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10th September 2015
Sune Warberg Clausen, Head of Risk in Personal Banking
Operational Risk function in 1st line
2
Agenda
Danske Bank — Version and strategy
The Risk function in Personal Banking
Building an Oprisk framework
How do you influence the risk culture
Improving risk culture through 1:1 risk attention
Improving risk culture through measurement
Improving risk culture — Empowerment & consequences
3
Overview: Danske Bank has a strong Nordic franchise
Northern
Ireland Denmark
Norway
Sweden
Finland
Estonia
Latvia
Lithuania
20% 26%
5%
5%
10%
8%
3%
6%
Danske Bank market share**
1. Excluding agricultural centres in Denmark.
2. Market share by lending
Business units
Personal Banking
Business Banking
Corporates & Institutions
Danica Pension
Danske Capital
For divestment
Non–core (Ireland & Conduits)
Personal banking activities in the
Baltics
Facts
3.6 million customers
313 branches1
15 countries
18,874 full–time employees
4
Personal Banking
[Finland]
[Norway]
[Sweden]
[Denmark]
[Luxembourg]
[UK)
[Northern Ireland]
Key facts
 3,256 (millions) customers
 1,886 (millions) active
e-banking customers
 6,796 employees
5
Agenda
Danske Bank — Version and strategy
The Risk function in Personal Banking
Building an Oprisk framework
How do you influence the risk culture
Improving risk culture through 1:1 risk attention
Improving risk culture through measurement
Improving risk culture — Empowerment & consequences
6
The mandate of Risk in PB is to define and execute
on the described risk framework and bring issues
to PB Risk Committee
The mandate for Risk is to define the risk framework for the management of non-
financial risks in all market areas and have it approved in Personal Banking’s Risk
Committee. The risk framework in this context includes risk policies, governance,
identification, monitoring, controlling, reporting and event handling. Each market area
can to the extent necessary add on additional risk management activities where they
see fit.
PB Risk
Committee
Risk
Function
BD Denmark BD Sweden BD Norway BD Finland
Risk
function in
Luxembourg
Risk function
in UK
7
Governance in a Group perspective – Risk follows the
guidelines defined by Group Operational Risk and ORCO
ORCO
PB Risk Committee
31AW RiskGroup Compliance
Group Operational Risk
Group Security PB Denmark
PB Sweden
PB Norway
PB Finland
PB UK
Private Banking DK
Private Banking Int.
2nd line risk function
2nd line risk function
2nd line risk function
2nd line risk function
2nd line risk function
8
Our Foundation: Three lines of defence
As a business unit risk function we are somewhere between 1. and 2. line. We report to
business unit management but maintain a dotted line to the Group Risk Management
function
First line: Business
units dealing with
customers
Second line: Control
units
Third line: Internal audit
9
The role of the risk function
“We identify the weaknesses in the operation, streamline our control environment and
follow up on key areas”
 Be part of projects
with risk content
 Be part of product
and process
design
 Influence the
culture through
reporting and
communication
 Build and drive risk management
framework for PB in all countries
 Look across all non–financial risks
 Report to management and ensure
informed decisions on risk areas
10
Agenda
Danske Bank — Version and strategy
The Risk function in Personal Banking
Building an Oprisk framework
How do you influence the risk culture
Improving risk culture through 1:1 risk attention
Improving risk culture through measurement
Improving risk culture — Empowerment & consequences
11
We want to put numbers on the risk — AWACS–principle
12
It’s not easy to put numbers on risk
Starting point
Data on
losses
Today
Data on losses
Management
controls
Verification
AML Monitoring
Quality OpRisk
controlling
CDD errors on new
customers
Errors in handovers
to back office
Open audit
recommendation
How did we get to the point, where we could get
the “AWAC to take off”
13
We chose the bottom up approach
Example
Management
controls
“AWAC”
Risk Dashboard
and reporting
Risk Controlling
set–up
Risk officer set–up
Management control set–up
 We can now say that we have a “AWAC” on
management controls
 Creating an automatic risk dashboard
 Measuring on all levels (bottom to top)
 Monthly reporting on all levels
 Set–up for controlling of the quality of the risk work in
the branches
 Measurable — correctness percent
 Risk officers who are working with the branches
 Training and best practice
 Full overview and transparency
 Measurable
14
What was the value of the work
Strong control set-up Good overview
