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1、 Risk @ Wholesale Bank An orientation to effective risk management & control TABLE OF CONTENTS Introduction 3 Risk Culture – what does it mean at Standard Chartered 3 Business and Risk 4 Risk Principles (also refer Database B 101) 5 Risk Types 5 Credit Risk 5 Country Risk

2、 (also refer database B 301 and B 326) 6 Market and Liquidity Risk (also refer Group Market Risk Policy Database) 6 Operational Risk (also refer database B 501) 7 Compliance Risk (also refer database B 601 and B 602) 8 Reputational Risk (also refer database B 701 and J401) 9 Environmental and S

3、ocial Risk (also refer database B 204) 9 Risk Management Framework & Matrix of Responsibilities 9 Risk Management Organization 10 Group Level 10 Functional Level 11 Country Level 11 Risk Policies and Procedures 11 1. Group Policies 11 2. Functional Policies 12 3. Country Underwriting Standa

4、rds 12 Risk Pricing 13 Economic Profit 13 Measurement Tools 13 Pricing Guidelines 13 Management of Customers/Counterparties 14 Target Customers 14 Name Lending 14 Money Laundering – Know your customer (also refer database B 507 and B 534) 14 Types 15 I. CORPORATES 15 Groups (also refer d

5、atabase J 202, J 203 and J 206) 15 Lending to Holding Companies (also refer database J101) 15 Subsidiary Companies (also refer database J 207) 15 II. BANKS 16 Banks and Financial Institutions (also refer database J 154, J 155, J 307, J 804 & J 806) 16 III. GOVERNMENTS 16 Governments and Govern

6、ment Owned Companies (also refer database J 204) 16 IV. INVESTMENT INSTITUTIONS 16 Funds, Fund Managers and Hedge Funds (also refer database J 807 and J 808) 16 V. PERSONAL BORROWERS 16 Lending to Individuals within Functional level policy (also refer database J 104) 17 Products 17 Categories

7、of Risk for Limit Purposes – Category 1,2&3 (also refer database R 201) 17 Suitability, Saleability, Pricing (also refer database J 101, J111) 18 Specific Requirements (also refer database J 101, J 302, J307) 18 Specialist Product and Higher Risk Areas (also refer database J 101) 18 Restricted A

8、ctivities (also refer database J 101 and B 702) 18 Environmental and Social Risk (also refer database B204 and B 226) 19 Others (also refer database J 101) 19 Approval Process 19 Business Credit Application (also refer database J 151, J154,) 19 Credit Grades (also refer database D 101 and J 206

9、) 21 Grading Groups and use of Parental Support (also refer database J 206) 22 Regulatory Compliance (also refer database B 202) 22 Credit Reference Levels (also refer database J 121) 22 Security (also refer database J 158 and J 616) 23 Country Risk (also refer database B 326) 23 Approval Auth

10、orities (also refer database J 102 & J 152) 23 Pre Disbursal Process – Control of Lending 24 Securing Documentation (also refer database J175 and J506) 24 Monitoring & Control 25 Trigger Points (also refer database J 151) 25 Early Alert Accounts – (also refer database J 503) 25 Accounts Subjec

11、t To Additional Review (also refer database J 505) 25 Management of Special Assets - GSAM 26 Accounts graded CG 12 (also refer database N 101) 26 Lessons Learned Review (also refer database N 300) 26 Introduction Welcome to Standard Chartered Bank. This risk handbook will give you an intro

12、duction to the various risk related activities within the bank. This handbook is not meant to be a “Bible” on Risk Management but instead will provide you with the background to several key areas within the lending function and will serve as your “first point of reference”. Elaboration and detail of

13、 any policy or process will be found in the respective database(s) and you will be provided a reference to the same in the handbook. Further, if you are in a sales related role, you must also refer to the Relationship Managers Guide, which will equip you on, “How to be a better Relationship Manager

14、and become a partner to your clients”. Risk Culture – what does it mean at Standard Chartered What is culture? Webster defines it as: "The set of shared attitudes, values, goals, and practices that characterises a organisation" - the key word is shared. We all have different roles to

