risk types and management

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    Risk management

    RISK MANAGEMENT FRAMEWORK

    Risk is defined as potential losses or foregone profits that can be triggered by internal and external factors.

    Therefore, the objectives of risk management are identification of potential risks in our operations and transactions,

    in our assets, liabilities, income, cost and offbalance sheet exposures and independent measurement and

    assessment of such risks and taking timely and adequate measures to manage and mitigate such risks within arisk-return framework.

    In DBBL, only calculated risks are taken while conducting banking business to strike a balance between risk and

    return. Risk is clearly identified, mitigated or minimized and if possible eliminated to protect capital and to maximize

    value for shareholders. It is also ensured that on balance sheet and off-balance sheet risks taken by the Bank are

    consistent with risk appetite and strategic objectives of the Bank.

    A wide range of tools and techniques are used to address & mitigate all kinds of inherent and potential risks in

    banking operations. The Bank attaches highest priority to establish, maintain and upgrade risk management

    infrastructure, systems and procedures. In this regard, sufficient resources are allocated to improve skills and

    expertise of relevant banking professionals to manage the risk effectively. The policies and procedures are

    approved by the Board and assessed on a regular basis to bring these to the level of satisfaction required tomanage & mitigate the risks adequately and consistently.

    Ultimate responsibility for effective risk management lies with the Board of Directors of DBBL. The Board and its

    committees like Audit Committee and Executive Committee, set principles and limits, review and monitor various

    risks to assess adequacy of system and to ensure that the Bank is operating within approved systems &

    procedures. Management committees, like ALCO and Credit Committee, also oversee and ensure that sufficient

    risk management systems are in place and these are consistently applied to protect the interest of the Bank.

    RISK MANAGEMENT PROCEDURE

    Approved predetermined po licies & guidelines

    To ensure that risks are properly addressed and protected for sustainable development of the Bank, there are

    approved policies and procedures covering all the risk areas i.e. credit risks, operational risks and market risks.

    These are formulated taking into account Bangladesh Banks Guidelines for Managing Core Risks on Credit Risk

    Management, Internal Control & Compliance, Asset and Liability Management, Foreign Exchange Risk

    Management and Money Laundering Risk Management as well as the business environment in which the Bank

    operates, specific needs for particular type of operations or transactions and international best practice. These

    policies are regularly reviewed and updated to keep pace with the changing operating environment, technology and

    regulatory requirement. Meticulous compliance with the established procedures are ensured to satisfy that the Bank

    is operating within approved procedures and limits and that risks are within tolerable limits to effectively ensure

    long term solvency and sustainable growth of the Bank.

    Risk management infrastructure

    Risk management procedures are approved, monitored, and mitigated at various stages of the Bank with a

    combination of Board, its committees, management committees, management units and Internal Control &

    Compliance Division as detailed below:

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    Board of Directors

    Board oversees and approves all major risk management policies and parameters taking into account market

    condition, regulatory requirement and lessons learned in the past. While setting policies and parameters for credit,

    operational and market risks, a balance is maintained for ensuring smooth banking operations while protecting

    against down-side risk from potential loss or foregone income and to protect interest of shareholders and

    depositors.

    Executive Committee (EC) of the Board

    Executive Committee is responsible to oversee that the management and its committees are operating within

    approved limits and authorities and that all major risks are managed & mitigated effectively and potential and actual

    losses arising from risks are within accepted limits. The Committee also approves credit proposals, administrative

    proposals and major purchases as recommended by the Management Credit Committee, Management Committee

    and Management Purchase Committee.

    Audi t Committee of the Board

    Audit Committee independently monitors all activities of banking operations involving credit risks, operational risks

    and market risks through Internal Control & Compliance Division of the Bank. Risk based audit plan for IC &CD is

    approved by the Committee and its implementation is monitored on a regular basis to ensure that all risk factors are

    adequately addressed and any deviation is quickly corrected to ensure sustainable operation of banking activities.

    Management Committees

    Management Committees like Credit Committee, Asset-Liability Management Committee and Purchase Committee

    ensure compliance with all relevant risk management policies.

    Management units

    Management units like Credit Risk Management Division, Treasury Division, Credit Administration Division, Credit

    Monitoring & Recovery Division etc. ensure and monitor risk management system and compliance with all

    approved limits and procedures at operational level on a daily basis.

    Internal Control & Compliance Division

    Internal Control & Compliance Division on a regular basis independently verifies compliance with all approved risk

    management and internal control policies. Deviations are identified, reported and corrected to mitigate risk on a

    continuous basis and to ensure that the Bank is operating in compliance with all approved and established policies.

