Sound Compliance Risk Management
Clear and practical policies and procedures are embedded in ING business processes in all Business Lines. Systems are in place to enable management to track current and emerging Compliance Risk issues, to communicate these to internal and external stakeholders, and to drive continuous improvement. ING understands that good Compliance Risk Management involves understanding and delivering on the expectations of customers and other stakeholders, thereby strengthening the quality of key relationships.
Non Financial Risk policies and procedures include:
- The ING Group Charter & framework
- Insider regulations
- Whistleblower procedure
- Financial Economic Crime policies
Environmental and Social Risk Policies
ING avoids business dealings that are not in line with our visions on corporate responsibility. For that reason, ING has also developed environmental and social policies to help our employees identify deals that carry sustainability and ethical challenges. The Environmental & Social Risk Policies provide the framework for responsible business engagements and are an integral part of ING’s Risk Management portfolio. ING’s current ESR Policies are focused on:
- business activities of clients.
- environmental and social profile and track records of clients.
- environmental and social impacts linked to project financings.
Environmental and Social Risk Policies
Environmental & Social Risk (ESR) Policies provide the framework for responsible business engagements and are an integral part of ING’s Risk Management portfolio.
The current set of ESR Policies is grouped into the following three categories:
- General ESR Policies: the ESR assessment is based on the business activities of the clients.
- Sector Specific ESR Policies: the ESR assessment is based on environmental and social profile and track records of clients.
- Equator Principles: the ESR assessment is based on the project impacts and the environmental and social track record of clients and or sponsors.
Learning
By having clear policies and extensive monitoring ING aims to reduce incidents of non compliance to a minimum. This requires the education of all ING’s (107.000) employees on their roles and responsibilities in managing compliance risks.
During 2009 ING Group Compliance Risk Management continued the roll out of an aggressive training programme aimed at employees, managers and compliance professionals. Trainings include:
The Leading Compliance Risk Management in your business. class room training targeted the top four echelons of ING management (Bank and Insurance) worldwide. It ensured over 12,000 Managers not only gained a deeper understanding of the effective embedding of ING’s Three Lines of Defence model and the strategic value of Compliance Risk Management, but also learned practically what actions they can take to strengthen the management of Compliance Risk as well as how to apply the Framework and tools
Compliance Officer Training Group Compliance RM worked closely with the Business Lines on developing this week long programme which focussed on technical knowledge and personal effectiveness skills for the Compliance Risk Management staff.
OUTLOOK 2010
In addition to the implementation of improved Compliance Risk Management tools and processes, Group Compliance Risk Management will continue to raise awareness on managing compliance risks by further focussing on group wide communication, training and education.
Amongst the innovations for 2010 are:
- Raising awareness of compliance risks through an innovative cartoon campaign.
- An integrated Web 2.0. knowledge portal developed to facilitate knowledge sharing
- A manager lead version of the Leading Integrity Behaviour education programme will be rolled out throughout ING
- A new half day Integrity behaviour programme will be delivered to all new ING employees as part of their induction to ensure that they have a deep understanding of ING’s commitment to its Business Principles, Environmental and Social Responsibility and compliance standards and practices.
- Following the agreement with the European Commission, Group Compliance Risk Management will work closely with the European Commission representatives on monitoring the adherence to the EC specified requirements.
- The restructuring of ING will continue to be managed carefully from a Compliance Risk Management perspective and awareness, procedures and processes around potential conflicts of interest and use of inside information are tightened. In addition, the operational compliance risk management processes such as, threshold reporting, screening and monitoring of customers and personal transactions monitoring will be executed for divested units as