Services Formatted ...
Supervisory Agency (Official Gazette 90/13, 156/13) Formatted ...
Financial Collateral Act (Official Gazette 76/07, 59/12) Formatted ...
Formatted ...
Ordinance on Conditions for Members of Stock Exchange Management Board, on Formatted ...
Contents of Request and Documentation for the Issuance of Consent for
Formatted ...
Performance of Duties of a Management Board Member (Official Gazette 9/09)
Formatted ...
66. Ordinance on Criteria for the Stock Exchange Management Board Membership Formatted ...
and Procedure for Obtaining Approval for Such Membership (Official Gazette Formatted ...
117/13, 32/14)
Formatted ...
67. Financial Operations and Pre-Bankruptcy Settlements Act (Official Gazette Formatted ...
108/12, 81/13) Formatted ...
68. Regulation supplementing and amending Financial Operations and Pre- Formatted ...
Bankruptcy Settlements Act (144/12, 112/13)
Formatted Table ...
69. Ordinance on the Costs of Pre-Bankruptcy Settlements Procedure (Official Formatted ...
Gazette 5/13, 23/13) Formatted ...
Formatted ...
Regulation on Amendments to the Financial Operations and Pre-Bankruptcy
Settlements Act (Official Gazette 144/12, 112/13) Formatted ...
Formatted ...
70. Ordinance on Form and Content of the Request for Direct Carrier Billing (Official Formatted ...
Gazette 115/12, 127/14)
Formatted ...
71. Act on Amendments to the Postal Services Act (Official Gazette 88/09, 61/11, Formatted ...
153/13, 78/15) Formatted ...
Formatted ...
72. Ordinance on the Determination of Quota for Employment of Disabled Persons
(Official Gazette 44/14, 2/15) Formatted ...
Formatted ...
73. Ordinance on Types and Amounts of Compensations for Performing Activities Formatted ...
Stipulated by the Act on Execution of Cash Assets (Official Gazette 105/10,
Formatted ...
124/11, 52/12 and 06/13)
Formatted ...
74. Ordinance on Contents of Salary, Remuneration or Severance Pay Calculation Formatted ...
(Official Gazette 372/151) Formatted ...
75. Ordinance on the Content and Manner of Keeping Records on Employees Formatted ...
(Official Gazette 371/151) Formatted ...
Formatted ...
76. Rates of Interest Act (Official Gazette 94/04, 35/05 s.Art. 1164 (2) of the Civil
Formatted ...
Obligations Act expired provisions of Art. 1,2,4,5,6,7,9(1)(1) and 10 of the Rates of
Interest Act) Formatted ...
Formatted ...
77. Regulation on Buildings Maintenance (Official Gazette 64/97) Formatted ...
78. Auditing Act (Official Gazette 146/05, 139/08, 144/12) Formatted ...
Formatted ...
Time for Performance of Pecuniary Obligations Act (Official Gazette 125/11) Formatted ...
Formatted ...
Formatted ...
SKDD-CCP Smart Clear d.d. 17 Formatted Table ...
Formatted ...
Formatted ...
Formatted ...
Formatted ...
79. Accounting Act (Official Gazette 109/07, 125/11, 54/13, 12/14, 78/15) Formatted ...
80. Decision on Publishing International Financial Reporting Standards (Official Formatted ...
Gazette 136/09, 8/10, 18/10, 27/10, 65/10, 120/10, 58/11, 140/11, 15/12, 69/13) Formatted ...
Formatted ...
81. Decision on Publishing Croatian Financial Reporting Standards (Official Gazette
Formatted ...
30/08, 4/09, 58/11, 140/11)
Formatted ...
82. Ordinance on the Conditions for Applying the Common Procurement Formatted ...
Vocabulary (Official Gazette 6/12) Formatted ...
83. Profit Tax Act (Official Gazette 177/04, 90/05, 57/06, 146/08, 80/10, 22/12, 148/13, Formatted ...
143/2014) Formatted ...
Formatted ...
84. Ordinance on the Registry of Annual Financial Reports (Official Gazette
Formatted ...
49/03,41/04)
Formatted ...
85. Ordinance on Profit Tax (Official Gazette 95/05, 133/07, 156/08, 146/09, 123/10, Formatted ...
137/11, 61/12, 146/12, 160/13, 12/14) Formatted ...
86. Value Added Tax Act (Official Gazette 47/95, 106/96, 164/98, 105/99, 54/00, 73/00, Formatted ...
127/00, 48/04, 82/04, 90/05, 76/07, 87/09, 94/09, 22/12, 136/12, 148/13,143/2014) Formatted ...
Formatted ...
87. Ordinance on Value Added Tax (Official Gazette 79/13, 85/13, 160/13, and 35/14,
Formatted ...
157/14)
Formatted ...
88. Contributions Act (Official Gazette 84/08, 152/08, 94/09, 18/11, 22/12, 41/14, Formatted ...
89. Ordinance on Contributions (Official Gazette 2/09, 9/09, 97/09, 25/11, 61/12, Formatted ...
Formatted ...
90. Regulation on the Method of Making Payments of Contributions Assessed on
Formatted ...
the Basis of Salaries, Receipts from Salaries, and on the Monthly Basis for the
Calculation of Contributions Based on Employment (Official Gazette 49/2012, Formatted ...
Formatted ...
91. Act on the Collection of Data on Insured Persons Contributions for Mandatory
Formatted ...
Pension Insurances (Official Gazette 177/04, 90/11)
Formatted ...
92. Payment System Act (Official Gazette 133/09, 136/12) Formatted ...
Formatted ...
93. Decision on the National Clearing System (Official Gazette 14/02, 150/02, 18/09)
