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contained therein) and any subsequent changes,  mittees each of which has a charter that clearly defines its
                       and review the plan (at least annually) to ensure     purpose, composition, structure, frequency of meetings,
                      its appropriateness;                    duties, tenure, and reporting lines to the Board.

               e)     Ensure the organization’s structure, culture,  In line with best practice, the Chairman of the Board does
                       infrastructure, financial means, managerial   not sit on any of the Committees. The Board has six stand-
                      resources and capabilities, as well as systems and  ing committees namely: the Board Risk Management Com-
                       controls are appropriate and adequate to   mittee, the Board Audit Committee, the Board Remuner-
                      support the implementation of its strategies.   ation Committee, the Board Governance and Nomination
                                                              Committee, the Board Credit and Finance Committee and
               f)     Review high-level reports periodically submitted   the Board Digital and IT Committee.
                      to the Board on the overall strategic risk profile,
                      and ensure that any material risks and strategic  The management committees which exist in the Bank in-
                       implications identified from those reports are  clude:  The  Executive  Committee  (EXCO),  Enterprise  Risk
                       properly addressed; and                Management Committee (ERMC), Management Cred-
                                                              it Committee (MCC), Group Asset & Liability Committee
               g)     Ensure that senior management is competent in    (Group ALCO), and Operational Risk Management Com-
                      implementing strategic decisions approved by   mittee (ORMC).
                      the Board, and supervising such performances on
                       a continuing basis                     Without prejudice to the roles of these committees, the full
                                                              Board retains ultimate responsibility for risk management.
               THE BOARD AND MANAGEMENT COMMITTEES

               The Board of Directors is the highest approval authority
               for credit risk policies and credit facilities in Access Bank. It
               carries out its oversight function through its standing com-




                 COMPLIANCE RISK MANAGEMENT





               The Bank organizes its compliance function and sets pri-  MEASUREMENT, MONITORING  AND MANAGEMENT
               orities for the management of its compliance risk in a way   OF COMPLIANCE RISK
               that is consistent with its own risk management strategy   In Access Bank, compliance risk is:
               and structures.
                                                              •      Measured by reference to identified metrics,
               The implementation of our compliance function trans-     incident assessments (whether affecting Access
               formation which we commenced in 2015 reached an ad-     Bank or the wider industry), regulatory feedback
               vanced stage in 2017. The integrated compliance function       and the judgment of our external assessors as it
               working closely with Internal Audit and Operational Risk to       relates to AML/CFT and other compliance
               achieve risk convergence provided backbone for integrat-  vulnerabilities;
               ed assurance and higher visibility of risk management and
               control consciousness across the Group.        •      Monitored against our compliance risk
                                                                     assessments and metrics, the results of the
               The compliance function has continued to redefine its ap-     continuous monitoring and reporting activities of
               proach from the traditional inspectorate function into an       the compliance function and the results of
               advisory role with intense focus on regulatory intelligence      internal and external audits and regulatory
               gathering and closer cooperation with business units with-     inspections; and
               in the Bank and the Group acting as a contact point for
               compliance  queries  from  staff  members.  We  enhanced   •   Managed by establishing and communicating
               the monitoring to online real time to catch up with the cur-     appropriate policies and procedures, training
               rent digital banking environment instead of the old process      employees on them, and monitoring activity to
               of waiting for the next day to do transaction call over.  We       assure their observance.
               receive alerts of transactions on a risk based approach by
               focusing on the high-risk areas thereby spotting non-con-  The Bank continues to recognize its accountability to all its
               formities on time.                             stakeholders under the legal and regulatory requirements


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