ING Direct 2011 Annual Report Download - page 221

Chief Risk Officer
Risk Integration
and Analytics
Bank
Model Validation
Bank
Market Risk
Management
Bank
Credit Risk
Management
Bank
Operational Risk
Management
Bank
Compliance Risk
Management
Bank
Risk management continued
ING Bank
Executive Level
The risk committees described below act within the overall risk policy and delegated authorities granted by the Management Board Bank:
• The Finance and Risk Committee (F&RC) is a platform for the CRO and the Chief Financial Officer (CFO), along with their respective
direct reports, to discuss and decide on issues that relate to both the finance and risk domains. The primary responsibility of the F&RC is
to co-ordinate, on a high level, the finance and risk decisions that have an impact on internal and/or external reporting;
• ING Bank Credit Committee – Policy (GCC(P)): Discusses and approves policies, methodologies and procedures related to credit, country
and reputation risks within ING Bank. The GCC(P) meets on a monthly basis;
• ING Bank Credit Committee – Transaction Approval (GCC(TA)): Discusses and approves transactions which entail taking credit risk
(including issuer investment risk). The GCC(TA) meets twice a week;
• Asset and Liability Committee ING Bank (ALCO Bank): Discusses and approves on a monthly basis the overall risk profile of all ING
Bank’s market risks that occur in its Commercial Banking and Retail & Direct Banking activities. ALCO Bank defines the policy regarding
funding, liquidity, interest rate mismatch and solvency for ING Bank; and
• Non-Financial Risk Committee Bank (NFRC Bank): Accountable for the design and maintenance of the Risk Management Framework
including the ORM, Compliance and Legal policies, minimum standards, procedures and guidelines; the NFRC structure; development of
tools, methods and key parameters (incl. major changes) for risk identification, measurement and monitoring/ reporting.
Risk Management Function
The risk management function is embedded in all levels of ING Bank organisation.
The Chief Risk Officer, who is a MBB member, bears primary overall responsibility for the Risk management function. The CRO is
responsible for the management and control of risk on a consolidated level to ensure that ING Bank’s risk profile is consistent with its
financial resources and the risk appetite. The CRO is also responsible for establishing and maintaining a robust organisational basis for the
management of risk throughout the organisation.
The organisation chart below illustrates the functional reporting lines within ING Bank risk organisation.
The heads of these departments (Risk General Managers) report to the CRO and bear direct responsibility for risk (mitigating) decisions at the
Bank level. The Risk General Managers and the CRO are responsible for the harmonisation and standardisation of risk management practices.
From December 2011, the reporting lines have been changed. As of then the CCO reports to the new appointed Head of Non-Financial
Risk ING Bank who in his turn reports to the Chief Risk Officer.
In addition two staff departments report to the CRO:
• Risk Integration and Analytics (RI&A), which is responsible for inter-risk aggregation processes and for providing bank-wide risk
information to the CRO and Management Board Bank; and
• Model Validation (MV), which carries out periodic validations of all material risk models used by ING Bank. To ensure independence
from the business and other risk departments, the department head reports directly to the CRO.
Risk policies
ING Bank has a framework of risk management policies, procedures and standards in place to create consistency throughout the
organisation, and to define minimum requirements that are binding to all business units. The governance framework of the business units
aligns with the Bank’s level framework and meets local (regulatory) requirements. Senior Management is responsible to ensure policies,
procedures and standards are implemented and adhered to. Policies, procedures and standards are regularly reviewed and updated via the
relevant risk committees to reflect changes in markets, products and emerging best practices.
1 Who we are 2 Report of the Executive Board 3 Corporate governance 4 Consolidated annual accounts 5 Parent company annual accounts 6 Other information 7 Additional information
219ING Group Annual Report 2011