TIDMVANQ

RNS Number : 9847V

Vanquis Banking Group PLC

12 April 2023

12 April 2023

Vanquis Banking Group plc ('Company')

Publication of 2022 Annual Report and Financial Statements and Notice of 2023 Annual General Meeting

The Company has today published the following documents:

   -      2022 Annual Report and Financial Statements; and 
   -      Notice of 2023 Annual General Meeting ('AGM'). 

In compliance with LR 9.6.1R, the 2022 Annual Report and Financial Statements and Notice of 2023 AGM have been submitted to the Financial Conduct Authority via the National Storage Mechanism and will shortly be available to the public for inspection at https://data.fca.org.uk/#/nsm/nationalstoragemechanism . These documents will also be available on the Group's website from today at: www.vanquisbankinggroup.com/shareholder-hub .

Annual General Meeting

The AGM will be held at 11.30 on Thursday 25 May 2023 at the offices of Clifford Chance, 10 Upper Bank Street, Canary Wharf, London E14 5JJ.

Additional information

A condensed set of the Company's financial statements and information on important events that have occurred during the financial year and their impact on the financial statements were included in the Company's results statement (RNS announcement dated 31 March 2023 ("Preliminary results for the year ended 31 December 2022")). That information, together with the information set out below constitutes the material required by DTR 6.3.5R. This announcement is not a substitute for reading the 2022 Annual Report and Financial Statements in its entirety. Page, note and section references below refer to the corresponding pages and/or notes/section in the 2022 Annual Report and Financial Statements.

Contact: David Whincup, (0)1274 351 344

Appendix

Principal risks

Principal risks

Principal risks are risks which are most significant to Vanquis Banking Group's strategy and business model and have formally been articulated as part of its Risk Appetite Framework. Principal risk categories and associated risk appetite statements are reviewed and approved by the Board on an annual basis, effectively defining Vanquis Banking Group's overall risk appetite.

 
P1 Capital risk 
-------------------------  ------------------------------------------------------------ 
Risk description           Mitigating activities and other considerations 
 The risk that               *    The Group and Bank maintain capital ratios in excess 
 the Group fails                  of regulatory requirements. The capital risk metrics 
 to maintain the                  are regularly monitored at Asset and Liability 
 minimum regulatory               Committee (ALCO), the Risk Committee and the Board, 
 capital requirements             and are subject to other internal management reviews. 
 and a management                 This includes ensuring that capital resources are 
 buffer on a consolidated         sufficient for planned changes in the balance sheet, 
 basis to cover                   and consideration of changes in the regulatory 
 risk exposures                   environment. On 8 March 2023 the Group announced an 
 and withstand                    update about our capital requirements from the PRA, 
 a severe stress                  following conclusion of its Capital Supervisory 
 as identified                    Review and Evaluation Process. The outcome was a 
 as part of the                   reduction in the Group's Total Capital Requirement by 
 Internal Capital                 more than a third, from 18.3% to 11.9%. 
 Adequacy Assessment 
 Process (ICAAP). 
                             *    In line with the PRA's requirements, the Group's 
                                  Internal Capital Adequacy Assessment Process (ICAAP) 
                                  is updated at least annually. Challenge and oversight 
                                  of the ICAAP occurs at ALCO and Risk Committee before 
                                  approval by Board. 
 
 
                             *    The 2022 ICAAP is the first assessment since the 
                                  closure of the Consumer Credit Division (CCD). As CCD 
                                  has been removed from the assessment, the associated 
                                  capital requirements have reduced. The ICAAP 
                                  demonstrated that the Group and Bank are more than 
                                  adequately capitalised. 
 
 
                             *    The methodology for assessing capital risks takes the 
                                  Pillar 1 requirements for credit, operational and 
                                  market risks as a starting point. The assessment then 
                                  considers whether the Pillar 1 requirement is 
                                  sufficient to cover management's own assessment of 
                                  the risks (such as credit concentration, operational, 
                                  pension and interest rate risk). Where it is 
                                  considered that additional capital is required, this 
                                  is held as a Pillar 2A requirement. The combination 
                                  of Pillar 1 and Pillar 2A requirements form the total 
                                  capital requirement (TCR). 
 
