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Legal, Compliance & Regulatory

Description The risk that non‑compliance with laws or regulations could give rise to
fines, litigation, sanctions, reputational damage, or financial loss

Governance Board Audit Committee Compliance & Legal Framework
Board Risk & Compliance Committee Data Protection Framework
Risk Management Committee Compliance Monitoring Framework
Risk Appetite The Bank maintains a low appetite for Legal, Compliance and Regulatory Risk. Whilst
Statement the Bank recognises that operational errors can occur, it maintains zero tolerance
for breaches of regulations, relevant legislation, late responses to regulatory requests
or gifts/hospitality policy breaches. The Bank strives to ensure that it always remains
within the law and regulation. All material breaches are investigated and reported to
the Risk & Compliance Committee in a timely manner, rule changes are implemented
within the applicable regulatory timelines and staff operate within the Bank’s
documented policies and controls and, where applicable, industry guidelines.
Key Mitigants Compliance monitoring of the Bank’s Maintaining a Whistleblowing
activities through an approved annual plan. procedure for staff to self‑report.
Undertaking detailed and regular reviews Horizon scanning to ensure continued
of key activities and processes via the adherence to regulatory requirements
second line oversight programme. & developments involvement with relevant
Provision of guidance in relation to business, trade bodies and other industry professionals.
product, and change management requests. Regular reviews of training content &
Ensuring appropriate registrations under oversight of the training & development of
the Senior Management and Certification staff to ensure up to date knowledge base.
Regime, second line oversight.
Maintaining logs of internal
compliance breaches, regulatory
breaches & conflicts of interest.
Comments Ensuring compliance with all applicable regulatory requirements in a complex and fast‑
changing landscape is a challenge to which the Bank devotes considerable resources,
and the Compliance and Data Protection Frameworks are continually under review
to ensure that they meet all requirements and is in line with industry practices.
Annual submission of the Data Protection Officers Report.
Approval of the Annual Compliance Monitoring Plan.
Annual Whistleblowing report.
Supporting the Whistleblowing Champion regarding annual reporting.