Compliance Conduct & Ethics (CC&E) NL

Conduct is the risk vertical which covers the compliance risks arising from potential or perceived misconduct by ING or its employees towards its customers, market integrity, business partners, employees and other stakeholders. The team consist of two pillars: Customer & Markets (C&M) and Employee & Organizational (E&O) conduct.

C&M deals with (i) the risk related to treating customers unfairly and not having their best interests in mind throughout the product life cycle (from design to advise and claims handling), and ii) market conduct - running deals and operations not in line with good capital markets functioning along the product/service life cycle (i.e., pre-trade, execution, and post-execution). E&O will focus on the interrelated risk drivers conduct, culture and ethics. Under Ethics, the ING Global Code of Conduct and the Whistleblowing reporting policy are captured. The team will deal with the risks arising from illicit bribery & corruption activities conducted by ING as whole, its employees and 3rd parties acting on behalf of the bank, thereby failing to comply with Bribery & Corruption laws (e.g. UK Bribery Act & FCPA). The other activities of the team focus on the end-to-end processes relating to: i) employee conduct, ii) organisational conduct iii) conflict of interest, iv) anti competition risk.

The purpose of Conduct Compliance & Culture is to drive the first line of defence/business in the implementation of a conduct and culture risk management framework that is proportionate to the volume and the nature of its risks. This includes achieving a positive risk culture through training & awareness, proper guidance, constructive challenge and independent advisory activities. The vision of Conduct Compliance & Culture is to aim for ING to have conduct and culture embedded in its DNA so it can better help our customers to be a step ahead in their lives. It has an effective compliance organization in place that manages and oversees the operation of the conduct and culture risk management framework covering the risks: Conflict of Interest, Unfair Customer Treatment, Market Conduct, Anti-Competitive Conduct, Ethics, ESG, Compliance Governance and Regulatory Registration. You strive for efficiency and frictionless processes (as part of “Productization of Compliance” concept) and you actively interact with your different internal and external senior stakeholders.

Scope of activities: The new scope consolidates CC&E responsibilities across ING NL as universal bank, including WB next to (existing) Retail and additional risk "ABC" which moved from FCC team to CC&E team.

Tasks and Responsibilities

• You are effectively steering and managing the expert area Conduct Compliance & Culture within the Tribe with end-to-end accountability;

• You are pushing and co-defining Compliance NL’s strategy, more specifically on CC&E, in line with the overall NL Strategy ‘Growing the difference’

• You contribute to the vision (part of Productization of Compliance) in your expert area, introduce and nurture innovation within it;

• You manage the processes and activities within your expert area and provide accurate and timely reporting to senior management;

• You advice on and challenge the compliance risks associated within your expert area, shall define the applicable compliance requirements, establish mandatory policies, and/or written mandatory guidance on the appropriate implementation and embedment of compliance-related requirements;

• You advise and instruct management and employees on compliance-related requirements, assists them in educating on how to mitigate compliance risks, and escalate identified issues in order to maintain compliance with laws and regulations and remain within NL’s risk appetite;

• You share best practices for continuous feedback loop to improve and execute the activities of the Compliance Management Risk Cycle;

• Take the lead in further shaping and embedding a risk-based approach across the conduct risks, ensuring prioritization of high-impact risks, effective resource allocation, and demonstrable impact through data-driven insights (part of Productization of Compliance).

• You manage, coach employees and develop talents. You ensure the teams are adequately staffed in terms of both quality and quantity. Create the required environment and enables employees to do their jobs well, both now and in the future. Support employees in the specific expertise, creates a climate of learning and growing and evaluates results and existing knowledge; and

• You establish and maintain strong (sustainable) relationships with key stakeholders, focused on a clear understanding of their challenges and opportunities. Navigate distractions and politics to deliver on objectives effectively.