Page 36 - 86395_CCB - 2024 Annual Report (web)

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The Bank’s principal risks (continued):

Conduct

Description The risk that customers suffer loss or detriment due to failures at any stage of the customer
journey, including inadequate product design, sales/marketing processes and operational
delivery, data management and record keeping or the failure of its staff or key providers of
services to act with integrity and treat the customers’ best interests as the highest priority.

Governance Board Risk & Compliance Committee Customer & Product Committee
Risk Management Committee Conduct Risk Framework
Risk Appetite The Bank maintains a low appetite for Conduct Risk, employing a strategy that is customer‑
Statement centric, transparent, and built on integrity, professionalism, and fairness, ensuring that all
our employees understand and fully operate within regulatory requirements (including the
FCA Conduct Rules and Consumer Duty requirements). Furthermore, the Bank’s Strategic
Priorities (including ‘maintaining a culture of ‘doing the right thing’ for our customers
and staff’ and ‘delivering clear and simple products’) ensure all staff take responsibility for
proactively managing Conduct Risk, maintaining customer interests as the highest priority.

Key Mitigants Monitoring of the Conduct Risk KPIs. Annual report from the Chief Risk Officer
Complaints monitoring and analysis. on Conduct issues, feeding into the
remuneration policy and practice.
Customer surveys.
Linkage of all variables pay schemes to
Independent review of customer calls.
customer satisfaction measures.
Annual product reviews.
Embedding the Consumer Duty Regulatory
Analysis of the ‘customer journey’. requirements and enhanced reporting.
Comments The Bank prides itself on its strong risk culture and focus on customer outcomes. A Conduct
Risk Framework is in place to ensure continued compliance with all requirements in this regard,
including detailed reporting to the risk committees, incorporating Consumer Duty requirements.