 
                             *    To protect against the risk of consuming Pillar 1 and 
                                  Pillar 2A requirements, firms are subject to 
                                  regulatory capital buffers. Where relevant a 
                                  firm-specific PRA buffer is also applied. 
 
 
                             *    The overall capital requirement (OCR) for the Group 
                                  and Bank is comprised of: (i) the TCR (covering 
                                  Pillar 1 and 2A) set by the PRA after review of the 
                                  ICAAP; (ii) the combined buffers; and (iii) a PRA 
                                  buffer set by the PRA. 
 
 
                             *    At 31 December 2022, the Group's CET1 ratio was 26.4% 
                                  (2021: 29.1%), the TCR was 37.5% (2021: 40.6%) and 
                                  the OCR was 21.8% (2021: 20.8%), excluding any 
                                  confidential buffers, if applicable. The Group and 
                                  Bank also monitors the Leverage Ratio which was 21.0% 
                                  (2021: 18.1%). By 1 January 2022, around 75% of all 
                                  transitional adjustments had been absorbed through 
                                  capital resources, with the remaining transitional 
                                  adjustment to be fully unwound on 1 January 2023. On 
                                  a fully loaded basis, the Group capital resources are 
                                  in excess of its capital requirement. 
 
 
                             *    In December 2021, the Financial Policy Committee 
                                  (FPC) announced an increase to the UK Countercyclical 
                                  Capital Buffer (CCyB) rate to 1%, to be implemented 
                                  by 13 December 2022. In July 2022, the FPC confirmed 
                                  a further expected increase to 2%, effective 5 July 
                                  2023. The impact of this on the Group's OCR is 
                                  expected to be partly offset by a confirmation from 
                                  the PRA that the temporary 0.56% buffer (being the 
                                  CET1 portion of the PS15/20 2A reduction) imposed due 
                                  to uncertainty arising from Covid-19 will be removed, 
                                  effective 31 December 2022. The Group and Bank 
                                  already have sufficient capital resources to fully 
                                  absorb the net increase of 1.44%. 
 
 
                             *    The Group and Bank have elected to adopt the 
                                  transitional adjustments for IFRS 9. The transitional 
                                  adjustments have historically had a material impact 
                                  on the Group's and Bank's regulatory capital position 
                                  due to high levels of provisioning. By 1 January 2022 
                                  around 75% of all transitional adjustments had been 
                                  absorbed through capital resources. With the 
                                  remaining transitional adjustment to be fully unwound 
                                  on 1 January 2023. 
 
 
                             *    Given the robustness of the Group's financial 
                                  position and the Group's first half performance, an 
                                  interim dividend was announced as part of the 2022 
                                  interim results. Prior to this the Group had not paid 
                                  a dividend since the 2019 interim dividend. 
 
 
                             *    If the Group or Bank was to encounter a significant 
                                  stress on capital resources, a Recovery Plan is 
                                  maintained which includes options to ensure that they 
                                  can remain sufficiently capitalised to remain viable. 
                                  Recovery Plan Early Warning Indicators (EWIs) and 
                                  Invocation Trigger Points (ITPs) are regularly 
                                  monitored and reported against. During 2022, the 
                                  Recovery Plan was enhanced to ensure compliance with 
                                  latest regulatory guidance, as well as ensuring that 
                                  all recovery options were appropriately considered. 
                                  The Group and Bank continue to have a wide range of 
                                  recovery options available. 
 
 
                             *    As part of the intra-group funding arrangement, a 
                                  Core UK Group (CUG) waiver was approved in November 
                                  2022 which allows Vanquis to utilise retail deposits 
                                  to fund the different parts of the Group, resulting 
                                  in lower cost of funds for the non-bank group. As 
                                  part of considerations over Vanquis Bank's CUG waiver 
                                  application, a Capital Support Agreement (CSA) was 
                                  granted by Moneybarn in favour of Vanquis Bank. The 
                                  CSA, in circumstances where Vanquis Bank is failing 
                                  to meet its solo capital requirements, requires 
                                  Moneybarn to contribute any excess capital, or 
                                  liquidity, it holds to Vanquis Bank. In addition, 
                                  Moneybarn was capitalised as if it were a regulated 
                                  entity, based on the Group's 2022 ICAAP. 
 