Formatted ...
94. Decision on the Croatian Large Value Payment System and the Settlement in Formatted ...
Bank Accounts Held with the Croatian National Bank (Official Gazette 35/05, Formatted ...
74/05, 18/09)
Formatted ...
95. Decision on the Rules of Operation of the Croatian Large Value Payment Formatted ...
System (Official Gazette 55/11, 20/14) Formatted ...
Formatted ...
96. Decision on the Rules of Operation of the National Clearing System (Official
Gazette 55/11, 20/14) Formatted ...
Formatted ...
Ordinance on Types and Amounts of Compensations and Administrative Fees of the Formatted ...
Croatian Financial Services Supervisory Agency (Official Gazette 146/11, 52/12,
Formatted ...
65/12, 69/12, 145/12, 112/13, 156/13, 40/14)
Formatted ...
Formatted ...
Formatted ...
Formatted ...
Formatted ...
Formatted Table ...
Formatted ...
Formatted ...
Formatted ...
Formatted ...
Ordinance on the Calculation, Amount and Collection of Compensations Paid to the Formatted ...
Croatian Financial Services Supervisory Agency for 2014 (Official Gazette 156/13,
Formatted ...
40/14)
Formatted ...
Ordinance on Amendments to the Ordinance on Types and Amounts of Formatted ...
Compensations and Administrative Fees of the Croatian Financial Services Formatted ...
Supervisory Agency (Official Gazette 90/13, 156/13)
Formatted ...
97. Discount Rate of the Croatian National Bank (Official Gazette 12, 73/12, 1/13, Formatted ...
1/14, 1/15, 73/15)) Formatted ...
Formatted ...
98. Ordinance on the Management of Waste Electrical and Electronic Appliances
and Equipment (Official Gazette 74/07, 133/08, 31/09, 156/09, 143/12, 86/13) Formatted ...
Formatted ...
99. Foreign Exchange Act (Official Gazette 96/2003, 140/05, 132/06, 150/08, 92 /09, Formatted ...
133/09, 152/09, 145/10,76/13)
Formatted ...
100. ReRegulation on Amendments to the Foreign Exchange Act (Official Formatted ...
Gazette 150/2008, Official Gazette 92/2009, Official Gazette 153/2009) Formatted ...
Formatted ...
101. Act on Amendments to the Foreign Exchange Act (Official Gazette
145/2010) Formatted ...
Formatted ...
102. Decision on Payment and Collection in Foreign Exchange Means of Formatted ...
Payment (Official Gazette 146/03, 195/03,111/2005,16/15)
Formatted Table ...
Decision on the Manner of Opening Transaction Accounts Formatted ...
(Official Gazette, Nos 3/2011, 35/2011, 50/2011, 89/2011, 101/2011 and 135/2011, Formatted ...
103. Ordinance on the Structure and Content of Annual Financial Reports Formatted ...
(Official Gazette 38/08, 12/09, 130/10) Formatted ...
Formatted ...
104. Ordinance on Electronic Submission of Tax Returns and other Data
Formatted ...
(Official Gazette 51/11, 61/11-correction)
Formatted ...
Formatted ...
Formatted ...
105. Ordinance on R-Sm Form (38/05, 42/05, 64/05, 73/05, 116/06, 135/06,
126/07, 135/09) Formatted ...
Formatted Table ...
106. Decision on reporting of hypothetical capital (129/2015) Formatted ...
Formatted ...
107. Decision on the Collection of Data on Revenues and Expenditures from
Service Exchange with Foreign Countries (Official Gazette 141/2009, 129/2010) Formatted ...
Formatted ...
108. Decision on the Collection of Data for the Preparation of Balance of Formatted ...
Payments, Foreign Exchange Debt Status and International Investment Status Formatted ...
(Official Gazette 103/12, 10/2014) Formatted ...
Formatted ...
109. Official Statistics Act (Official Gazette 103/2003, 75/2009, 59/12, 12/13)
Formatted ...
Formatted ...
110. Act on the Protection and Preservation of Cultural Goods (Official Gazette
Nos 69/99, 151/03, 157/03, 87/09, 88/10, and 61/11, 25/12, 136/12, 157/13, 152/14) Formatted ...
Formatted ...
Ordinance on the Costs of Pre-Bankruptcy Settlements Procedure (Official Gazette Formatted ...
Formatted ...
Formatted ...
Formatted ...
Formatted ...
Formatted ...
Formatted ...
Formatted Table ...
5/13, 23/13)
Regulation on Amendments to the Financial Operations and Pre-Bankruptcy Formatted: English (United States)
Settlements Act (Official Gazette 144/12, 112/13) Formatted: List Paragraph, Numbered + Level: 1 +
Ordinance on Form and Content of the Request for Direct Carrier Billing (Official Aligned at: 0.25" + Indent at: 0.5"
Gazette 115/12) Formatted: English (United States)
Ordinance on Contents of Salary, Remuneration or Severance Pay Calculation Numbering Style: 1, 2, 3, + Start at: 1 + Alignment: Left +
(Official Gazette 120/12) Aligned at: 0.25" + Indent at: 0.5"
111. Regulation of the Government of Croatia on Digital Information-
Documentation Office (Official Gazette 66/13) Numbering Style: 1, 2, 3, + Start at: 1 + Alignment: Left +
Aligned at: 0.25" + Indent at: 0.5"
Formatted: Font: Bold, English (United States)
Aligned at: 0.25" + Indent at: 0.5"
Formatted: Pattern: Clear (Background 1)

