Instruction No. 002-06-2016 of June 9, 2016 on the Implementation Modalities for an Internal Control System by Credit Information Bureaus

The Governor of the Central Bank of West African States (BCEAO), Having regard to the Treaty of the West African Monetary Union (WAMU) of January 20, 2007, particularly Article 34; Having regard to the Statutes of the Central Bank of West African States, annexed to the WAMU Treaty of January 20, 2007, particularly Articles 30 and 59; Having regard to the Uniform Act regulating Credit Information Bureaus in the member states of WAMU, particularly Articles 29, 41, 64 and 76, DECIDES

Article 1: Subject Matter This Instruction specifies the implementation modalities for an internal control system by Credit Information Bureaus within WAMU.

Article 2: Objectives and Components of the Internal Control System The internal control system of Credit Information Bureaus must be adapted to the specific characteristics of their activities. It aims to ensure: – the definition of assessment rules and risk management, particularly technological risks; – the regular verification of compliance of the organization, operations performed and internal procedures with applicable legislative and regulatory provisions, professional and ethical standards and practices, as well as the orientations and decisions of deliberative and executive bodies, particularly regarding risk; – the quality of the process for collecting, processing, storing, disseminating and archiving customer information.

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INSTRUCTION NO. 002-06-2016 ON THE IMPLEMENTATION MODALITIES FOR AN INTERNAL CONTROL SYSTEM BY CREDIT INFORMATION BUREAUS

The internal control system comprises an Internal Audit Unit and an Audit Committee.

Article 3: Internal Audit Unit The Internal Audit Unit, directly attached to the executive body, has in particular the following functions: – to develop and maintain an internal control procedures manual that specifies the organization and objectives of internal control as well as the resources dedicated to this function; – to assess compliance with established policies and procedures, as well as conformity with applicable laws and regulations.

Article 4: Composition of the Audit Committee The Board of Directors of the Credit Information Bureau establishes an Audit Committee composed of at least three members. These members are designated in particular among non-employee directors or persons whose contribution is deemed useful to the proper functioning of the Audit Committee. Members of the Audit Committee must in particular: – have a good knowledge of the activities of Credit Information Bureaus; – have the ability to analyze basic financial statements; – understand the main financial risks and those inherent to the activity of Credit Information Bureaus, as well as the required controls.

Article 5: Functions and Operation of the Audit Committee The Audit Committee, under the supervision of the Board of Directors, is responsible for ensuring: – the monitoring of the implementation of the internal control policy; – the organization and operation of internal control and risk management systems. To this end, it assists the Board and reports to it on the implementation status of all recommendations deemed useful for the proper functioning of the Credit Information Bureau, particularly those formulated by supervisory authorities, internal auditors and external auditors. The Board of Directors of the Credit Information Bureau approves the Internal Regulations of the Audit Committee, which specify the operational modalities of said Committee.

Article 6: Reporting to the Central Bank Credit Information Bureaus submit to the BCEAO, by July 30 at the latest, a statement of anomalies identified during the first six months of the current year, within the framework of internal control, as well as proposed corrective actions.

Credit Information Bureaus prepare an annual internal control report submitted to the BCEAO no later than three months after the end of each year. The report submitted to the BCEAO must contain in particular: – the general overview of activities performed and risks incurred by the Credit Information Bureau; – significant modifications made to the organization of the internal control system of the Credit Information Bureau; – the governance of the Credit Information Bureau; – the results of periodic controls carried out during the previous financial year; – identified anomalies and the implementation status of corrective actions.

Article 7: Compliance with Rules and Sanctions Non-compliance with the rules provided by this Instruction is sanctioned, in accordance with the provisions of the Uniform Act regulating Credit Information Bureaus in the member states of WAMU.

Article 8: Entry into Force This Instruction enters into force on the date of its signature. It shall be published wherever necessary.

Done in Dakar, on June 9, 2016 Tiémoko Meyliet KONE