 
                             *    The Group's Pillar 3 disclosures contain a 
                                  comprehensive assessment of its capital requirement 
                                  and resources. Pillar 3 disclosures for the year 
                                  ended 31 December 2022 are published separately on 
                                  the Group's website, www.vanquisbankinggroup.com. 
-------------------------  ------------------------------------------------------------ 
 
 
P2 Funding and 
 liquidity risk 
------------------------    ------------------------------------------------------------ 
Risk description          Mitigating activities and other considerations 
 The risk that             *    Funding and liquidity risks are managed within a 
 the Group has                  comprehensive risk framework. This framework ensures 
 insufficient                   that the Group and the Bank maintain stable and 
 financial resources            diverse funding sources and a sufficient holding of 
 to meet its obligations        high-quality liquid assets such that there is no 
 (cash or collateral            significant risk that liabilities cannot be met as 
 requirements)                  they fall due. Funding and liquidity requirements are 
 as they fall                   regularly monitored to support the strategy of the 
 due, resulting                 Group and Bank. 
 in the failure 
 to meet regulatory 
 liquidity requirements,   *    Funding and liquidity risk is managed by the Group's 
 or is only able                Treasury function and is overseen by the ALCO Funding 
 to secure such                 and liquidity metrics are monitored daily through 
 resources at                   daily liquidity reporting and monthly at ALCO 
 excessive cost.                meetings. Metrics are also included in the 
                                information packs presented to the Group's ExCo, Risk 
                                Committee and Board. 
 
 
                           *    The primary metrics used to monitor and assess the 
                                adequacy of liquidity is the Overall Liquidity 
                                Adequacy Rule (OLAR) (which is the Board's own view 
                                of the Group and Bank liquidity needs as set out in 
                                the Board approved Internal Liquidity Adequacy 
                                Assessment Process (LAAP)), the Liquidity Coverage 
                                Ratio (LCR), and Net Stable Funding Ratio (NSFR). 
                                Liquidity is managed by working to ensure compliance 
                                with the most binding metric and is monitored on a 
                                solo and consolidated basis. 
 
 
                           *    During 2022, a significant amount of work was 
                                undertaken to update the ILAAP. The 2022 Board 
                                approved ILAAP is the first ILAAP prepared for the 
                                consolidated Group and excludes the CCD which was 
                                closed in December 2021. The ILAAP demonstrates that 
                                the Group and Bank have sufficient high-quality 
                                liquid assets to meet severe but plausible stress 
                                scenarios. 
 
 
                           *    Treasury conducts regular and comprehensive liquidity 
                                stress testing to ensure that the Group and Bank's 
                                liquidity position remains within the Board risk 
                                appetite. Stress testing covers idiosyncratic, 
                                market-wide and combined stress scenarios, including 
                                reverse stress testing. 
 
 
                           *    The Group and Bank have maintained liquidity ratios 
                                in excess of regulatory and internal requirements 
                                throughout the year and continue to hold significant 
                                levels of high-quality liquid assets (HQLA). The 
                                liquidity position was managed to more normalised 
                                levels following action that was taken during the 
                                Covid-19 pandemic. 
 
 
                           *    Throughout the year, the Bank has demonstrated that 
                                it continues to have access to the retail deposit 
                                market through fixed rate deposits. The Bank is 
                                seeking to widen the range of retail deposit products 
                                that it offers, increasing the pool of retail 
                                deposits it has access to as well as helping to 
                                alleviate upward movements in funding cost. 
 
 
                           *    Following the approval of the CUG waiver, retail 
                                deposits will provide most of the funding for the 
                                Group, resulting in lower cost of funds. Wholesale 
                                funding sources will be maintained to ensure 
                                diversity of funding sources and provide contingent 
                                funding options. 
 
