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38     Strategic Report                                                                                                                                                                                                             39








                                                                                                                                                                                                                                          Contents
                                                                                                                                                                                                                                          Contents

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


             Conduct         Conduct Risk    The Bank maintains a         ∞Monitoring of the   The Bank                              Financial      Model Risk      The Bank maintains a low     ∞Materiality assessment   The Bank’s     Strategic Report
                             Framework       low appetite for Conduct   Conduct Risk KPI’s     prides itself                         Models         Governance      appetite for Model Risk. We   for models at inception,   Model Risk
             The risk that                   Risk, employing a strategy                        on its strong                                        Framework       aim to minimise incidents   and annually thereafter  Governance
             customers       Customer        that is customer-centric,     ∞Complaints monitoring   risk culture                     The risk that   & Policy       and losses arising from model                     Policy
             suffer loss or   & Product      transparent and built on   and analysis           and focus                             the Bank incurs                risk issues by maintaining     ∞Regular independent   articulates the
             detriment due   Committee       integrity, professionalism and     ∞Customer surveys  on customer                       financial loss as   Model Risk   and operating within an   model validation      principles and
             to failures at   Risk           fairness, ensuring that all our                   outcomes. A                           a consequence   Governance     appropriate governance     for high/medium        standards for
             any stage of    Management      employees understand and     ∞Independent review   Conduct Risk                         of decisions   Committee       framework, supported by a   rated models          model use at
             the customer    Committee       fully operate within regulatory   of customer calls  Framework is in                    that could be   Risk           governance policy. We have     ∞Regular model self-  each stage of
             journey,                        requirements (including the     ∞Annual product reviews   place to ensure               principally    Management      a clear definition of a model   validation for low   its life cycle,
             including       Risk &          FCA Conduct Rules), further                       continued                             based on       Committee       and maintain an inventory of   rated models       with control
             inadequate      Compliance      the Bank’s Strategic Priorities     ∞Analysis of the   compliance                       the output                     all models within the Bank.                       and assurance       Corporate Governance Statement
             product design,   Committee     (including ‘maintaining a   ‘customer journey’    with all                              of (internal)   Risk &         We adopt a proportionate     ∞Ongoing model       requirements
             sales/marketing                 culture of ‘doing the right     ∞Annual report from the   requirements                  models, due    Compliance      risk-based approach        monitoring for         commensurate
             processes and                   thing’ for our customers and   Chief Risk Officer on   in this regard,                  to errors in the   Committee   according to the materiality   key models.        with the
             operational                     staff’ and ‘delivering clear   Conduct issues, feeding   including                      development,                   of each model, with specific     ∞End User Computing   model’s
             delivery, data                  and simple products’). All our   into the remuneration   detailed                       implementation,                requirements regarding model   (EUC’s) framework   materiality and
             management                      employees are responsible   policy and practice   reporting                             or use of such                 development, independent   enhancements –         level of risk.
             and record                      for proactively managing                          to the risk                           models.                        validation, approval,      requiring minimum
             keeping or                      Conduct Risk and maintaining     ∞Linkage of all variable   committees.                                                implementation, monitoring   standards for databases
             the failure of                  customer interests as      pay schemes to                                                                              and recommended
             its staff or key                the highest priority.      customer satisfaction                                                                       enhancements and future
             providers of                                               measures.                                                                                   developments. Oversight
             services, to act                                                                                                                                       is provided by the second
             with integrity                                                                                                                                         line of defence and the
             and treat the                                                                                                                                          quarterly Model Risk                                                  Independent Auditor’s Report
             customers’ best                                                                                                                                        Governance Committee.
             interests as the
             highest priority.                                                                                                                                                                                                            Financial Statements





































                                                                                                                                                                                                                                          Notes to the Financial Statements
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