Compliance Risk Management Regulation - 21.12.2015

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COMPLIANCE RISK MANAGEMENT

Zagreb, NovemberDecember August 2015

Name Compliance Risk Management Regulation Formatted: English (United States)

Responsible person Formatted: English (United States)

Version 1.0 Formatted: English (United States)

Official document number, Formatted: English (United States)

Application start date Formatted: English (United States)

External/internal Formatted: English (United States)

Published on websites Formatted: English (United States)

Translation into English Formatted: English (United States)

Necessary consent Formatted: English (United States)

Formatted: English (United States)

Formatted: Font color: Auto, English (United States)

Formatted: Font color: Auto, English (United States)

Formatted: Font color: Auto, English (United States)

Formatted: Font color: Auto, English (United States)

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SKDD-CCP Smart Clear d.d. 1

1. GENERAL PROVISIONS .................................................................................................... 33

SKDD-CCP Smart Clear d.d. 2

Compliance Risk Management

1. Compliance Monitoring Function is a control function of SKDD-CCP which

- Regulation (EU) No 648/2012 of the European Parliament and of the Council of 4

- Commission Delegated Regulation (EU) No 148/2013 of 19 December 2012

- Commission Delegated Regulation (EU) No 149/2013 of 19 December 2012

- Commission Delegated Regulation (EU) No 150/2013 of 19 December 2012

to regulatory technical standards specifying the details of the application for

- Commission Delegated Regulation (EU) No 151/2013 of 19 December 2012

- Commission Delegated Regulation (EU) No 152/2013 of 19 December 2012

- Commission Delegated Regulation (EU) No 153/2013 of 19 December 2012

- Commission Delegated Regulation (EU) No 285/2014 of 13 February 2014

4. Service Provider is Sredinje klirinko depozitarno drutvo, dioniko drutvo

5. Employee is SKDD-CCPs employee and an employee of the Service Provider who

6. Relevant Regulations are regulations which regulate SKDD-CCPs business

The Regulation defines:

organisational structure, task, purpose and objective of the Compliance Monitoring

role of SKDD-CCPs Management Board related to the risk of noncompliance;

2. ORGANISATIONAL STRUCTURE, PURPOSE AND OBJECTIVE OF THE COMPLIANCE

Person performing compliance monitoring tasks

Person responsible for compliance monitoring:

a) supervises and coordinates implementation of the Compliance Monitoring Function in SKDD-

Formatted: Font color: Auto, English (United States)

Purpose and objective of the Compliance Monitoring Function

Measures for ensuring independence

The Compliance Monitoring Function is an integral part of SKDD-CCPs internal control

1. Risk Management Function;

Independence of the Compliance Monitoring Function is ensured by it being systemised as a

Relation with other SKDD-CCPs control functions

Informing referred to in paragraph 1 of this Article is performed by submitting regular reports

4. ANNUAL WORK PLAN

Contents of the Plan

The Plan includes:

period of application of the Plan;

objective of the Plan;

Operative Work Plans

The Report from the previous paragraph of this Article contains:

report on the implementation of the Plan;

SKDD-CCP Smart Clear d.d. 7

Annual Report on the Activities