 
                           *    If the Group or Bank was to encounter a significant 
                                stress on liquidity resources, a Recovery Plan is 
                                maintained which includes options to ensure that they 
                                can remain sufficiently liquid to remain viable. 
                                Recovery Plan Early Warning Indicators (EWIs) and 
                                Invocation Trigger Points (ITPs) are regularly 
                                monitored and reported against. During 2022, the 
                                Recovery Plan was enhanced to ensure compliance with 
                                latest regulatory guidance, as well as ensuring that 
                                all recovery options were appropriately considered. 
                                The Group and Bank continue to have a wide range of 
                                recovery options available. 
------------------------  -------------------------------------------------------------- 
 
 
P3 Market risk 
-----------------------    ------------------------------------------------------------ 
Risk description         Mitigating activities and other considerations 
 The risk that            *    Market risk is managed by the Group's Treasury 
 the net value                 function and is overseen by the ALCO. The Group and 
 of, or net income             Bank do not take significant unmatched positions and 
 arising from,                 do not operate trading books. 
 assets and liabilities 
 is impacted as 
 a result of changes      *    The Group and Bank use interest rate sensitivity gap 
 in market prices              analysis to inform the Group and Bank of any 
 or rates, specifically        significant unmatched positions. 
 interest rates, 
 currency rates 
 or equity prices.        *    The interest rate risk position is reported on a 
                               monthly basis to the ALCO and includes risk appetite 
                               metrics set for both earnings at risk (EaR) and 
                               market value sensitivity (MVS). These are assessed 
                               against a 100bps and 200bps parallel shift in rates 
                               respectively. 
 
 
                          *    The Group and Bank also monitor their exposure to 
                               economic value of equity (EVE), against a 200bps 
                               parallel shock in interest rates, as well as the six 
                               standardised shocks prescribed by the Basel Committee 
                               on Banking Supervision (BCBS). 
 
 
                          *    Throughout 2022, a significant amount of work has 
                               been undertaken to validate the interest rate risk 
                               position on a behavioural basis and introduce the 
                               capability to transact interest rate derivatives to 
                               manage the residual interest rate risk position. This 
                               culminated in the transaction of interest rate 
                               derivatives (SONIA linked) in the second half of the 
                               year. 
 
 
                          *    The Group and Bank monitor their exposure to basis 
                               risk, with Bank of England base rate and SONIA the 
                               only external reference rates used. The Group does 
                               not have any exposure to LIBOR. 
 
 
                          *    The Group continues to monitor potential implications 
                               for the strategy in response to financial market 
                               turbulence and undertakes reviews of product pricing 
                               to ensure it is consistent with markets and cost of 
                               funds. 
-----------------------  -------------------------------------------------------------- 
 
 
P4 Credit risk 
-----------------------    ------------------------------------------------------------ 
Risk description         Mitigating activities and other considerations 
 The risk of unexpected   *    Credit risk remains a key focus for the Group given 
 credit losses                 the current macroeconomic environment. 
 arising through 
 either adverse 
 macroeconomic            *    The Group continues to monitor the impact of the cost 
 factors or parties            of living crisis on portfolio performance, and 
 with whom the                 internal measures have been put in place to help 
 Group has contracted          mitigate potential risks. These include, but are not 
 failing to meet               limited to, alignment of creditworthiness assessments 
 their financial               to the latest official inflationary outlook, 
 obligations.                  production of targeted management information, and 
                               enhanced forbearance programmes. Ongoing executive 
                               focus is maintained through a Cost of Living Forum, 
                               jointly chaired by the CRO and the COO, together with 
                               standard Risk Committee reporting. 
 
 
                          *    The Group's credit risk appetite is under regular 
                               review by the Credit Committee and Risk Committee to 
                               ensure that it remains aligned to current market and 
                               economic conditions. 
 
 
                          *    A cross-functional working group is in place to 
                               create a centre of excellence for calculation of 
                               provisions under IFRS 9. The working group ensures 
                               that there are suitably skilled resources with clear 
                               accountabilities, effective governance arrangements, 
                               optimised models, aligned activities and effective 
                               management information and insights across the Group. 
 
 
                          *    Performance of risk models is being closely monitored 
                               by the Group, with adjustments implemented where any 
                               continued deviation from expected performance is 
                               evidenced. 
 