15、play within the organisation but one thing is clear, Standard Chartered can and will only be successful if we all take ownership of risk and accept accountability for our actions. Every one of us can lead by example and ensure that the decisions we make, the actions we take, are to the long term be

16、nefit of the bank firstly and that any personal benefit is subordinate. The bank benefits from a strong risk culture and we endeavour to reward good risk behaviour in the same way that we reward other achievements. Those of us who demonstrate a sound approach to risk can expect to see this furth

17、er our careers and be appropriately rewarded. Saving losses is as important as growing revenue. We expect people to behave responsibly and to bring problems to the fore at the earliest possible stage. In the same way that we expect openness and full disclosure from our clients, so we expect it

18、of ourselves. Problems are there to be solved, not hidden. In a good, sound institution risk is an integral part of strategic planning from the top down. Good risk culture derives from good risk behaviour, a collegiate approach, open and robust debate on issues of concern and most of all a firm

19、 and unwavering commitment to a "No Surprises" philosophy. We will also ensure we all have a clear framework within which to operate and that we all understand what we can and can not do. The following table lays down key characteristics of effective risk culture: SCB Risk Culture We

20、 succeed if everyone sees ownership of risk as part of their responsibility, not everyone elses; it doesnt have to be in the job description. We are all expected to take risk decisions in the best interests of the Bank as a whole, not just our part of it. Risk behaviour that is in the best int

21、erests of the Bank will be recognised in career development and promotion. Risk ownership begins as close to the client as possible and is an active, on-going responsibility. Group Risk will provide and communicate a clear and unambiguous framework of policies, principles and processes for ris

22、k ownership and review. All risks decisions will have a clearly identifiable audit trail and the Bank will hold staff accountable. In holding people to account, the Bank will differentiate between unforeseeable consequences and deliberate policy- flouting. Saving significant losses will be

23、rewarded in the same way as growing the revenue line. The Bank will work to create a climate in which staff can talk honestly and openly about risk or problems at a sufficiently early stage, with the emphasis on solutions. We will openly discuss and learn lessons from mistakes/misjudgements.

24、 The Bank will ensure that all employees receive Risk training appropriate to their position, starting with induction. Business and Risk Most dictionaries define risk as ‘danger’ or ‘the possibility of something harmful or undesirable happening’. Consequently the intuitive understanding

25、 of the word is a “negative” one. However, as a Bank, risk is our business and we profit from managing it. Therefore it is imperative that we understand the risks we face and have robust systems that identify, measure and manage these risks and have people who are risk aware so that we can exploit t

26、he opportunities that are presented to us. Specifically we need to ensure when we accept risk, we do so because it fits with our strategy, is within underwriting standards, is priced and approved appropriately and is monitored constantly. Risk Principles (also refer Database B 101) The Basic

27、Principles of Risk Management within the bank are: We recognise that revenue is earned by accepting risk and we will ensure that business activities are controlled on the basis of risk adjusted return. We will be explicit in setting our appetite for risk and we will manage risk to stay with

28、in agreed parameters. It follows from this that risk must be quantified wherever possible. Risk will be assessed before acceptance and for as long thereafter as we remain exposed to it. We will comply with all applicable laws and regulations in every country where we do business, and with

29、the governance standards prescribed for listed companies. We will apply high and consistent ethical standards to our relationships with all customers, employees, and other stakeholders. Group activities will be undertaken in accordance with fundamental control standards. These controls w

30、ill employ the disciplines of planning, monitoring, segregation, authorisation and approval, recording, safeguarding, reconciliation, and valuation. Risk Types Often credit risk is considered as the only risk that lenders need to evaluate when arriving at a lending decision. In an increasin

31、gly dynamic and complex marketplace, it is imperative that we consider all the types of risk that could exist and then dimension and evaluate the critical ones so as to focus our limited time and resources on them before arriving at a decision. As a bank we generate most of our revenues by accepting

32、 risk of differing types in our lending decisions. For a summary of definitions of the main types of risk, also refer database B 101. The main types of risk that need to be considered are: - Credit Risk In assessing credit risk we seek to establish the probability that a counterparty will not

