ING Direct 2009 Annual Report Download - page 241

ING Group – Non-financial risks
Learning
The ‘Leading Compliance Risk Management in your business’ workshop targeted the top four echelons of ING management (Bank and
Insurance) worldwide. It helped provide over 12,000 Managers with a deeper understanding of the effective embedding of ING’s Three
Lines of Defence model and the strategic value of Compliance Risk Management. Managers also learned in practical steps what actions
they can take to strengthen the management of Compliance Risk as well as how to apply the Framework and tools.
Additionally over 700 Compliance Officers world-wide completed a five day face to face Compliance Officer training focused on raising
technical knowledge and enhancing personal effectiveness.
Compliance risk reporting - Quality Assurance – Challenging Process
The embedding of policies in all ING’s Business Units is vital to the effectiveness of ING’s Compliance Risk Management strategy.
To ensure that ING has clarity on the status of policy embedding and what actions are planned or in place to ensure all policies are
operationally effective, all ING Business Units produce quarterly progress reports.
To ensure the quality of the policy embedding data, Group Compliance Risk Management has formalised a robust Risk Challenging and
verification process. The process is lead by the Chief Compliance Officer and is conducted with members of the Business units and the
Group Compliance Reporting and Analytics team.
Communication
Communication in 2009 focused on delivering clear messages and useable knowledge to the Compliance Risk Management community
through vehicles such as E-Bulletins, workshops and poster campaigns. The Group Compliance Risk Management intranet site was
re-designed to provide all employees with an easier more engaging tool to find reference material, policies and Compliance Risk
Management news.
When communicating to all ING’s’ employees, Group Compliance Risk Management embraced all forms of media from high tech intranet
to engaging cartoons that convey the key messages on how to apply compliance risk management policies in their work environment.
2.1 Consolidated annual accounts
Risk management (continued)
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