 
                          *    The Group continues to pursue opportunities to 
                               supplement existing data sources to enhance both 
                               credit and affordability risk, i.e. open banking. 
-----------------------  -------------------------------------------------------------- 
 
 
P5 Strategic 
 execution risk 
-------------------------    ------------------------------------------------------------ 
Risk description           Mitigating activities and other considerations 
 The risk of making         *    The Board and its sub-committees make risk-based 
 and/or executing                decisions in the formulation of their business 
 poor strategic                  strategy, in line with their Delegated Authority 
 decisions related               Framework and Risk Appetite Framework and subject to 
 to acquisitions,                independent oversight from the Risk function. 
 products, distribution, 
 etc. as a result 
 of ineffective             *    Board Governance Manual and Delegated Authorities 
 governance arrangements,        Matrix (DAM) is in place to provide a framework for 
 processes and                   key decision making at all levels across the Group. 
 controls. 
 
                            *    Executive director scorecards are in place, with 
                                 reward incentives based on a combination of financial 
                                 and non-financial measures. 
 
 
                            *    Group Risk Appetite Framework is in place with agreed 
                                 metrics and thresholds approved by the Board. 
 
 
                            *    Strategic and emerging risks are reported to the GEC 
                                 and GRC on any areas of concern. 
 
 
                            *    Risk overlay is completed annually by the Group CRO 
                                 on behalf of the Remuneration Committee (RemCo) to 
                                 provide recommendations on adjustments to variable 
                                 reward where governance has failed. 
-------------------------  -------------------------------------------------------------- 
 
 
P6 Climate risk 
--------------------------    ------------------------------------------------------------ 
Risk description            Mitigating activities and other considerations 
 The physical                *    Group-wide Climate Strategy and Policy is in place to 
 risk of the impacts              ensure appropriate governance, controls and processes 
 of climate change                are in place to support compliance with TCFD 
 and the business                 requirements and broader ESG strategy (including 
 risk posed to                    net-zero targets). 
 the Group and 
 its counterparties 
 related to non-compliance   *    Climate Risk Committee is in operation, supported by 
 costs and financial              Climate Risk and Environmental Working Groups, 
 loss associated                  facilitating the integration of climate 
 with the process                 considerations into the Group's broader Risk 
 of adjusting                     Management Framework through its reporting lines into 
 to a low carbon                  the Customer, Culture and Ethics Committee and Group 
 economy.                         Executive Committee. 
 
 
                             *    Quantitative Climate Risk Scenario Analysis and 
                                  Stress Testing Framework is in place to inform 
                                  forward-looking strategy, with scenarios proposed to 
                                  identify potential financial impacts of transition 
                                  and physical climate-related risks. ICAAP activity 
                                  continues to take account of material climate-related 
                                  financial impacts, meeting PRA requirements. 
 
 
                             *    The Group continues to offset its direct operational 
                                  carbon footprint via sustainable development projects 
                                  and all main Group premises maintain ISO 14001:2015 
                                  compliant status. 
--------------------------  -------------------------------------------------------------- 
 
 
P7 Legal and 
 governance risk 
--------------------------    ------------------------------------------------------------ 
Risk description            Mitigating activities and other considerations 
 The risk that               *    The Group simplified and strengthened its governance 
 the Group is                     structure by collapsing and consolidating the Vanquis 
 exposed to financial             Banking Group and VBL Board executive structures. 
 loss, fines, 
 censure or enforcement 
 action due to               *    Board Governance Manual and Group Delegated 
 failing to comply                Authorities Framework is in place, setting out key 
 with legal and                   decision making at all levels across the Group. 
 governance requirements 
 as a result of 
 ineffective arrangements,   *    Board effectiveness is assessed on an annual basis 
 processes and                    with action plans in place to promote a culture of 
 controls.                        continuous improvement. 
 
 
                             *    Explicit approval from the Board is required before 
                                  any decisions and actions are made that could result 
                                  in risks materialising outside of appetite. 
 
 
                             *    Conflicts of Interest Policy and processes are in 
                                  place to ensure all employees meet their fiduciary 
                                  responsibilities. 
 
