Board Committees

Sustainability, culture and conduct-related topics are routinely addressed at meetings of the Board committees. For example, as part of its performance assessment of the Executive Board for the purposes of determining compensation, the Compensation Committee considers the achievements of Executive Board members not only in terms of financial performance, but with respect to non-financial aspects as well, such as risk and compliance, conduct and ethics, and talent development. In addition, at meetings of the Compensation Committee and as necessary, members review and approve any sanctions imposed on senior employees’ compensation for conduct-related matters.


The Conduct and Financial Crime Control Committee reflects the Group’s priority to rigorously address financial crime risk and ensure that the highest standards of conduct and vigilance are maintained throughout the Group. The Conduct and Financial Crime Control Committee assists the Board in fulfilling its oversight duties with respect to the Group’s exposure to financial crime risk. It is tasked with monitoring and assessing the effectiveness of financial crime compliance programs and initiatives focused on improving conduct and vigilance within the context of combatting financial crime.

Each time the Audit Committee meets, it is provided with a compliance update, covering aspects such as compliance trends, issues and developments, including information on the conduct risk framework. Critical compliance initiatives and specific conduct matters may also be reviewed jointly with the Conduct and Financial Crime Control Committee.

Climate change-related responsibilities are explicitly included in the Board’s Risk Committee charter. In 2020, the Risk Committee conducted its annual review of our risk and sustainability framework, which included a discussion of key sustainability developments and steps taken by management to integrate sustainability considerations more closely into our risk assessment process. The Risk Committee also received a comprehensive briefing on the progress of the climate risk strategy, which, among other aspects, covered key external developments with respect to the management of climate risk at banks, as well as internal progress on the development of energy transition frameworks for corporate clients in industries impacted most by climate change, and progress against our existing commitments, such as the restriction of certain business activities in carbon-intensive sectors. As our journey progresses towards the setting of quantitative risk appetite metrics, we expect to update our reporting to include such metrics at the applicable governance levels. Furthermore, sustainability and climate risks feature in the monthly Group risk reports, which cover key risks to the firm and are provided to all members of the Board of Directors.