ING Direct 2009 Annual Report Download - page 239

In addition to effective reporting systems, ING has a Whistleblower procedure which encourages staff to speak up if they know of
or suspect a breach of external regulations or internal policies or Business Principles.
The Compliance Risk Management function
The Chief Compliance Officer (CCO) reports directly to the Chief Risk Officer who is a member of the Executive Board. The CCO is
responsible for developing and establishing the company-wide Compliance Risk Management Charter & Framework, establishes the
Minimum Standards for managing Compliance Risks and assists and supports the Executive Board in managing ING’s Compliance Risks.
ING uses a functional approach within Business Lines to ensure systematic and consistent implementation of the company-wide Charter &
Framework, policies, Minimum Standards and related procedures. The Local Compliance Officer has the responsibility to assist local
management in managing Compliance Risk within that business unit. The regional or division Compliance Officer has a management and
supervisory role over all functional activities of the Compliance Officers in the respective region or division. Reporting functionally into the
CCO, the Business Line Compliance Officers perform this task for their Business Line and also provide leadership and overall direction to
the regional or divisional Compliance Officers.
To avoid potential conflicts of interest, it is imperative that the Compliance Officers are impartial and objective when advising business
management on Compliance Risk in their Business Unit, region, division or Business Line. To facilitate this, a strong functional reporting line
to the next higher level Compliance Officer is in place. The functional reporting line has clear accountabilities relating to objective setting,
remuneration, performance management and the appointment of new Compliance Risk Management staff as well as obligations to veto
and escalate.
Compliance Risk Management Policies and Tools
The responsibility of the Compliance Risk Management function is, in accordance with the Charter and Framework, to proactively:
Identify, assess, monitor and report on the Compliance Risks faced by ING;•
Assist, support and advise management in fulfilling its responsibilities to manage Compliance Risks;•
Advise any employee or officer with respect to their (personal) obligations to manage Compliance Risks.•
The Framework consists of three key components: the Compliance Chart, an Advisory component and the Scorecard as illustrated below
Compliance Risk Management Framework
The
chart
Risk
Assessment
Compliance
Risk
Mitigation
Compliance
Risk
Monitoring
Compliance
Risk
Reporting
Identification of
Compliance Risk
Obligations
A
BE
CD
A
D
V
I
S
O
R
Y
&
S
C
O
R
E
C
A
R
D
1. The Chart
The Chart is an output from five key activities carried out in accordance with the requirements of the Framework:
A. Identification of Compliance Risk Obligations;
B. Risk Assessment;
C. Compliance Risk Mitigation (includes Training and Education);
D. Compliance Risk Monitoring (includes Action Tracking);
E. Compliance Risk Reporting (includes Incident Management).
ING Group – Non-financial risks
2.1 Consolidated annual accounts
Risk management (continued)
ING Group Annual Report 2009 237