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Chapter 10 Ethics, corporate governance and internal controls 10/7
It is usual to identify risk at three levels:
• Internal: the impact of the risk absent of any controls.
• Appetite/tolerance: the impact of the risk the insurer is prepared to accept.
• Residual: the impact of the risk after applying mitigation controls.
The level of impact is a combination of frequency and severity. Residual risk should always be at, or
lower than, appetite/tolerance, otherwise the controls are not effective.
The following diagram illustrates a ‘best practice’ risk management framework showing the key features
of the framework as described in the following sections:
Figure 10.1: ‘Best practice’ risk management framework
Governance and a risk management framework
Risk managment Risk tolerance
policy statement
Feedback loop
Own risk and solvency assessment
Feedback loop
Economic and
Continuity analysis
regulatory capital
Role of supervision
C1A Governance and a risk management framework
As part of its overall governance structure, an insurer should establish a sound risk management
framework appropriate to the nature, scale and complexity of its business. The framework should be
integrated with the insurer’s business operations, reflecting desired business culture and behavioural
expectations and addressing all reasonably foreseeable material risks in accordance with a properly
constructed risk management policy.
The establishment and operation of the risk management framework should be led by the insurer’s
board and senior management.
For it to be adequate for capital management and solvency purposes, the framework should have been
stress tested for a sufficiently wide range of outcomes.
C1B Risk management policy
An insurer should have a risk management policy which outlines the way they manage each material
category of risk, both strategically and operationally, and describes the link with the insurer’s tolerance
limits, regulatory capital requirements, economic capital and the processes and methods for Chapter
monitoring risk.
C1C Risk tolerance statement 10
An insurer should establish and maintain a risk tolerance statement which sets out its quantitative and
qualitative tolerance levels and defines tolerance limits for each relevant and material category of risk,
taking into account the relationships between these risk categories.