 
                             *    All regulatory interactions are recorded and tracked, 
                                  with regular reporting through the executive and 
                                  Board committees to ensure consistency and read 
                                  across through a Group lens. 
 
 
                             *    The Group proactively engages with regulatory 
                                  authorities and industry bodies on forthcoming 
                                  regulatory changes. 
 
 
                             *    Governance arrangements are continuously reviewed to 
                                  ensure they are designed and operating effectively to 
                                  meet the Group's objectives. 
--------------------------  -------------------------------------------------------------- 
 
 
P8 Financial 
 crime risk 
-----------------------    ------------------------------------------------------------ 
Risk description         Mitigating activities and other considerations 
 The risk that            *    The Group is committed to operating a strong and 
 the Group's products          risk-proportionate set of systems and controls to 
 and services                  manage the risk within appetite. 
 are used to facilitate 
 financial crime 
 against the Group,       *    The second line Financial Crime Oversight team has 
 customers or                  been significantly enhanced with regards to capacity 
 third parties.                and capability. 
 
 
                          *    A revised Group-wide financial crime assessment 
                               approach established to set control requirements 
                               which define the standards by which financial crime 
                               risk will be managed. 
 
 
                          *    New AML, CTF and Sanctions Policy has been 
                               implemented which sets out control standards and 
                               requirements in line with the Group's Financial Crime 
                               Risk Assessment Methodology. 
 
 
                          *    Regulatory actions and notifications are monitored 
                               and managed in line with relevant timescales, and 
                               regular horizon scanning takes place to identify 
                               relevant and significant regulatory change. 
 
 
                          *    A Customer Lookback Project was successfully 
                               completed in March 2022, whereby 100,000 alerts were 
                               manually reviewed. This gave the Group confidence of 
                               Politically Exposed Person (PEP) records and that no 
                               relationships exist with individuals subject to 
                               economic sanctions. 
-----------------------  -------------------------------------------------------------- 
 
 
P9 Conduct and 
 regulatory risk 
-----------------------    ------------------------------------------------------------ 
Risk description         Mitigating activities and other considerations 
 The risk of customer     *    A Group-wide Conduct Risk Framework has been 
 detriment due                 developed, with plans in place to further embed its 
 to poor design,               requirements across the Group. This enables the Group 
 distribution                  to demonstrate adherence to the requirements set out 
 and execution                 within the FCA's three-year Strategy and Annual 
 of products and               Business Plan and includes improved monitoring of 
 services or other             customer outcomes across all high-risk interactions 
 activities which              such as lending, forbearance, vulnerability and 
 could lead to                 complaints. 
 unfair customer 
 outcomes or regulatory 
 censure.                 *    A programme of activity has been established to meet 
                               the requirements of the FCA's Consumer Duty 
                               regulations coming into force 2023-2024. The Board 
                               and Risk Committee are provided with regular updates 
                               to support their oversight. 
 
 
                          *    As part of risk harmonisation, the legacy divisional 
                               Conduct and Compliance teams have been centralised 
                               and report to the Group's Chief Conduct and 
                               Compliance Officer who continues to consolidate 
                               consistent and best practices. 
 
 
                          *    Conduct Policies and Procedures are in place to 
                               ensure the Group has appropriate controls and 
                               processes to deliver fair customer outcomes. 
 
 
                          *    Group Complaints Forum and reporting were established 
                               to ensure the Group is learning from complaints 
                               trends across products, including any FOS referrals 
                               or upholds and actions of claims management 
                               companies. This has resulted in a number of strategic 
                               changes outlined in the Group's emerging risks: 
                               'Threats to our business model' and 'Responsible 
                               lending'. 
 
