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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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