Page 120 - 86395_CCB - 2024 Annual Report (web)
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           •  Operational Risk                                 The ICAAP represents the Board’s risk
                                                               assessment for the Bank, and it is used by
              Operational Risk is the risk of direct or indirect   the Board, Management, and shareholders to
              loss arising from inadequate or failed internal   understand the levels of capital required to be
              processes, people and systems or from external   held over the short and medium term, and to
              events that cause regulatory censure, reputational   assess the resilience of the Bank against failure.
              damage, financial loss, service disruption and/or   Management presents regular reports on the
              customer detriment.
                                                               current and forecast level of capital to the
              The Bank’s objective is to manage Operational    Executive Committee, ALCO, Risk & Compliance
              Risk to balance the avoidance of financial losses or   Committee, and Board. The key assumptions and
              damage to the Bank’s reputation with overall cost   risk drivers used to create the ICAAP are regularly
              effectiveness and innovation. In all cases, Bank   monitored and reported, and any material
              policy requires compliance with all applicable legal   deviation from the forecast and risk profile of the
              and regulatory requirements.                     Bank would require the ICAAP to be reviewed.

              The Board of Directors has delegated responsibility   The Bank’s Total Capital Requirement (TCR) is
              for Operational Risk to the Risk & Compliance    set by its Regulator, the PRA. The Bank’s TCR
              Committee, which is responsible for the oversight   was 13.19% of Risk Weighted Assets (RWA)
              of the management of the full range of operational   at 31 December 2024. The Bank’s regulatory
              risks the Bank faces, including:                 capital at 31 December 2024 totalled £241.1m
                                                               (2023: £218.7m), (after IFRS 9 transitional
                 – People
                                                               relief). In addition to the TCR requirement
                 – Fraud                                       the Bank is required to hold additional capital
                                                               buffers, referred to as Pillar 2B, which includes
                 – Execution, delivery and process management
                                                               the Counter Cyclical Buffer and the Capital
                 – Information security and management         Conservation Buffer. The Capital Conservation
                                                               Buffer was 2.5% of RWA and the Counter Cyclical
                 – Technology and cyber security
                                                               Buffer was 2% of RWA in 2024.
                 – Model risk
                                                               As at 31 December 2024, the Bank’s regulatory
                 – Supplier risk                               capital consists of Tier 1 capital which includes
                                                               ordinary share capital, convertible loan notes,
                 – Change management/execution
                                                               retained earnings, reserves, and deductions for
                 – Employment practices and workplace safety   intangible assets as well as £5m of tier 2 capital.
                                                               The Bank’s intangible assets as at 31 December
                 – Conduct
                                                               2024 are fully deducted from CET1 (Common
                 – Operational Resilience                      Equity Tier 1) capital.

                 – Environmental risk                        •  Impact of IFRS 9 on capital planning
              The Bank uses various tools to monitor its exposure   In June 2020, as part of the economic
              to Operational Risk, including Risk and Control Self   support initiatives implemented because of
              Assessments, monitoring of Operational Risk Events,   the COVID‑19 pandemic, the CRR ‘Quick Fix’
              scenario analysis and the use of key risk indicators.  package announced measures that enable banks
                                                               to reduce the impact on Tier 1 capital from
           31  Capital management                              increased expected credit losses in 2020 and
                                                               2021. The Bank elected to adopt this transitional
              The Bank manages its capital under the Capital   relief and informed its Regulator of this decision.
              Requirements Regulation (CRR) and Capital        The relief allowed the impact of increased
              Requirements Directive (together referred to as CRD   expected loss provision balances in stage 1 and
              IV) framework. The framework is enforced in the UK   stage 2 cases in 2020, 2021 and 2022 on CET 1
              by the Prudential Regulation Authority (PRA) who   regulatory capital, to be phased in over 5 years.
              sets and monitors capital requirements for the Bank.
                                                               The relief ended on 31 December 2024.
              The Bank’s policy is to maintain a strong capital   The Bank’s capital requirement is calculated
              base, to maintain investor and market confidence,   based on the gross exposures net of specific
              and to sustain the future development of the     provisions. The tables below set out the Bank’s
              business. The Board manages its capital levels for   capital resources at 31 December and reconciles
              both current and future activities, and documents   these resources to the Bank’s reported
              its Risk Appetite, and capital requirements as part   regulatory capital.
              of the Bank’s Internal Capital Adequacy Assessment
              Process (ICAAP). The Bank’s ICAAP was updated
              during the year and approved by the Board in
              July 2024 and reviewed by the Bank’s regulator
              in September 2024.
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