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34  Strategic Report                                                                                             35








                                                                                                                   Contents
                                                                                                                   Contents

 Principal Risk   Governance  Risk Appetite Statement  Key Mitigants  Comments  Principal Risk   Governance  Risk Appetite Statement  Key Mitigants  Comments


 Credit  Credit Risk   The Bank has a moderate     ∞Regular modelling of   Credit Risk   Legal,   Compliance   The Bank maintains a     ∞Provision of guidance   Ensuring   Strategic Report
 Management   appetite for Credit Risk   funding requirements   is one of the   Compliance &   Framework  low appetite for Legal,   in relation to business,   compliance
 The risk that   Framework  overall, maintaining   and interest rate   principal risks   Regulatory  Compliance and Regulatory   product, and change   with all
 counterparties   conservative parameters,   risk analysis  that the Bank   Compliance   Risk. Whilst we recognise   management requests  applicable
 fail to meet the   Lending   including a maximum LTV and   faces, given   The risk   Monitoring   that operational errors can   regulatory
 commitments   Protocols  a DSCR at a higher level than     ∞Compliance with   the nature of   that non-  Framework  occur, we maintain zero     ∞Ensuring appropriate   requirements in
 into which they   Credit   PRA requirements, focusing   detailed Risk Appetite   its business.   compliance   Risk   tolerance for reportable   registrations under the   a fast-changing
 have entered   Committee  on relationship management,   and Lending Protocol   The lending   with laws or   Management   breaches of regulations,   Senior Management   landscape is
 in a timely   including annual reviews.   parameters  portfolio   regulations   Committee  regulatory policy breaches,   and Certification   a challenge
 manner.  Risk &     ∞Quarterly Stress Testing   is closely   could give   breaches of applicable laws,   Regime through   to which the
 Compliance   We will maintain the Bank’s   of the loan portfolio  monitored   rise to fines,   Risk &   late responses to regulatory   second line oversight  Bank devotes
 Committee   litigation,     Compliance
 lending distribution and   via a suite   Committee  requests or gifts/hospitality     ∞Maintaining logs of   considerable   Corporate Governance Statement
 Environmental,   product offering within     ∞Segregation of   of detailed   sanctions,   policy breaches. We strive to   internal compliance   resources,
 Social &   parameters agreed by the   responsibility for   metrics,   reputational   ensure that we always remain   breaches, regulatory   and the
 Governance   Board, diversified by sector   the management of   including   damage or   within the law and regulation.   breaches & conflicts   Compliance
 loans and a program
 (ESG)   and UK region, with a minimal   of underwriting from   Concentration,   financial loss.  Regulatory Changes (Horizon   of interest  Framework
 Committee  appetite for ‘speculative’   business development   Breaches and   Scanning) are logged,   is continually
 lending. These ensure that we   Exceptions,   allocated, monitored, and     ∞Horizon scanning   under review
 Model Risk   and sales  Asset Quality                                  to ensure continued    to ensure that
 Oversight   concentrate lending on areas     ∞Use of seasoned   and Treasury   tracked ensuring additions   adherence to regulatory   it meets all
 Committee  where we have experienced        to or changes within       requirements &
 subject matter experts both   professionals with   Counterparty   regulatory requirements   developments  requirements
 in the first and second line of   deep subject matter   Indicators, and   are proportionately applied.   and is in line
 defence, with the necessary   expertise, experience,   via the use of   All material breaches are     ∞Regular reviews of   with leading
 operational capacity,   and ongoing training  credit grading   investigated and reported   training content &   industry
 systems, and infrastructure     ∞Quality Assurance   models. Stress   to the Risk & Compliance   oversight of the training   practices.  Independent Auditor’s Report
 to effectively manage and   checks to ensure   testing is   Committee in a timely   & development of
 monitor the loans through   adherence to policies   employed to   manner, rule changes   staff to ensure up to
 their life cycle. We will operate   and procedures  ensure that   are implemented within   date knowledge base
 within protocols, underwriting   sufficient   the applicable regulatory
 guidelines, exception limits     ∞ Use of the Credit   capital is   timelines and staff operate
 and regulatory guidelines   Grading Models as part   maintained.  within the Bank’s documented
 and manage the Early   of the approval process,   policies and controls
 Warning Report and Watch   refreshed monthly,   The Bank   and, where applicable,
 List proactively to ensure   allowing the portfolio   continues to   industry guidelines.
 that asset quality remains   to be monitored on   assess the
 satisfactory. We will not   an ongoing basis.   potential
 chase growth at the expense     ∞Conducting annual   impact of                                                    Financial Statements
 of credit and asset quality.   reviews to ensure   climate change
 Although we recognise that   monitoring throughout   and the
 through the full economic   the facility lifecycle  environmental
 cycle, some credit losses   factors
 are inevitable, our robust     ∞Close monitoring   across its
 underwriting standards aim   of non-performing   loan portfolio
 to minimise them, with close   loans, including Early   as well as
 monitoring of risk appetite   Warning Report, Watch   undertaking
 on a monthly basis via the   List, Forbearance, and   appropriate
 comprehensive suite of KRIs.  management of arrears  stress testing.

   ∞Detailed provisioning                                                                                          Notes to the Financial Statements
 requirements and
 procedures
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