Page 72 - Demo

OMNES CAPITAL 3. SUSTAINABILITY IN OUR OPERATIONSGOVERNANCE POLICIES, PRACTICES, AND METRICSOversight Structure and AccountabilityThe executives of Omnes (the CEO and the Corporate Secretary) have primary responsibility for ensuring compliance with the legal, regulatory, professional, and ethical obligations applicable to the company and its employees. Day-to-day oversight of business conduct and adherence to the Code of Ethics is the responsibility of the Head of Compliance and Risk Management (Responsable de la Conformit%u00e9 et du Contr%u00f4le Interne, RCCI), who operates independently of the operational units and reports directly to the Corporate Secretary. This structural independence is a deliberate feature of the firm%u2019s governance design: by positioning the RCCI outside the operational hierarchy, Omnes ensures that risk and compliance assessments are objective and free from operational pressure.The internal control framework at Omnes operates across three levels. First-level controls are carried out by the operational teams on an ongoing basis. An additional first-level control operates on a continuous basis for some specific matters. Second-level controls