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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