    Internal Control & Compliance Division directly reports to the Audit Committee of the Board.

    CREDIT RISK

    Credit risk is the most significant and inherent risk in banking business. Every loan exposure or transaction with

    counterparty involves the Bank to some degree of credit risks. Credit Risk Management is at the heart of the overallrisk management system of the Bank. It is designed and continuously updated to identify, measure, manage and

    mitigate credit risk to maintain and improve quality of loan portfolio and reduce actual loan losses and to ensure

    that approved processes are followed and appropriate due diligence are made in approving new credit facilities and

    renewals.

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    Early warning system

    Operation and performance of loans are regularly monitored to trigger early warning system to address the loans

    whose performance show any deteriorating trend enabling the Bank to grow its credit portfolio in a sustainable way

    to ensure higher quality and lower risk with the ultimate objective to protect the interest of depositors and

    shareholders.

    Credit policy approved by the BoardThe Board approves the major policy guidelines, growth strategy, exposure limits for particular sector, product,

    individual company and group, keeping in view regulatory compliance, risk management strategy and industry best

    practice.

    Credit approval is delegated properly

    Credit approval authorities are carefully delegated to the Executive Committee of the Board and appropriate level of

    management to strike a balance between adequate control and flexibility in credit operations to ensure full

    transparency and accountability at all levels.

    Independent Credit Risk Management DivisionThere is an independent risk management division to assess credit risks and suggest mitigations before

    recommendation of every credit proposal.

    Separate Credit Administration Division for documentation

    A separate Credit Administration Division confirms that perfected security documents are in place before

    disbursement. DBBL is continuing a unique process of rechecking security documentation by a second legal

    adviser other than the lawyer who vetted it originally.

    Independent Credit Monitoring & Recovery Division and Management Recovery

    Committee

    An independent and fully dedicated credit monitoring and recovery division monitors the performance and recovery

    of loans, identify early signs of delinquencies in portfolio and take corrective measures to mitigate risks, improve

    loan quality and to ensure recovery of loans on time including legal actions. This department also monitors risk

    status of loan portfolio and ensures adequate loan loss provision. There is a dedicated and high-level management

    recovery committee to deal with the problem loans for early and most appropriate settlements.

    Adequate provision & suspension of interest

    Interest accrued on classified loan is suspended and adequate provision is maintained there-against as per

    Bangladesh Banks Guidelines.

    Credit operations are subject to independent Internal Audit

    Internal Control & Compliance Division independently verifies and ensures, at least once in a year, compliance with

    approved lending guidelines, Bangladesh Bank guidelines, operational procedures, adequacy of internal control

    and documentation. Internal Control & Compliance Division directly reports to the Audit Committee of the Board.

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    Reporting to Board /Executive Committee

    Overall quality, performance, recovery status, risks status, adequacy of provision of loan portfolio is regularly

    reported to the Board of Directors/EC for information and guidance.

    MARKET RISK

    Market risk is the risk of losses in on and off-balance sheet positions arising from movements in market price suchas changes in interest rate and price of equity, foreign exchange and commodity.

    Liquidity, interest rate and foreign exchange risks

    The Treasury Division manages the liquidity, interest rate and foreign exchange risks with oversight from Asset-

    Liability Management Committee (ALCO) which is chaired by the Managing Director including top management and

    senior executives of the Bank. The Committee meets at least once a month. The Board approves all risk

    management policies, sets limits and reviews compliance on a regular basis. The overall objective is to provide cost

    effective funding to finance the asset growth and trade related transactions, optimize the funding cost, increase

    spread with the lowest possible liquidity, maturity, foreign exchange and interest rate risks.

    Liquidity risk

    Liquidity risk is the risk that we may not meet our financial obligation as they become due. Liquidity risks also

    include our inability to liquidate any asset at reasonable price in a timely manner. It is the policy of the Bank to

    maintain adequate liquidity at all times and in both local and foreign currencies. Liquidity risks are managed on a

    short, medium and long-term basis. There are approved limits for credit-deposit ratio, liquid assets to total assets

    ratio, maturity mismatch, commitments for both in on-balance sheet and off-balance sheet items and borrowing

    from money market to ensure that loans & investments are funded by stable sources, maturity mismatches are

    within limits and that cash inflow from maturities of assets, customer deposits in a given period exceeds cash

    outflow by a comfortable margin even under a stressed liquidity scenario.

    Interest rate risk

    Interest rate risk is potential reduction in net interest income caused by changes in the level of interest rates. In

    DBBL, it is ensured that the Bank is not subjected to undue interest rate risks due to interest rate mismatch and

    maturity mismatch. Fixed rate assets are not financed by floating rates liabilities or vice versa.

