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32   Strategic Report                                                                                                                                                                                                             33


           The Bank’s principal risks:








            Principal Risk  Governance      Risk Appetite Statement   Key Mitigants          Comments                                 Principal Risk  Governance      Risk Appetite Statement  Key Mitigants           Comments

            Total Risk      Enterprise Risk   The Bank takes a        Monthly assessment     The Bank                                 Capital         Capital         The Bank maintains a     Maintaining a capital   The Bank
                            Management      conservative approach to   by the Chief Risk     monitors                                 Adequacy        Management      low appetite for Capital   surplus buffer exceeding   maintains and
            Total exposure
                            Framework       risk management, having   Officer of the Bank’s   its overall                                             Policy          Adequacy Risk. Our       minimum regulatory      monitors a
            to all types                    a low-risk appetite for all   overall risk profile,   risk profile                        The risk that                   priority is to maintain   requirements           robust capital
            of risk         Strategic Plan  risk types, apart from Credit   based on performance   closely via its                    the Bank        Asset & Liabilities   (via retained earnings)                    base, including
            in aggregate.                                                                                                             fails to hold   Committee                                Ongoing forecasting
                            Risk            Risk, for which its appetite   against appetite in all   governance                                                       a capital surplus above                          a management
                            Management      is moderate, operating    risk categories.       structure to                             sufficient      Risk &          CET1 and Total Capital   of capital requirements   buffer more
                            Committee       within strict parameters.                        ensure that it                           capital to meet   Compliance    requirements sufficient to   reported to risk    than regulatory
                                            There are certain types of                       remains within                           its regulatory   Committee      absorb any unexpected    committees.             requirements.
                            Risk &          risk to which the Bank does                      Risk Appetite, in                        obligations,
                            Compliance      not want any exposure (e.g.,                     alignment with                           support         Executive       losses and costs without   Quarterly stress testing
                            Committee                                                                                                 its growth      Committee       using regulatory buffers   Annual ICAAP,
                                            fraud), noting that instances                    its strategy.                                                            and ensure that the Bank’s
                                            can and do occur. The                                                                     plans or to     Board           capital base can support   incorporating regular
                                            Bank takes active steps to                                                                absorb shocks.                  a growing and maturing   stress testing of the
                                            minimise the possibilities                                                                                                book throughout the      capital base in ‘severe yet
                                            of such incidents arising                                                                                                 economic cycle, allowing   plausible’ scenarios.
                                            and strives to mitigate                                                                                                   for potential downturns.  Horizon scanning
                                            the impact when they                                                                                                                               to ensure continued
                                            happen, learning from any                                                                                                                          compliance with
                                            mistakes made.                                                                                                                                     regulatory requirements

            Strategic       Enterprise Risk   The Bank maintains a    Strategy debated at    The Bank                                 Liquidity &     Asset-Liability   The Bank maintains a   Measuring, managing,    The Bank
                            Management      low appetite for Strategic   the Board’s Strategy   has a clear                           Funding         Management      low-risk appetite for    and monitoring the risk   maintains
            The risk of     Framework       Risk. We aim to deliver   Day, including second   strategy, which
            having an                       a satisfactory return on   line challenge.       is monitored                             The risk of     Policy          Liquidity & Funding Risk.   over appropriate time   and monitors
            insufficiently   Strategic Plan  capital to our shareholders,                    effectively.                             being unable    Savings         We will maintain sufficient   horizons, including   its liquidity
            defined or      Risk            generating profitable     Ongoing discussion                                              to fund assets   Protocols      liquid assets to meet    intra-day               and funding
            flawed strategy   Management    returns and building gross   at risk committees                                           and meet                        liabilities as they fall due   Regular reforecasting of   requirements
            that does not   Committee       lending balances, whilst   and Board                                                      obligations     Asset & Liabilities   in a stressed scenario and   the liquidity positions  on a regular
            adapt to market                 retaining stable asset    Regular employee,                                               as they fall    Committee       always maintain a buffer,                        basis, including
            and business    Risk &          quality and maintaining a   broker, and                                                   due, without    Risk &          including satisfactory   Monitoring strict criteria   intra-day risk
            developments    Compliance      satisfactory cost of risk.   customer surveys                                             incurring       Compliance      liquidity coverage and loan   over the use of High   and maintains
            and/or meet the   Committee     We will achieve this within                                                               unacceptable    Committee       to deposit ratios. We will   Quality Liquid Assets  sufficient
            requirements    Executive       our stated Risk Appetite   Ongoing review of                                              losses.                         ensure that we are not   Annual ILAAP, including   liquidity
            and expectations   Committee    and regulatory guidelines   financial performance                                                         Liquidity       overly reliant upon any   stress testing of the   headroom to
            of our                          and deliver market        against budget                                                                  Contingency     single savings intermediary   liquidity base in ‘severe   ensure that
            stakeholders.   Board                                                                                                                     Plan            to raise deposits.       yet plausible’ scenarios.  the Board’s
                                            leading customer service,   Media monitoring/                                                                                                                              risk appetite
                                            demonstrated by above     engagement                                                                                                               Horizon scanning        and regulatory
                                            average new business      Demonstrations                                                                                                           to ensure continued     requirements
                                            margins and positive      of corporate                                                                                                             compliance with         are always met.
                                            customer experience. We   social responsibility                                                                                                    regulatory requirements
                                            aim to be an employer                                                                     Market
                                            of choice, ensuring that   Seeking B Corp                                                                 Interest Rate Risk   The Bank has no appetite   Scenario analysis  Market Risk
                                            we have the right mix of   Accreditation                                                  The risk that   in the Bank Book   for foreign currency risk   Use of natural balance   is limited
                                                                                                                                                                                                                       to Interest
                                            skills and experience to   Part of wider                                                  changes in      Policy          and a low appetite for   sheet hedges and        Rate Risk in
                                            grow the Bank. We work    ESG activities.                                                 market rates    Asset & Liabilities   interest rate and basis   derivatives when needed.  the Banking
                                            hard to protect our brand,                                                                negatively      Committee       risk keeping all assets,                         Book, which
                                            minimising reputational                                                                   impact the                      liabilities and off-balance   Monitoring of pipeline,   is monitored
                                            risk and play an active                                                                   earnings        Risk &          sheet exposures in       repayment profiles and   by the Bank’s
                                            and responsible part in                                                                   or market       Compliance      sterling and carefully   product maturities.     ALCO and a
                                            our community.                                                                            value of the    Committee       managing mismatches      Modelling a variety of   suite of Key
                                                                                                                                      Bank’s assets                   between tenors of loans   different yield curves/  Risk Indicators
                                                                                                                                                                      and deposits, hedging
                                                                                                                                      or liabilities.                                          interest rate paths.
                                                                                                                                                                      exposures where                                  and tested
                                                                                                                                                                      necessary within pre-                            via scenario
                                                                                                                                                                      determined limits.                               analysis.
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