 
                          *    As part of the Group's response to the cost of living 
                               crisis (COLC), a number of steps have been taken, 
                               including reviewing the range of support available to 
                               customers and setting up a Cost of Living Forum, 
                               which closely monitors for early indicators of cost 
                               of living pressures in the Group's book performance, 
                               to enable any remedial action to be taken as 
                               required. The Group has proactively liaised with 
                               regulators to share insights on the COLC impact, 
                               providing updates on the outcome of the Group's 
                               monitoring and adjustments to its credit risk 
                               approach throughout the year. The FCA have concluded 
                               a review of Cost-of-Living Crisis Forbearance 
                               Outcomes which Moneybarn were selected to be part of. 
                               The findings, received on 3 February 2023, were 
                               consistent with an internal review performed during 
                               2022 which initiated a programme of work to enhance 
                               the effectiveness of operational areas to deliver 
                               improved customers outcomes. This in-flight programme 
                               will be further enhanced to reflect any additional 
                               areas of concern raised by the FCA. 
 
 
                          *    A Compliance Monitoring Programme is in place, 
                               supported by a robust methodology and approved by the 
                               Risk Committee, to assess the adequacy and 
                               effectiveness of the control frameworks in place and 
                               supporting fair customer outcomes and regulatory 
                               compliance. 
 
 
                          *    The Group proactively engages with regulatory 
                               authorities on a frequent basis. 
-----------------------  -------------------------------------------------------------- 
 
 
P10 People risk 
-----------------------------    ------------------------------------------------------------ 
Risk description               Mitigating activities and other considerations 
 There is a risk                *    People and HR function centralised to streamline 
 that we have                        critical people management activities across the 
 insufficient                        Group. 
 operational capacity 
 and colleagues 
 with the right                 *    People Risk Forum to support the management of key 
 skills in meeting                   people-related risks. 
 our financial, 
 customer and 
 regulatory responsibilities.   *    Operational Effectiveness Steering Group (OESG) 
                                     implemented to govern and manage the risks associated 
                                     with structural changes. 
 
 
                                *    Succession plans completed and in place for all 
                                     Executive and Senior Management. 
 
 
                                *    Communications have and continue to be shared with 
                                     colleagues across the Group to keep them apprised of 
                                     business changes and to support wellbeing. 
 
 
                                *    Full health and safety risk assessment completed of 
                                     all our key work locations with mitigating actions 
                                     completed. 
 
 
                                *    Recruitment, onboarding, training and exit processes 
                                     have been strengthened across the Group. 
 
 
                                *    Consistent frameworks have been developed and 
                                     embedded for Group reward, performance management (Be 
                                     Better) and talent management. 
-----------------------------  -------------------------------------------------------------- 
 
 
P11 Technology and information security risk 
---------------------------------------------------------------------------  -------- 
Risk description       Mitigating activities and other considerations 
 The risk arising        *    An IT shared service operating model has been 
 from compromised             implemented to seek commercial and cost opportunities 
 or inadequate                and manage associated risks effectively and 
 technology, security         efficiently across all product lines. 
 and data that 
 could affect 
 the confidentiality,    *    An IT Strategic Programme is in place to deliver new 
 integrity or                 architecture to embrace modern principles of open 
 availability                 architecture, supporting easy addition, upgrade and 
 of the Group's               replacement of components and the use of scalable 
 data or systems.             cloud services, while continuing to address key areas 
                              of technical debt. 
 
 
                         *    A cyber security strategy has been developed to align 
                              security across the Group and implement a consistent 
                              and robust service which supports the delivery of the 
                              overall business and IT strategies. 
 
 
                         *    Continued progress with the IT First Line Controls 
                              Review (FLCR), enhancing IT control effectiveness and 
                              risk maturity across the Group and transitioning risk 
                              and control ownership into business as usual (BAU) 
                              activity. 
---------------------  -------------------------------------------------------------- 
 
 
 
P12 Operational 
 risk 
------------------    ------------------------------------------------------------ 
Risk description    Mitigating activities and other considerations 
 The risk of loss    *    The Group's three lines of defence model ensures 
 resulting from           there are clear lines of accountability between 
 inadequate or            management which owns the risks, oversight by the 
 failed internal          Risk function and independent assurance provided by 
 processes, people        Internal Audit. 
 and systems or 
 from external 
 events.             *    The Risk Harmonisation Programme, which provides a 
                          more consistent and integrated approach to risk 
                          management across the Group, has moved from 
                          implementation to embedding stage. The programme is 
                          delivering a single Enterprise Risk Management 
                          Framework, consolidated Risk Policies and 
                          methodologies, and risk reporting capability. 
 