    Foreign exchange risk

    Foreign exchange risk is potential loss arising from changes in foreign currency exchange rate in either direction.

    Assets and liabilities denominated in foreign currencies have foreign exchange risks.

    In order to further strengthening the foreign exchange risk management, DBBL has strengthened and restructured

    its dealing room with the help of advanced technological equipment and experienced personnel. The Bank operates

    its foreign exchange and money market activities under a centralized and single functional area. Bank's Exchange

    Rate Committee meets on a daily basis to review the prevailing market condition, exchange rate, exposure and

    transactions to mitigate foreign exchange risk.

    OPERATIONAL RISK

    Operational risk is the risk of loss resulting from inadequacy or failure of internal processes, systems and people or

    from external events.

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    Internal Control & Compliance risk

    The Board of Directors approved updated policy guidelines on Internal Control & Compliance Risk (ICC).

    Management thereby restructuring the organizational chart of the Bank in accordance with the instructions of

    Bangladesh Bank for managing core risks. In line with aforesaid policy guidelines, Bank's own working manual on

    ICC has been approved by the Board of Directors of DBBL and the manual is now in operation.

    Internal Control & Compliance Division of the Bank under direct supervision of Audit Committee of the Board has

    been implementing detail guidelines on ICC risk management to assess and mitigate risks and as part of it the

    IC&CD has been divided into three (3) independent units; namely:-

    a) Audit & inspection unit

    b) Monitoring unit

    c) Compliance unit

    The units have been functioning independently and separately with direct reporting lines to the Head of IC&CD.

    In addition, Departmental Control Function Check List has been introduced in the branches and divisions at Head

    Office under direct supervision of Monitoring Unit of IC&CD which ensures compliance with regulatory rules and

    regulations as well as general banking norms and procedures.

    Documental Check List has been brought in practice under supervision of dedicated units. Exceptions are

    addressed monitored and corrected on a regular basis.

    Policy guidelines on RISK BASED INTERNAL AUDIT (RBIA) system have been formulated and the branches have

    already been brought under RBIA networks. As per RBIA, marks have been allocated for rating of the branches in

    terms of business risk and control risk. The branches scoring higher are being subjected to more frequent audits.

    It is a Policy of the Bank to put all brances of the Bank under any form of audit once in a year and IC&CD has been

    working in that direction.

    All these activities of the Internal Control & Compliance Division are devoted to address and mitigate operationalrisks of the Bank in more effective way to ensure effciency and effectiveness of performance, ensure reliability and

    completeness of financial and management information and to ensure compliance with legal and regulatory

    requirements.

    Money Laundering risk

    As prevention of Money Laundering had become a burning issue in the beginning of this century, Money

    Laundering Prevention Act, 2002 was enacted in our country to give tight rein on money laundering process.

    Bangladesh Bank too undertook a project in the year 2003 to review the global best practices in the risk areas in

    view of globalization of business and identified 5 (five) core risks for implementation by the banks which included,

    among others, Money Laundering risk.

    In line with the money laundering law and relevant guideline of Bangladesh Bank on Money Laundering risk, our

    Bank has already formulated guidelines on policies & procedures on prevention of Money Laundering. The prime

    objective of the guidelines is to combat Money Laundering which became rampant in recent years.

    As per the guidelines, Account Opening Form of our Bank has been redesigned with provision for obtaining

    particulars of Personal Identity of customer and Transaction Profile. The Bank has also undertaken enhanced due

    diligence in case of opening of accounts of Politically Exposed Persons( PEP) as per directive of Bangladesh Bank

    which is in line with recommendation of Financial Action Task Force of U.N. Anti Money Laundering units have

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    been set up in all the branches under a central unit at Head Office. Basic training has been imparted to all the

    officers of the Bank on compliance with rules and regulations of Money Laundering Act so as to prevent opening of

    suspicious accounts and identify suspicious transactions.

    Legal risks

    In DBBL legal risks are covered by recognizing potential losses from litigation or possible litigation at an early stage

    and by formulating solutions for reducing, restricting and avoiding such risks and creating adequate provision

    thereagainst.

    OTHER RISKS

    Business risk

    Business risk covers the risk of losses arising from lower non-interest income and higher expenses from the

    budgeted amount. The business risk is resulted from the market condition, customer behavior or technological

    development that may change compared to the assumptions made at the time of planning.

    Business risk in DBBL is managed by setting clear targets for specific business units in term of business volume,

    income, cost, cost / income ratio, quality of assets etc. with an ongoing process of continuous improvement.