33、repay it’s obligations to the bank. The better the quality of the customer, the lower is the expected probability of default. The assessment of this risk is carried out by the nature of the counterparty and can be broadly categorised into the following: Corporates – These include Local Franchises

34、 and MNC segments of the Corporate Bank and are approved by Credit Officers with delegated lending authority within the Country and if beyond their authority then at Regional Credit Officer level or Group level. Non Corporates – These include Governments, Banks, Financial Institutions and Investm

35、ent Institutions. Given that the nature of these counterparties are very different from that of Corporates, the same are assessed and approved by Markets and Institutions Risk Management (MIRM) which is an independent approving unit within the Risk Management function. MIRM on a centralised basis su

36、pports the bank’s business in setting and approving credit limits on counterparties to support the following activities: – 1. Asset Liability Management – This is done on a portfolio basis and against pre agreed norms with regard to counterparty rating, nature of instrument and amount of exposure a

37、nd does not need specific approval on a counterparty basis. These are controlled on an oversight basis with regard to outstandings and credit quality. 2. Normal Business – This is done on a product basis (e.g. Trade Finance, FEX, Derivatives, Fixed Income Securities, Syndication’s, etc.) and with r

38、eference to a specific counterparty on whom credit limits are established. Sovereign Risk and Country Risk – are they the same? NO, Sovereign Risk is the counter-party credit risk of a borrower who is a government or a wholly owned entity of a government. Hence sovereign risk is assessed as part

39、of the risk approval process for Non Corporates and should not be confused with Country Risk. Country Risk (also refer database B 301 and B 326) Country Risk arises when the bank has a cross border exposure on a counterparty on which we have Credit Risk. Country Risk is the risk that our coun

40、terparty is unable to meet its contractual obligations as a result of adverse economic conditions or actions taken by governments in the relevant country. Given that this is independent of the counterparty credit risk, we assess this risk in addition to credit risk. Since the assumption of country r

41、isk requires capital allocation, we also price for it in accordance to the risk of the country on which an exposure is being taken. Country risk arises in all cases other than in those that are on-shore transactions in domestic currency. Nominated Country Risk Allocation Holders manage and monitor t

42、his risk under the supervision of Group Country Risk in London. (also refer database B327 and B329, for details of allocation holders and country status) A modular e-learning solution is also available on ‘Peoplewise’ for Country Risk. Market and Liquidity Risk (also refer Group Market Risk Po

43、licy Database) Unlike Credit and Country Risk where the risk needs to be assessed at a counterparty level, Market and Liquidity risk are assessed in the main on a portfolio basis. However, in the case of large or complex exposures this could also be evaluated at a transaction level. Typically the

44、se risks are evaluated with the use of sophisticated statistical models which are employed to quantify these risks at transaction or portfolio level. Group Market Risk is responsible for the overall framework and management/ control of market and liquidity risk within the organisation. They evaluate

45、 and implement the models and validate the assumptions in the models on a continuous basis. At a business and country level, they monitor and control these risks by delegating authority to Local Management who are primarily responsible to comply with the group guidelines. These can be briefly explai

46、ned as under: - 1. Market Risk is the risk to the Groups earnings and capital due to changes in the market level of interest rates, securities, foreign exchange and equities, as well as the volatilities of those prices. Group Market Risk prescribes the unified framework for the assessment and contr

47、ol of market price risk. A risk monitoring limit and reporting structure is set out for portfolios of products, instruments, and income streams, where the economic value is directly or indirectly sensitive to changes in variable market prices, such as spot foreign exchange or interest rates. 2. Li

48、quidity risk management involves the ability to manage and maintain adequate liquidity at all times. Good liquidity risk management will result in the bank being in a position (in the normal course of business) to meet all it’s obligations, to repay depositors, to fulfil commitments to lend and to

49、 meet any other commitments it may have made. Of critical importance is the need to avoid having to liquidate assets or to raise funds at unfavourable terms resulting in financial loss or long term damage to the reputation of the Bank. Prudent liquidity management is of paramount importance as the