Only relevant controls Saved time
Measurable
Easy to know when you
have done what there
is expected
Better risk culture
Fewer errors
(lower costs)
Risk Business
15
Agenda
Danske Bank — Version and strategy
The Risk function in Personal Banking
Building an Oprisk framework
How do you influence the risk culture
Improving risk culture through 1:1 risk attention
Improving risk culture through measurement
Improving risk culture — Empowerment & consequences
16
“The ability of the organisation to integrate risk considerations in the
decision making and daily business operation”
Definition of Risk Culture
17
Driving the Risk Culture — Input factors
Risk
culture
Risk
framework
Control
infrastructure
Risk
infrastructure
Integration
of risk
metrics
Tone
at the top Number
of FTE
Competencies
in Risk
Number of
distortions
Core values
18
Agenda
Danske Bank — Version and strategy
The Risk function in Personal Banking
Building an Oprisk framework
How do you influence the risk culture
Improving risk culture through 1:1 risk attention
Improving risk culture through measurement
Improving risk culture — Empowerment & consequences
19
Improving risk culture through 1:1 risk attention
Branch
visit
Training
Give best
practice
OpRisk
Controlling
Get feed
back
Focus on
solutions
 Visit by a local risk officer
• Visit every branch 1 or 2 times
every year
Branch visit
• Important topics
• Specific training after the
branches needs
Training
• Take best practice from the best
branches to the branches with
needs
Give best
practice
• Testing of quality of the risk work
• Objective score (correctness
percent)
OpRisk
Controlling
• Feed back from the branches
• Ensure better processes
Get feed back
• Looking forward — how can we
ensure a better risk picture in the
future
Focus on
solutions
20
Branch meetings
Change Controlling process
Recommend
changed controls
& processes
Risk control
 Local
presence
 Business
support
 Business
knowledge
 Simple tools
and methods
Testing the
operational quality &
process adherence
Giving feedback on
suitability of processes
and controls
Branches
 Most
important
bearers of the
risk culture
 Users of the
customer
facing
processes
 Executes key
controls
21
Has it worked? — Quality
in our testing/controlling
Each line is a region in Denmark — The graph shows the development in correctness score in our OpRisk Controlling
60
65
70
75
80
85
90
95
100
NovOctSepAugJulJunMayAprMarFe
b
Jan DecNovOctSepAugJulJunMayAprMarFe
b
JanDec
TotalTarget
RedArea 6
Area 5
Area 4
Area 3
Area 2
Area 1
22
Agenda
Danske Bank — Version and strategy
The Risk function in Personal Banking
Building an Oprisk framework
How do you influence the risk culture
Improving risk culture through 1:1 risk attention
Improving risk culture through measurement
Improving risk culture — Empowerment & consequences
23
Risk reporting universe in Personal Banking
Risk tolerance
 Management board level
(market areas)
 Measurement of not accepted
deviations
 E.g. OpRisk losses or
Customer complaints
Market Area performance
 Branch Manager level (each
branch)
 Measurement of correctness
percent
 E.g. Management controls or
Controlling
Staff performance
 Local risk owner level
(managers in staff functions)
 Measurement of better
processor or risk acceptance
 E.g. RIA issues or Audit
recommendations
License to operate
 Employee and manager level
 Measurement of areas that
require that all employees
have completed all relevant
targets
 E.g. AML education or
identification of customers
Early warning
indicators
24
Has it worked? — Quality
in our testing/controlling
Each line is a region in Denmark — The graph shows the development in correctness score in our OpRisk Controlling
35
40
45
50
55
60
65
70
75
80
85
90
95
100
NovOctSepAugJulJunMayAprMarFe
b
Jan Dec
Target
Red
Total
Area 5
Area 4
Area 3
Area 2
Area 1
25
Agenda
Danske Bank — Version and strategy
The Risk function in Personal Banking
Building an Oprisk framework
How do you influence the risk culture
Improving risk culture through 1:1 risk attention
Improving risk culture through measurement
Improving risk culture — Empowerment & consequences
26
Empowerment vs. consequences — A natural link
Empowerment requires a strong risk culture throughout the organisation AND clear
consequences if basic rules are broken
Simplification Empowerment Consequences
27
Licence to Operate — An example of working with culture
To ensure that we all know the basics of banking so we can
 Meet external legal and regulatory requirements
 Build financial confidence and earn trust
 Meet our customers’ expectations
 Ensure strong fundamental skills
WHY do we need License to Operate?