 
                     *    An integrated Risk Management System (Riskonnect) has 
                          been implemented which provides a central and secure 
                          repository of risk information across the Group's 
                          three lines of defence. Implementation of the system 
                          significantly enhances the Group's risk management 
                          capability, improved risk and control effectiveness, 
                          and realised resource efficiencies with the 
                          automation of processes and reporting. 
 
 
                     *    The Risk and Control Self-Assessment (RCSA) process 
                          has been subject to a budgeted programme of 
                          improvement activity, jointly sponsored by the Chief 
                          Operations Officer, Chief Information Officer and 
                          Chief Risk Officer. This programme has enhanced the 
                          accuracy, completeness and reliability of risk and 
                          control data. 
 
 
                     *    A fully standardised model for supplier management is 
                          being embedded, which includes the implementation of 
                          a new Supplier Relationship Management (SRM) 
                          Framework, Change Governance Framework, Portfolio 
                          Working Group and Transformation Executive Committee, 
                          and alignment of the Operational Resilience and 
                          Supplier and Third-Party Risk Management Frameworks. 
 
 
                     *    Work is progressing on the implementation and 
                          embedding of a harmonised change management control 
                          environment across the Group. 
------------------  -------------------------------------------------------------- 
 
 
P13 Model risk 
-----------------------    ------------------------------------------------------------ 
Risk description         Mitigating activities and other considerations 
 The risk of financial    *    Model Risk Management Framework and Policy, Target 
 losses where                  Operating Model and supporting modelling standards 
 models fail to                are in place. 
 perform as expected 
 due to poor governance 
 (including design        *    Material models across the Group are independently 
 and operation).               validated as required in the policy. 
 
 
                          *    Group model inventory, containing key models across 
                               the Group, is reviewed and updated on a regular basis 
                               and has all the necessary information to enable 
                               effective model risk reporting and planning. 
 
 
                          *    High-risk issues and findings on material models are 
                               addressed urgently and outstanding model risk issues 
                               and findings are monitored and reported to relevant 
                               governance forums across the Group. 
 
 
                          *    Group Model Governance Forum meets regularly and 
                               effectively provides model risk oversight, driving a 
                               standardised approach to model development and 
                               governance across the Group. 
 
 
                          *    Existing Group Model Risk Management Framework has 
                               been assessed against the PRA's proposed Model Risk 
                               Management Principles (CP6/22) and found no material 
                               gaps. 
 
 
                          *    Enhancements made to the existing IFRS 9 models with 
                               further improvements planned on the governance, 
                               performance monitoring and methodology of these 
                               models. 
-----------------------  -------------------------------------------------------------- 
 

Responsibilities statement

The Directors' responsibilities statement is extracted from page 118 of the 2022 Annual Report and Financial Statements.

Company law requires the directors to prepare financial statements for each financial year. Under that law the directors are required to prepare the Group financial statements in accordance with relevant IFRS, IFRIC interpretations and the Companies Act 2006.

 
 Patrick Snowball     Chairman 
 Malcolm Le May       Chief Executive Officer 
                     ------------------------- 
 Neeraj Kapur         Chief Finance Officer 
                     ------------------------- 
 Andrea Blance        Senior Independent 
                       Director 
                     ------------------------- 
 Angela Knight        Non-Executive Director 
                     ------------------------- 
 Elizabeth Chambers   Non-Executive Director 
                     ------------------------- 
 Margot James         Non-Executive Director 
                     ------------------------- 
 Paul Hewitt          Non-Executive Director 
                     ------------------------- 
 Graham Lindsay       Non-Executive Director 
                     ------------------------- 
 Michele Greene       Non-Executive Director 
                       Appointed 9(th) March 
                       2023 
                     ------------------------- 
 Robert East          Non-Executive Director 
                       Resigned 13(th) January 
                       2022 
                     ------------------------- 
 

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END

ACSNKBBNCBKKCQD

(END) Dow Jones Newswires

April 12, 2023 05:41 ET (09:41 GMT)

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