50、ultimate cost of a lack of liquidity is being out of business, which we cannot afford. Operational Risk (also refer database B 501) In addition to other established risk classes discussed so far, the bank also views Operational risk as a separate risk class. Like Credit, Market and Liquidity r

51、isks, Operational Risk too has evolved in the Group and now has it’s own established policies (also refer database sub chapter B 500) and procedures (also refer database sub chapter B 525) to facilitate management and measurement. Operational Risk is defined as “The risk that the Group will incu

52、r direct or indirect loss due to an event or action causing the failure of technology, processes, infrastructure, personnel and other risks having operational impact. Legal risk is included. This definition excludes strategic/business and reputational risk”. Some of the key developments in this

53、area are enumerated hereunder: Operational Risk coverage is now enterprise wide i.e. across front office / middle office and back office functions in the Group and works on a de-centralised model, with business and countries taking greater responsibility and ownership for day-to-day risk manage

54、ment. Group Operational Risk is today an independent risk unit within Group Risk and is responsible for defining and implementing the Group’s Operational Risk Policy and framework. In addition to the Operational Risk unit, the Group Operational Risk function also includes Group Insurance and Grou

55、p Security (including responsibility for the Group’s Continuity Planning Policy). The Operational Risk management framework is also being used to track and manage non-traditional risks like Reputational, Compliance, Social, Ethical and Environmental risk in the Group. Risk management at country

56、, business and Group levels is an integrated process and is through self-assessment and exception reporting. The evolving relationship between a robust control environment and shareholder value has resulted in a greater governance focus within organizations. Roles and responsibilities are also bei

57、ng constantly reviewed / enhanced to support the same and Group Audit plays an active role in reviewing the effectiveness of risk management process and framework. On the international front Standard Chartered is a member on the Financial Services Authority (FSA) Advisory panel on Operational Ris

58、k and the Institute of International Finance (IIF) Working Group on Operational Risk. All employees have a role to play in managing operational risk and compliance with the Group Operational Risk Policy & Procedures is mandatory. You must ensure that your key operational risks are understood, be

59、ing managed and reported (where significant) to senior management. Within the Wholesale Bank, significant risks should be reported to the Wholesale Bank Risk Committee. Coverage should be across front office, middle office and back office areas and scope should not be restricted to just Service Deli

60、very / Technology issues. Compliance Risk (also refer database B 601 and B 602) Since Banking and Financial service activities are conducted within a framework of obligations imposed by regulators and national/ international law, complying with such requirements is not optional for the bank.

61、The consequences of non-compliance include fines, public reprimands, and enforced supervision of operations or withdrawal of authorisation to operate, any of which can lead to reputational loss particularly through adverse publicity in national or international media. Non-compliance with regulatory

62、requirements can also lead to civil or criminal action being taken against the Bank and responsible employees, which is detrimental to our ability to successfully conduct business. Therefore the bank is working towards developing a robust framework of procedures and controls so as to minimise compli

63、ance risk and to ensure that everyone understands their roles and responsibilities in this process. All employees are expected to observe the Group Code of Conduct, which must be followed at all times. The increasing importance to the issue of money laundering cannot be overlooked and it is mandator

64、y for all staff to be conversant with the Money Laundering Policy (refer B 507). Reputational Risk (also refer database B 701 and J401) Our reputation is one of our most important assets and therefore it is important to understand the implications of putting our ‘Reputation’ at risk. To prot

65、ect our (good) reputation we need to ensure that we are seen to conduct business activities in a manner that is in line with the requirements or expectations of all our key stakeholders. Every time we fail to manage one or more of the risks discussed so far in an appropriate manner, the resultant ad

66、verse publicity will always impact our reputation as well our revenue generating capability in any given business location. The intuitive way to assess this risk is to ask yourself the question, “If this made it to the Headlines in the newspaper, will it embarrass or harm us in any way?” If the answer is Yes, then escalate the issue to your Manager at an early stage to enable a risk reward assessment to be made and an appropriate decision agreed to. All staff are responsible f