VP & Chief Compliance Officer

The VP & Chief Compliance Officer ("CCO") is accountable for the design, implementation and operation of the organization's Regulatory Compliance Management Framework and associated compliance frameworks to safeguard the organization and support the attainment of strategic goals. Ensures compliance with applicable compliance-management-related regulatory requirements through appropriate policies, guidelines and processes. Works collaboratively with all lines of business and other corporate oversight groups to ensure a consistent and integrated approach is applied to compliance governance that aligns to the overall compliance management mandate and framework. As well, acts as Chief Privacy Officer ("CPO") and Chief Anti-Money Laundering Officer ("CAMLO").

The incumbent will play a key role in the following:

• Oversee compliance with laws, regulations and guidelines relevant to the activities of Alterna Savings and Alterna Bank ("Alterna") in the jurisdictions in which they operate.
• Through communication and collaboration, ensure all appropriate stakeholders are provided with current and accurate information to identify, assess, communicate, manage and mitigate regulatory compliance risk, and maintain knowledge of applicable regulatory requirements in operations.
• Using a risk-based approach, independently monitor and test the adequacy of, adherence to, and effectiveness of day-to-day compliance in operations. Obtain periodic assurance directly from stakeholders that they are maintaining processes and controls to assure continued regulatory compliance in their area of responsibility.
• As the CPO, provide accountability for Alterna's compliance with applicable laws, regulations, guidelines and policies relevant to the privacy activities of Alterna in the jurisdictions in which it operates, namely the Personal Information Protection and Electronic Documents Act ("PIPEDA") including the 10 principles set out in Schedule 1 of PIPEDA and provincial privacy laws as applicable.
• As the CAMLO, independently manage and operate Alterna's Anti-Money Laundering / Anti-Terrorist Financing (AML / ATF) regime and maintain the program in compliance with applicable laws, namely the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA), herein referred to as "the Act" and its regulations and guidelines relevant to the AML / ATF activities of Alterna in the jurisdictions in which it operates, including responsibility and accountability for regime content, design and enterprise-wide implementation.
• Provide accountability for Alterna's consumer protection policies, procedures and controls, including for Alterna Bank, compliance with the Financial Consumer Protection Framework and Alterna Bank's relationship with the Financial Consumer Protection Agency of Canada ("FCAC").
• Be aware of and communicate on any emerging issues in the compliance space including with respect to any upcoming legislation, regulations, or guidance that may be applicable to Alterna.

Major Responsibilities

Chief Compliance Officer

• Recognize the requirements of all regulations affecting Alterna. Identify and allocate ownership of compliance responsibility and maintain an inventory of such;
• Complete the activities included in the Mandate of the CAMLO with respect to the Act;
• Complete the activities included in the Mandate of the CPO with respect to PIPEDA;
• Develop a value driven and risk-based annual Compliance Plan including any compliance risks or control concerns identified by management and submit that plan to the Finance and Audit Committee for review and approval;
• Implement the annual Compliance Plan, as approved, including as appropriate any special tasks or projects requested by senior management and the Finance and Audit Committee;
• Develop or amend Alterna compliance policies, as new business activities impose different legislative requirements, and as efficiencies are actively discovered;
• Communicate new or amended compliance policies across Alterna on a timely basis;
• Collaborate with stakeholders to address and integrate significant legislative or regulatory requirements into the business activities of Alterna through appropriate procedural controls;
• Develop and implement written ongoing training programs for senior management, employees, agents and other persons authorized to act on Alterna's behalf as required;
• Manage consumer protection compliance at Alterna including: for Alterna Bank the relationship with the FCAC and the filing of all necessary reports on complaints, reputable compliance issues, governance etc. For Alterna Savings compliance with the Market Conduct Framework Guidance;
• Independently monitor adherence to applicable laws, regulations and guidelines across Alterna in order to ensure that significant issues are identified and brought to senior management's attention for timely resolution, as well as to support the CCO's opinion on the status of compliance;
• Review compliance practices regularly for continued effectiveness.

Chief Privacy Officer

• Maintain oversight of employees' compliance with privacy legislation, guidance, policies and procedures relating to the day-to-day collection, processing and disclosure of personal information in its possession or custody.
• Keep the privacy regime current relative to Alterna's identified inherent risks, including client and business relationships, products and delivery channels, geographic locations of operation and any other relevant risk factors;
• Ensure timely breach notifications are sent to affected parties and reported to the regulators;
• Implement an annual self-assessment of controls by monitoring adherence to applicable privacy laws, regulations and guidelines across Alterna, in order to ensure that significant privacy issues are identified and brought to senior management's attention for timely resolution;
• Develop and implement the annual privacy plan including anticipated responses to privacy gaps identified as a result of the self-assessments and other reviews.
• Develop or amend Alterna's written privacy policies, processes and practices for continued effectiveness or as legislation and regulation is introduced or amended, or as new business activities such as new products, services or business directions are introduced;
• Communicate new or amended operational privacy policies across Alterna on a timely basis, including information on how to contact the CPO.
• Ensure compliance with the procedures for employee personal information privacy.

Chief Anti-Money Laundering Officer

• Maintain oversight of AML / ATF control activities using a risk-based approach in all business areas at Alterna as a means to establish a reasonable threshold of control consistencies on an enterprise-wide basis;
• Keep the AML / ATF regime current relative to Alterna's identified inherent risks including member / client and business relationships, products and delivery channels, geographic locations of operation and any other relevant risk factors;
• Develop and implement an assessment of inherent ML / TF risks including being satisfied that new products, services, channels, clients, geographies, and technologies, as well as the processes and procedures associated with those elements are subjected to timely inherent risk analysis and appropriate measures are taken to control any identified risks;
• Develop and implement an annual self-assessment of controls by monitoring adherence to applicable AML / ATF laws, regulations and guidelines across Alterna, including other areas key to the AML / ATF control environment, in order to ensure that significant AML / ATF issues are identified and brought to senior management's attention for timely resolution, as well as to support the CCO's opinion on the status of AML / ATF compliance;
• Develop or amend Alterna's written AML / ATF policies, processes and practices annually for continued effectiveness or as legislation is introduced or amended, or as new business activities such as new products, services, technologies, or business directions are introduced;
• Develop and implement a written ongoing training program for senior management, employees, agents and other persons authorized to act on Alterna's behalf;
• Ensure that Internal Audit is aware of the requirement in the Act for effectiveness testing of the AML / ATF program at least every two years;
• Be satisfied that human and system resources are sufficient in all areas of Alterna for ensuring identification and reporting of unusual / suspicious transactions and unusual / suspicious attempted transactions as well as ensuring those processes that generate information used in reports to senior management and the Board are adequate and appropriate, use reasonably consistent reporting criteria and generate accurate information;
• Develop and implement the annual AML / ATF plan including any AML / ATF risks, control concerns or special tasks and projects identified or requested by management and submit that plan to senior management and the Board for review and approval.
• Communicate new or amended AML / ATF regulatory developments and internal policies across Alterna on a timely basis;
• Maintain an effective ongoing monitoring program using a risk-based approach;
• Maintain an effective reporting program to ensure the following reports are prepared and filed appropriately as per regulation and as per deadline by the Compliance department:
• Suspicious transactions and suspicious attempted transactions
• Large cash transactions
• Electronic funds transfers
• Terrorist property
• Compliance is managed to support the achievement of strategic objectives through prudent execution.
• All significant risks are identified and accurately reported; risk mitigation activities are monitored for progress / completion.
• Executive Leadership Team / Board have confidence in the effectiveness of the Compliance management framework and integrity of compliance management reporting.