    Reputational risk

    Reputational risk is defined as the risk of losses, falling business volume or income as well as reduced value of the

    company arising from business events that may reduce the confidence of the customers & clients, shareholders,

    investors, counterparties, business partners, credit rating agencies, regulators and general public in DBBL.

    The branches and operational divisions are directly responsible for reputational risks arising from their business

    operations. Reputational risks may also arise from other risks and even increase those risks. The management

    ensures that DBBL is aware of any changes in market perceptions as soon as possible. Accordingly, all business

    policies and transactions are subjected to careful consideration. DBBL takes necessary precautions to avoid

    business policies and transactions, that may result in significant tax, legal or environmental risks. Reputation risk is

    also factored into major credit decisions that may lead to credit proposal being declined.

    Compliance risk

    The success of DBBL is largely dependent on the trust and confidence of our existing and potential customers, our

    shareholders, our staff, our regulators and the general public in our integrity and ethical standard. This confidence

    largely depends on meticulous compliance with

    applicable legal and regulatory requirements and internal policies of DBBL. The confidence also depends on

    conformity with generaly accepted market norms and standards in our business operations. The Board of Directors

    is primarily responsible for compliance with all applicable norms and regulations. The Board discharges its

    responsibilities itself and through delegation of authorities to Executive Committee and Audit Committee of the

    Board. The objective is to identify any compliance risks at an early stage that may undermine the integrity and thesuccess of DBBL and to mitigate the risks in most appropriate way.

    CAPITAL PLAN AND MANAGEMENT

    The Bank is committed to maintain a strong capital base to support business growth, comply with all regulatory

    requirements, obtain good credit rating and CAMELS rating and to have a cushion to absorb any unforeseen shock

    arising from credit, operational and market risks.

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    The capital maintenance and dividend policies are pursued taking into consideration the

    following factors

    Increased capital requirement for sustainable business growth.

    Keeping sufficient cushion to absorb unforeseen shock or stress.

    Cost effective options for raising Tier 1 and Tier 2 capital.

    Improving credit rating and CAMELS rating of the Bank.

    Meeting regulatory requirements.

    Meeting covenants of lenders.

    The Board is responsible to ensure capital management within a broad framework of risk management.

    The Bank has been pursuing a dividend policy that must ensure satisfactory return for shareholders as well as

    sustainable growth of the Bank with strong capital adequacy ratio to protect greater interest of depositors and

    shareholders.

    As per BRPD Circular Letter No. 11 dated August 14, 2008, the total capital of the Bank should be raised to Taka

    4,000 million latest by August 11, 2011 within which total paid up capital would be Taka 2,000 million. The Bank is

    well positioned to meet that requirement much earlier before the deadline.

    The Banks Tier 2 capital is strengthened by subordinated debt obtained from FMO, revaluation of fixed assets and

    revaluation of held to maturity securities. Other alternative options to raise Tier 2 capital would be explored as and

    when necessary.

    PREPARATION FOR BASEL II ACCORD STRENGTHENING RISK MANAGEMENT SYSTEM AND

    CAPITAL BASE OF THE BANK

    In order to make the banks in Bangladesh more shock absorbent as well as to cope with international best practice

    for risk management and, a sound and robust banking industry, Bangladesh Bank has taken measures to

    implement BASEL II from January 2009.

    BASEL Committee on Banking Supervision published a more comprehensive new package on capital adequacy

    requirement known as BASEL II for strengthening the capital adequacy, improving supervisory system to assess

    the adequacy of capital based on a thorough review of risks, reinforce risk management system and market

    discipline with the ultimate objective of having strong capital base that are commensurate with risk profile of the

    Bank comprising credit risk, market risk and operational risk that can ensure long term stability and solvency of

    banking company and banking sector as a whole.

    A National Steering Committee comprising senior officials from banking industry, Bangladesh Bank and Chartered

    Accountant Firms has been constituted. Furthermore, a Coordination Committee and a Basel II implementation Cell

    have been established. In the meantime, Bangladesh Bank has done two studies one is self-audit on Basel core

    principles for effective Bank supervision and the second one is quantitative impact study in order to assess

    readiness of the banks for implementation of Basel II.

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    Under standardized approach, Basel II requires the recognition of External Credit Assessment Institutions for this a

    guideline has been prepared by BB and recognition process of credit rating agencies is under process. Bangladesh

    Bank has already issued Guidelines on Risk based capital adequacy for banks (revised regulatory capital

    framework in line with BASEL II) vide BRPD Circular No. 09 dated December 31, 2008.

    In line with Bangladesh Bank requirement, the Bank has already formed a Basel II Implementation Unit to ensure

    smooth and timely implementation of Basel II Accord. Capacity building measures are underway so that the Bank

    is fully prepared to adopt the Accord in 2009.