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40     Strategic Report                                                                                                                                                                                                             41


            Emerging risks and uncertainties


            On a regular basis, the Bank will reassess the key risks to which it is exposed and add any                                                                                                                                   Contents
                                                                                                                                                                                                                                          Contents
            which are emerging, within the environment in which it operates. The Bank’s emerging risks
            during the year and at the time of the preparation of this document are assessed to be:
             Emerging Risk   Definition                               The Bank’s Response                                            Emerging Risk  Definition                               The Bank’s Response


             Global macro    As restrictions linked to Covid 19 are relaxed   The Bank monitors a range of current                   Operational    Securing Operational Resilience is a key   Operational Resilience and Supplier Risk   Strategic Report
             economic        there remains a risk of new waves/variants   andforward-looking measures covering                       Resilience     regulatory and operational requirement   Management arrangements have been
             outlook /       and the extent of subsequent Government   all susceptive risk types (primarily                                         such that the Bank can prevent, respond   significantly enhanced during 2021, including
             COVID-19        response. These may include temporary    operational, conduct, strategic, and credit).                                 to, recover, and learn from operational   Board approval of Important Business Services
                             staff shortages, supply-chain disruptions,   These are reviewed by management                                          disruptions. As several key IT services are   (IBS’s) and Impact Tolerances. Continual
                             increased forbearance arrangements.      and oversight forums on an ongoing                                            outsourced, including the Bank’s core    developments are being made and are subject
                                                                      basis, and appropriate responsive action                                      platform, satisfactory performance of    to Board and Executive level oversight.
                             The onset of the Ukraine conflict, and wider   undertaken. In mitigation to more severe                                its service providers is an essential part
                             associated geo-political risks, has increased   scenarios, documented arrangements are                                 of ensuring Operational Resilience.
                             this uncertainty primarily through the impact   in place for each of the Bank’s ‘Important
                             on energy and commodity prices and       Business Services’, and for each business                      Transformation  The Bank’s change agenda and investment   The risk is mitigated through a combination
                             potential supply disruptions, the impact of   area, identifying key points of failure and                              in operations transformation to deliver   of first-line management oversight,         Corporate Governance Statement
                             sanctions, and the potential for firms to adopt   management’s contingency arrangements.                               improved workflow and processing         including maintaining effective operating
                             a ‘wait and see’ approach to investment..                                                                              efficiencies is designed to deliver clear   structures, governance forums (Executive
                                                                                                                                                    business benefits. However, there remains   & Business Change Committees), and
             Hybrid Working   With the development of more flexible working  The Bank is focussed on maintaining a positive                         some risk of increased process errors,   Risk and Control Self-Assessments, and
             (Staffing)      arrangements hybrid working arrangements   culture, along with positive employee relations,                            due to the level of complexity and manual   second and third line assurance.
                             could create a new set of expectations   balancing both employer and employee                                          intervention in the product life cycle.
                             (both employer and employee) which could   needs. Regular staff feedback and surveys are
                             change the normal pattern of working.    undertaken to inform management’s approach.                    Cyber Threat   The nature of cyber-attacks across the   CCB’s technology infrastructure is UK
                                                                                                                                                    industry began to change during the      based and has a very small externally
             UK Macro-       As the impact of the pandemic unwinds    Macro-economic risk is considered as                                          pandemic with a greater proportion utilising   facing footprint, and the Bank’s websites
             Economic Risk   there remains some risk of economic      part of the Strategic Planning process                                        previously unseen malware or methods, as   are outside its perimeter, greatly reducing
                             uncertainties, impacting the Bank and its   and monitored via various reporting to                                     well as an increase in volume. More recently,   the inherent exposure. Furthermore, the
                             customer base, resulting in the potential for   Board and executive level committees.                                  the Ukraine conflict has led GCHQ and    Bank profile, suppliers, and customer-
                             the Bank being unable to achieve its business                                                                          the National Cyber Security Centre (NCSC   base does not make it an obvious           Independent Auditor’s Report
                             targets – (growth/credit risk related).                                                                                – the UK’s cyber watchdog) to warn of a   target for state-sponsored hackers.
                                                                                                                                                    potential increase in cyber risk, as disruptive
                             Additionally, there remains a risk in relation                                                                         attacks against organisations in Ukraine   The Bank’s technology perimeter has
                             to the broader economic pressures                                                                                      may ‘spill over’ into supportive countries.  been reviewed without issue, and
                             on the UK, including inflation risk.                                                                                                                            patching timescales are as aggressive
                                                                                                                                                    CCB’s operations are inherently reliant   as possible. Technology arrangements
             Development     The risk that pursuing the business growth   The key mitigant will be management                                       upon its technology infrastructure, and the   have been reviewed against the NCSC
             of the 2021+    targets outlined in the most recent Strategic   judgement, supported by Board oversight                                performance of third-party technology    guidance, and no deficiencies or areas
             Growth Plan     Plan will bring additional operational   in areas including due diligence,                                             firms to maintain cyber security defences.  for improvement were identified.
                             pressures and create increased risk, either   management competency, and
                             Credit Risk or Operational/Fulfilment Risk.  ensuring that the Bank recruits sufficient                                                                         Advice has been taken from CCB’s new Board   Financial Statements
                                                                      resources/skills to manage the risk.                                                                                   advisory cyber experts, and the new OT and
                                                                                                                                                                                             operational consultancy, regarding this risk.
             Climate Change  Climate Change is a growing risk and ongoing   This is a topic that the Bank takes very                                                                         Current arrangements, including technical
                             consideration needs to be given to the   seriously and has conducted a detailed report                                                                          resiliency (firewalls, monitoring, patching,
                             longer-term impacts, particularly in relation   in response to the PRA’s Climate Change                                                                         etc.), staff training, documented and tested
                             to the loan portfolio. If left unchecked, will   Requirements and plans for firms to manage                                                                     recovery plans, and scenario playbooks,
                             lead to a medium/long term risk to the credit   these risks. The Environmental, Social &                                                                        meet the recommendations received.
                             quality of the book because of extreme   Governance (ESG) Steering Committee,
                             climate events such as flood risk and poor   chaired by the Chief Risk Officer, continues
                             preparedness and lack of attention given   to develop the Bank’s action plans, in addition            The Strategic report on pages 4 - 41 was approved, by order of the Board.
                             to this risk by the property industry (which   to working with external bodies, such as
                             continues to tolerate low EPC grades) and   UK Finance, to assess sector preparedness,                                                                                                                       Notes to the Financial Statements
                             impact on the Asset Finance and Classic   planning and actions to ensure the Bank’s
                             Vehicles and Sports loan (CV&S) books.   initiatives remain appropriate and relevant.
                             Both physical and transitional risks are being   Regular progress reports are provided to             Richard Bryan
                             factored into Risk Appetite, Key Risk Indicators,  key stakeholders, including the Board.             Company Secretary
                             and the credit grading model calculation.
                                                                                                                                   12 April 2022
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