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                                                                                                                   Contents
                                                                                                                   Contents

                                                                         Environmental, social
                                                      The Bank’s         and governance
                                                      governance                                                   Strategic Report
                                                      policies and
                                                      processes          Introduction
                                                      are set out
                                                      in detail on       The environmental, social and governance
                                                      pages 42 – 71      (ESG) agenda is a key focus for the Board,
                                                                         with regular debate and reports received
                                                                         from the Executive relating to environmental,
                                                                         community, and wider industry issues. The
                                                                         Bank’s governance policies and processes
                                                                         are set out in detail on pages 42 - 71.
            The Bank is pleased to report                                The Board recognises the importance of    Corporate Governance Statement

            the successful extension                                     the tone from the top so that the Board
 Decisions made during the year                                          culture to the Bank’s health and creates
 The Board reaffirmed the Bank’s current     ∞ Liquidity costs, greater commoditisation,   of its carbon neutral status   delivers on its responsibilities to all its various
                                                                         stakeholders, especially our customers.
 strategy, business structure, dividend   and the continued rise in deposit brokers
 policy and capital structure during 2021.   in both the retail and SME markets;  from 2020 to 2021.  Reducing our environmental impact
 The Bank’s strategy has remained broadly
 unchanged since it started trading in 2012     ∞ Long term trends in technology   Climate change is a significant challenge
 and has resulted in a balance sheet with   investment including IT data security and   facing society, with a growing focus for
 assets exceeding £1bn, with pre-tax profits   cyber security threats;  Other non-financial disclosures  all stakeholders, and the Bank continues
 in excess of £18m pa.                                                   to maintain a proactive approach to its
   ∞ Operational Resilience including the   The Bank has a moral, legal, and regulatory   environmental responsibilities. In 2021, the
 The Board has assessed the future   impact of Supplier/Outsourcing Risks;  duty to prevent, detect and deter financial   Bank collaborated with Lancaster University   Independent Auditor’s Report
 operating environment for the business and   crime and maintains a financial crime   Management School (LUMS) to further
 expects continued growth in profits, and     ∞ Geopolitical headwinds and post   framework. This framework is supported   advise how climate risk changes will impact
 ongoing investment in people and systems.   Brexit financial services equivalence   and reinforced by the Bank’s systems and   the Bank’s customer base, the properties
 The Bank’s strategic objectives remain   arrangements, trade negotiations, and   behaviours which put the customer at   on which it has lent money, and inform the
 unchanged. The Bank plans to continue to   the effects on UK business confidence;   the heart of every interaction. The Bank   environmental focus in the evolution of the
 grow and bring its products and services to   and  promotes an environment that protects its   Bank’s strategy.
 a wider geographical footprint and expand   customers, employees, and communities
 its lending activities into new asset classes     ∞ The increased focus on climate   from financial crime, and continues to   The Bank is currently focusing on
 where the existing capacity and capability   change risk.  invest in its Anti-Money Laundering (AML)   understanding the potential impact on
 of the Bank can be brought to bear,   and Know Your Customer (KYC) financial   its loan security values and customers’
 realising niche opportunities in markets   The number of newly launched niche   control system enhancements. The Bank’s   investments from increased flooding as
 that offer earnings at a level accretive to   challenger banks, together with an increase   compliance with requirements of the   well as potential new legislation relating to   Financial Statements
 those achieved in the core businesses.   in the non-banking participation in the   financial crime framework is monitored   minimum Energy Performance Certificate
 asset finance market, has over the past   through ongoing control testing, assurance,   gradings. The Bank’s initial analysis has
 The Bank’s future plans have been   few years also had a significant effect   audit, and the provision of management   concluded that its exposure to properties
 influenced by the following trends   on lending margins. This has inevitably   information at senior governance   in high flood risk areas in England is limited
 and risks:  continued to put pressure on the Bank’s   committees. The Bank’s Modern Slavery   to 13 properties. Properties financed by
 gross lending margins. We continue to   Statement (which is available on our   the Bank have a range of EPC gradings and
   ∞ Macroeconomic environment (bank   ensure that our customers enjoy rates that   website) sets out the policies we apply   the Bank is currently developing plans for
 base rate and property valuations) and   compare well with those that are currently   and actions we take to ensure that our   how it can work with customers to assist,
 the impact of Covid 19 and the Ukraine   on offer in the market. Margin compression   employees and customers are treated with   where required, in the upgrading of property
 conflict on the UK economy,   is expected to continue although we   dignity and respect. This includes raising   energy standards. The Bank achieved its
 remain confident that following the   awareness of issues that could put the   plans to be carbon neutral across its head
   ∞ Credit cycle impacts closely aligned   expansion of our geographic footprint   people the Bank comes into contact with at   office site in Leicester in 2019, and is pleased   Notes to the Financial Statements
 to the above and the risk of material   across the country, and investing in our   risks such as vulnerability and exploitation.   to report the successful extension of its
 property price erosion;  relationships with our broker introducers,   The statement also explains how we ensure   carbon neutral plus status from 2020 to
 we will meet our growth appetite at   that the Bank’s values are applied within our   2021 following inclusion of its two regional
   ∞ Changes in competition and   margins commensurate with the Board’s   supply chain including the due diligence we   offices, as independently verified by Carbon
 market demand;  credit risk appetite.  carry out on our suppliers.      Footprint Ltd.
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