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40  Strategic Report                                                                                            41


 Emerging Risks and Uncertainties


 The Bank regularly reassesses the key risks to which it is exposed including any 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‑  The onset of the Ukraine conflict, and wider   The Bank monitors a range of current   Cyber Threat  The nature of cyber-attacks across the   The Bank’s technology infrastructure is
 economic   associated geo-political risks, has increased   and forward-looking measures covering   industry continues to change with the use   UK based and has a very small externally
 outlook  uncertainty in supply-chain disruption   all susceptive risk types (primarily   of more sophisticated unseen malware or   facing footprint, and the Bank’s websites
 and increased forbearance arrangements   operational, conduct, strategic, and credit).   methods, as well as an increase in volume.  are outside its perimeter, greatly reducing
 primarily through the impact on energy   These are reviewed by management   the inherent exposure. Furthermore, the
 and commodity prices and potential supply   and oversight forums on an ongoing   The Bank operations are inherently reliant   Bank profile, suppliers, and customer-
 disruptions, the impact of sanctions, and   basis, and appropriate responsive action   upon its technology infrastructure, and the   base does not make it an obvious target
 the potential for firms to adopt a ‘wait   undertaken. In mitigation to more severe   performance of third-party technology firms   for state-sponsored or other hackers.
                                to maintain cyber security defences.
 and see’ approach to investment.  scenarios, documented arrangements are   The Bank’s technology perimeter has
 in place for each of the Bank’s ‘Important                            been reviewed without issue, and
 Business Services’, and for each business                             patching timescales are as aggressive
 area, identifying key points of failure and                           as possible. Technology arrangements
 management’s contingency arrangements.
                                                                       have been reviewed against the NCSC
 UK Macro‑  As the impact of the war in Ukraine and   Macro-economic risk is considered as   guidance, and no deficiencies or areas
 Economic Risk  other economic challenges, such as the cost   part of the Strategic Planning process   for improvement were identified.
 of living, rising interest rates etc continue,   and monitored via various reporting to   A Cyber Strategy and linked programme
 there remains some risk of economic   Board and executive level committees.  of focused work, including obtaining a
 uncertainties, impacting the Bank and its                             NIST Level 3 status, has begun and will
 customer base, resulting in the potential for                         continue throughout 2023 which includes
 the Bank being unable to achieve its business                         strengthening both Board and colleagues
 targets – both growth/credit risk related.
                                                                       understanding and ownership of Cyber
 These risks include broader economic                                  risk and the actions they need to take.
 pressures on the UK, inflation, and wider   Legal,   Proposed regulation relating to a Strong   We continue to monitor developments,
 economic uncertainty/recessionary   Compliance &   and Simple Regime along with Basel 3.1, is   as and when further clarity is provided,
 pressures, property price movements etc.
               Regulatory.      expected to have an impact on the Bank,   consideration is given to the impact for the
 Development   The risk that pursuing the business growth   The key mitigant will be management   including the capital holding requirements.  Bank. We also engage with the relevant trade
 of the 2023+   targets outlined in the most recent Strategic   judgement, supported by Board   bodies, as part of the wider industry response
 Growth Plan  Plan will bring additional operational   oversight in areas including due   to these proposed regulatory changes.
 pressures and create increased risk, either   diligence, management competency, and
 Credit Risk or Operational/Fulfilment Risk.  ensuring that the Bank recruits sufficient
 resources/skills to manage the risk.  The Strategic report on
 Climate Change  Climate Change is a growing risk and   This is a topic that the Bank takes very   pages 4 – 41 was approved,
 ongoing consideration needs to be given   seriously and has conducted a detailed report   by order of the Board.
 to the longer-term impacts, particularly   in response to the PRA’s Climate Change
 in relation to the loan portfolio. If left   Requirements and plans for firms to manage
 unchecked, it could lead to a medium/long   these risks. The Environmental, Social &
 term risk to the credit quality of the book   Governance (ESG) Steering Committee,
 because of extreme climate events such as   chaired by the Bank’s General Counsel
 flood risk and poor preparedness and lack   and supported by the Chief Risk Officer,   Richard Bryan
 of attention given to this risk by the property   continues to develop action plans, in addition   Company Secretary
 industry (which continues to see low EPC   to working with external bodies, such as   30 March 2023
 ratings) and impact on the Asset Finance   UK Finance, to assess sector preparedness,
 and Classic Vehicles and Sports (CV&S) loan   planning and actions to ensure the Bank’s
 books. Both physical and transitional risks   initiatives remain appropriate and relevant.
 are being factored into Risk Appetite, Key   Regular progress reports are provided to
 Risk Indicators, and broader lending activity.  key stakeholders, including the Board.
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