How we manage reputational risk

Our reputation is at risk when stakeholders have poor perceptions of us, regardless of whether those perceptions are grounded in fact or not. Stakeholders’ expectations change constantly and so reputational risk is dynamic. It varies between geographical regions, groups and individuals.

There are three risk stewards for reputational risk: the Group Head of External Affairs and Sustainability, the Global Head of Financial Crime Compliance and the Global Head of Regulatory Compliance. The development of policies, management and mitigation of reputational risk are co-ordinated through the Group Reputational Risk Policy Committee, which is chaired by the Group Chairman. In parallel, the Global Risk Resolution Committee, chaired by the Chief Risk Officer, is the highest decision-making forum in the Group for matters arising from clients or transactions that either present a serious potential reputational risk to the Group, or merit a Group-led decision to ensure a consistent risk management approach across our regions and global businesses. Significant issues posing reputational risk are also reported to the Board and the Conduct & Values Committee, where appropriate.

Our policies set out our risk appetite and operational procedures for all areas of reputational risk, including financial crime prevention, regulatory compliance, conduct-related concerns, environmental impacts, human rights matters and employee relations.

Our efforts to detect, deter and prevent financial crime are of key importance to our reputation. We continue to take measures to address the requirements of the US Deferred Prosecution Agreement and enhance our anti-money laundering, sanctions and other regulatory compliance frameworks. These measures should also help us to manage reputational risk now and in the future.

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