28
Has it worked? — License to Operate
Data from the LTO tool — 2. January 2015
Green Amber Red
% there is
done
Not done
courses
Not corrected
CDD errors
Personal Banking 6.307 5 0 99,92 0 0
Personal Banking Staff 1 188 0 0 100,00 0 0
Personal Banking Staff 2 40 0 0 100,00 0 0
Personal Banking Marked area 1 2.962 0 0 100,00 0 0
Personal Banking Staff 3 30 0 0 100,00 0 0
Personal Banking Marked area 2 934 0 0 100,00 0 0
Personal Banking Staff 4 16 0 0 100,00 0 0
Personal Banking Staff 5 18 0 0 100,00 0 0
Personal Banking Marked area 3 303 5 0 98,38 0 0
Personal Banking Marked area 4 367 0 0 100,00 0 0
Personal Banking Marked area 5 862 0 0 100,00 0 0
Private Banking Marked area 6 332 0 0 100,00 0 0
Private Banking Marked area 7 255 0 0 100,00 0 0
29

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Operational Risk function in 1st line

  • 1. 10th September 2015 Sune Warberg Clausen, Head of Risk in Personal Banking Operational Risk function in 1st line
  • 2. 2 Agenda Danske Bank — Version and strategy The Risk function in Personal Banking Building an Oprisk framework How do you influence the risk culture Improving risk culture through 1:1 risk attention Improving risk culture through measurement Improving risk culture — Empowerment & consequences
  • 3. 3 Overview: Danske Bank has a strong Nordic franchise Northern Ireland Denmark Norway Sweden Finland Estonia Latvia Lithuania 20% 26% 5% 5% 10% 8% 3% 6% Danske Bank market share** 1. Excluding agricultural centres in Denmark. 2. Market share by lending Business units Personal Banking Business Banking Corporates & Institutions Danica Pension Danske Capital For divestment Non–core (Ireland & Conduits) Personal banking activities in the Baltics Facts 3.6 million customers 313 branches1 15 countries 18,874 full–time employees
  • 4. 4 Personal Banking [Finland] [Norway] [Sweden] [Denmark] [Luxembourg] [UK) [Northern Ireland] Key facts  3,256 (millions) customers  1,886 (millions) active e-banking customers  6,796 employees
  • 5. 5 Agenda Danske Bank — Version and strategy The Risk function in Personal Banking Building an Oprisk framework How do you influence the risk culture Improving risk culture through 1:1 risk attention Improving risk culture through measurement Improving risk culture — Empowerment & consequences
  • 6. 6 The mandate of Risk in PB is to define and execute on the described risk framework and bring issues to PB Risk Committee The mandate for Risk is to define the risk framework for the management of non- financial risks in all market areas and have it approved in Personal Banking’s Risk Committee. The risk framework in this context includes risk policies, governance, identification, monitoring, controlling, reporting and event handling. Each market area can to the extent necessary add on additional risk management activities where they see fit. PB Risk Committee Risk Function BD Denmark BD Sweden BD Norway BD Finland Risk function in Luxembourg Risk function in UK
  • 7. 7 Governance in a Group perspective – Risk follows the guidelines defined by Group Operational Risk and ORCO ORCO PB Risk Committee 31AW RiskGroup Compliance Group Operational Risk Group Security PB Denmark PB Sweden PB Norway PB Finland PB UK Private Banking DK Private Banking Int. 2nd line risk function 2nd line risk function 2nd line risk function 2nd line risk function 2nd line risk function
  • 8. 8 Our Foundation: Three lines of defence As a business unit risk function we are somewhere between 1. and 2. line. We report to business unit management but maintain a dotted line to the Group Risk Management function First line: Business units dealing with customers Second line: Control units Third line: Internal audit
  • 9. 9 The role of the risk function “We identify the weaknesses in the operation, streamline our control environment and follow up on key areas”  Be part of projects with risk content  Be part of product and process design  Influence the culture through reporting and communication  Build and drive risk management framework for PB in all countries  Look across all non–financial risks  Report to management and ensure informed decisions on risk areas
  • 10. 10 Agenda Danske Bank — Version and strategy The Risk function in Personal Banking Building an Oprisk framework How do you influence the risk culture Improving risk culture through 1:1 risk attention Improving risk culture through measurement Improving risk culture — Empowerment & consequences
  • 11. 11 We want to put numbers on the risk — AWACS–principle
  • 12. 12 It’s not easy to put numbers on risk Starting point Data on losses Today Data on losses Management controls Verification AML Monitoring Quality OpRisk controlling CDD errors on new customers Errors in handovers to back office Open audit recommendation How did we get to the point, where we could get the “AWAC to take off”
  • 13. 13 We chose the bottom up approach Example Management controls “AWAC” Risk Dashboard and reporting Risk Controlling set–up Risk officer set–up Management control set–up  We can now say that we have a “AWAC” on management controls  Creating an automatic risk dashboard  Measuring on all levels (bottom to top)  Monthly reporting on all levels  Set–up for controlling of the quality of the risk work in the branches  Measurable — correctness percent  Risk officers who are working with the branches  Training and best practice  Full overview and transparency  Measurable
