** Additonal information on conduct can be found the Annual Report **
The character of our company is formed by the way we behave in our day-to-day working lives. The conduct of employees can seriously damage our business and reputation – but when we do the right thing, our customers trust and value us, and our colleagues take pride in working for the bank.
Our Code and YES check
Our Code provides guidance on the behaviour we expect from all employees, and lays out the standards of conduct that support our values. It sets out what we expect of each other and what our customers and communities expect of us.
The YES check is a simple tool that asks five questions to guide the thinking behind our decisions and actions. We use our values to help us think through decisions and make sure we do the right thing. When in doubt, we use the YES check for guidance.
RBS is committed to participating in national and international efforts to counter bribery, corruption, money laundering, sanctions violations and terrorism financing. We have a strategy to be amongst the best in class, with a proactive approach to financial crime risk, whilst deterring abuse of our products and services for criminal activity.
- We published revised Anti-Bribery and Corruption, Anti-Money Laundering and Sanctions Policies and Mandatory Procedures.
- We conducted a Financial Crime Risk assessment, asking each RBS franchise and function to identify, understand and manage their financial crime risk, including bribery and corruption risks.
- 95.5% of employees completed the core Anti-Bribery and Corruption (ABC) Group Policy Learning training;
- 95% of employees completed the core Anti-Money Laundering Group Policy Learning training; and
- 98.9% of employees completed the core Sanctions Group Policy Learning training;
- with the remainder are being managed to completion.
Managing conduct risks
In 2015, a new Conduct Risk Appetite Framework was established and is being embedded across the bank. The framework is divided into seven pillars covering the understanding, management and reporting of risk. It is designed to ensure a consistent approach to risk appetite – the amount and type of risk we are willing to take in order to achieve our goals – across the bank.
The conduct risk objectives provide a framework that helps RBS staff to think about the lifecycle of a product, focusing on its suitability for customers. This has helped us to simplify our product structure, making the products we offer more consistent, transparent and easy to use.
The Board and its senior committees receive updates on conduct risk exposures and action plans through regular reporting.