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Second-tier senior officers: integrity screening
Published: 03 March 2016
Both the bank or insurer and DNB assess the integrity of second-tier senior officers. The institution will first investigate the integrity of managers that might influence their risk profile, and will subsequently send the outcomes of its own integrity assessment and a completed integrity screening form to DNB. We will then start up our supplementary integrity screening.
To perform their own integrity assessment an institution should use the following sources of information:
- Integrity screening form for second-tier senior officers; check that the form has been completed correctly and in full.
- Own systems, such as the incidents register of integrity breaches.
- Databases, such as the trade register of the Chamber of Commerce and any investigation into the personal or business financial background of the individual to be screened.
- Public sources, such as Google.
- Interview with the individual to gather more information and clarify any findings from own research if relevant.
To communicate their integrity assessment findings, institutions should use the ‘Company integrity screening’ form.
Screening by DNB
We will send the details of the individual to be screened to the tax authorities and to the National Public Prosecutor. We may also seek information from other financial regulators and criminal law authorities, as well as consult supervisory information. If we see a need, we will invite the individual to come in for an interview. Our processing time depends partly on the quality of the institution’s own integrity assessment. The more in-depth and comprehensive this is, the quicker our screening will be completed.
As soon as our investigations are complete, we will advise the institution of our integrity decision in writing and send a copy to the individual concerned. If our decision is negative we will first phone the individual and then advise the institution.
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