  • 14. 14 What was the value of the work Strong control set-up Good overview Only relevant controls Saved time Measurable Easy to know when you have done what there is expected Better risk culture Fewer errors (lower costs) Risk Business
  • 15. 15 Agenda Danske Bank — Version and strategy The Risk function in Personal Banking Building an Oprisk framework How do you influence the risk culture Improving risk culture through 1:1 risk attention Improving risk culture through measurement Improving risk culture — Empowerment & consequences
  • 16. 16 “The ability of the organisation to integrate risk considerations in the decision making and daily business operation” Definition of Risk Culture
  • 17. 17 Driving the Risk Culture — Input factors Risk culture Risk framework Control infrastructure Risk infrastructure Integration of risk metrics Tone at the top Number of FTE Competencies in Risk Number of distortions Core values
  • 18. 18 Agenda Danske Bank — Version and strategy The Risk function in Personal Banking Building an Oprisk framework How do you influence the risk culture Improving risk culture through 1:1 risk attention Improving risk culture through measurement Improving risk culture — Empowerment & consequences
  • 19. 19 Improving risk culture through 1:1 risk attention Branch visit Training Give best practice OpRisk Controlling Get feed back Focus on solutions  Visit by a local risk officer • Visit every branch 1 or 2 times every year Branch visit • Important topics • Specific training after the branches needs Training • Take best practice from the best branches to the branches with needs Give best practice • Testing of quality of the risk work • Objective score (correctness percent) OpRisk Controlling • Feed back from the branches • Ensure better processes Get feed back • Looking forward — how can we ensure a better risk picture in the future Focus on solutions
  • 20. 20 Branch meetings Change Controlling process Recommend changed controls & processes Risk control  Local presence  Business support  Business knowledge  Simple tools and methods Testing the operational quality & process adherence Giving feedback on suitability of processes and controls Branches  Most important bearers of the risk culture  Users of the customer facing processes  Executes key controls
  • 21. 21 Has it worked? — Quality in our testing/controlling Each line is a region in Denmark — The graph shows the development in correctness score in our OpRisk Controlling 60 65 70 75 80 85 90 95 100 NovOctSepAugJulJunMayAprMarFe b Jan DecNovOctSepAugJulJunMayAprMarFe b JanDec TotalTarget RedArea 6 Area 5 Area 4 Area 3 Area 2 Area 1
  • 22. 22 Agenda Danske Bank — Version and strategy The Risk function in Personal Banking Building an Oprisk framework How do you influence the risk culture Improving risk culture through 1:1 risk attention Improving risk culture through measurement Improving risk culture — Empowerment & consequences
  • 23. 23 Risk reporting universe in Personal Banking Risk tolerance  Management board level (market areas)  Measurement of not accepted deviations  E.g. OpRisk losses or Customer complaints Market Area performance  Branch Manager level (each branch)  Measurement of correctness percent  E.g. Management controls or Controlling Staff performance  Local risk owner level (managers in staff functions)  Measurement of better processor or risk acceptance  E.g. RIA issues or Audit recommendations License to operate  Employee and manager level  Measurement of areas that require that all employees have completed all relevant targets  E.g. AML education or identification of customers Early warning indicators
  • 24. 24 Has it worked? — Quality in our testing/controlling Each line is a region in Denmark — The graph shows the development in correctness score in our OpRisk Controlling 35 40 45 50 55 60 65 70 75 80 85 90 95 100 NovOctSepAugJulJunMayAprMarFe b Jan Dec Target Red Total Area 5 Area 4 Area 3 Area 2 Area 1
  • 25. 25 Agenda Danske Bank — Version and strategy The Risk function in Personal Banking Building an Oprisk framework How do you influence the risk culture Improving risk culture through 1:1 risk attention Improving risk culture through measurement Improving risk culture — Empowerment & consequences
  • 26. 26 Empowerment vs. consequences — A natural link Empowerment requires a strong risk culture throughout the organisation AND clear consequences if basic rules are broken Simplification Empowerment Consequences
  • 27. 27 Licence to Operate — An example of working with culture To ensure that we all know the basics of banking so we can  Meet external legal and regulatory requirements  Build financial confidence and earn trust  Meet our customers’ expectations  Ensure strong fundamental skills WHY do we need License to Operate?
  • 28. 28 Has it worked? — License to Operate Data from the LTO tool — 2. January 2015 Green Amber Red % there is done Not done courses Not corrected CDD errors Personal Banking 6.307 5 0 99,92 0 0 Personal Banking Staff 1 188 0 0 100,00 0 0 Personal Banking Staff 2 40 0 0 100,00 0 0 Personal Banking Marked area 1 2.962 0 0 100,00 0 0 Personal Banking Staff 3 30 0 0 100,00 0 0 Personal Banking Marked area 2 934 0 0 100,00 0 0 Personal Banking Staff 4 16 0 0 100,00 0 0 Personal Banking Staff 5 18 0 0 100,00 0 0 Personal Banking Marked area 3 303 5 0 98,38 0 0 Personal Banking Marked area 4 367 0 0 100,00 0 0 Personal Banking Marked area 5 862 0 0 100,00 0 0 Private Banking Marked area 6 332 0 0 100,00 0 0 Private Banking Marked area 7 255 0 0 100,00 0 0
  • 29. 29