Managing the CFCC teams and for delivering the CFCC book of work in for Uganda as well as implementing the vision and strategy of the CFCC function and the Enterprise Management Framework (ERMF). Be the main escalation point in Uganda for all CFCC related issues, including regulatory matters.

The accountability set out in the rest of the document will apply to Uganda, where I will be assigning accountabilities of the Heads of CFCC. I will provide direction in Uganda as described below, be the main point of contact and escalate risks/issues where appropriate to the region and relevant forums on behalf of my country. I will take full accountability for the CFCC function in Uganda as delegated by the Cluster Head of CFCC for Uganda.

First line accountability for the implementation of Conduct, Financial Crime and Compliance policies, procedures and processes to the extent the processes have been identified as owned by the CFCC function, in line with the Group’s process universe as set out in the Group Operational Risk Framework, including activities within the processes owned by the CFCC function that are hubbed or outsourced.

Insofar as they relate to conduct and compliance be accountable for consolidating Uganda and providing details of developments giving rise to a material risk, serious regulatory breaches or breaches of risk tolerances (as agreed by the Board from time to time) may occur and notifying any such breaches to (as appropriate):

• the Cluster Head, CFCC, Uganda
• the relevant Heads, Business / Function

Accountable for:

• Managing the CFCC function in Uganda. This includes oversight of Conduct, Compliance and Financial Crime matters, in Uganda.
• Managing the delivery of the SCB financial crime risk framework in Uganda. Financial crime risk for the purpose of this role covers: anti-money laundering, countering terrorist financing, countering weapons proliferation financing, compliance with financial sanctions and asset freezes; and anti-bribery.
• Driving the execution of the various CFCC frameworks in Uganda, in compliance with applicable regulations, internal policies, procedures and codes so SCB operates within the letter and spirit of the law and in so doing protect the reputation of SCB with its regulators and balance the needs of other stakeholders.
• Working collaboratively with other relevant CFCC teams, Advisory and FC, to support the function’s stakeholders (including those in the businesses) for all CFCC issues and risks in Uganda.
• Leading Uganda CFCC function to meet its commitment of being “Here for Good”.
• Proactively supporting and challenging the country’s CEOs, businesses and functions to exhibit appropriate conduct, comply with regulatory and CFCC requirements and strive to achieve fair outcome for the Group’s clients.
• Maintaining independence, delivering timely responses, and timely escalation of risks and issues where the management tolerance of the Group is exceeded for Uganda.
• Developing and maintaining constructive and effective stakeholder relationships with the relevant business and supporting functions, and to assist the Cluster Head CFCC to interface with and support all key stakeholders for Uganda.
• Oversight for management of regulatory relationships with all the country’s regulators.

Insofar as they relate to financial crime risks, be accountable for Uganda to provide details of developments giving rise to a material risk, serious regulatory breaches or breaches of risk tolerances (as agreed by the Board from time to time) may occur and for notifying any such breaches to (as appropriate):

• the Cluster Head, FCC, Kenya and East Africa
• the relevant Heads, Business / Function

Head, CFCC is accountable to the principal, FC Uganda for the below:

(a) the discharge of authorities delegated by the Global Co-Heads, FCC (as Risk Framework Owner for FCC) to the role holder under the Delegation of Authorities Document;

(b) executing actions agreed with the Global Co-Heads, FCC that require escalation to or action in the countries, including changes to their first line processes;

(c) escalating FCC matters of relevance from key governance forums; and,

(d) maintaining sufficient resources with the necessary knowledge and skills required by FCC policies and procedures to discharge authorities, or escalating to the Cluster Head, FCC Kenya and East Africa, where that is not possible without compromising other accountabilities.

Strategy

• Drive and implement the vision, strategy and direction in Uganda, consistent with the CFCC vision and strategy as communicated by Cluster Head, CFCC Kenya and East Africa and Cluster Head, FCC, Kenya and East Africa for the CFCC function aligned with the broader strategic agenda and growth aspirations of the Group and Cluster business.
• Acccountable to ensure that there is adequate support (people, processes, tools, frameworks, systems) in CFCC, Uganda to support sustainable business growth and address CFCC risks.
• Promote the culture and practice of CFCC standards (including conducting business within regulatory requirements, and to high ethical standards) within the Bank and embed a Here for good culture and the Group Code of Conduct.

Business

• Develop a comprehensive understanding of the Uganda business model and strategy to provide substantive support and challenge in order to enable appropriate and sustainable CFCC outcomes.
• Accountable for effective management of CFCC matters across Uganda working closely with GB, CB and Retail Business CFCC advisory at the Cluster and Region. Assume active involvement in problem-solving and crisis management over critical issues that have an impact on the Bank’s business/operations in Uganda
• Analyse comprehensive impact of CFCC matters on the relevant business areas and their operations.
• Accountable for communicating, implementing and escalating key changes to internal policies, procedures and standards and accountable to ensure it is cascaded (in region/country), in coordination with Group communications.
• Support relevant stakeholders to make decisions based on current and possible future policies, practices, and trends and provide robust challenge to all relevant business and functions stakeholders where activities are outside of risk tolerance / appetite for Uganda.
• Accountable for oversight of advice provided to the relevant stakeholders on the interpretation and application of regulatory expectations, laws, best practices and policies related to CFCC.

Processes

• Act under delegation from the respective Risk Framework Owners for the principal risk types of Conduct, Financial Crime and Compliance in discharging the accountabilities contained in the ERMF in Uganda.
• Recommending for approval by the relevant Risk Committees, appropriate policies/processes/DOls to address CFCC risks, aligning them with relevant regulatory requirements for Uganda.
• Accountable for appropriate support and challenge to the Bank’s senior management to ensure that they establish and monitor appropriate processes for compliance with CFCC policies, procedures and standards (including meeting regulatory obligations and maintaining high standards of conduct) for Uganda
• Accountable for governance and oversight over the implementation of CFCC-related policies and procedures in Uganda to ensure compliance with such policies and procedures.

People and Talent

• Lead through example and build the appropriate culture and values. Set appropriate tone and expectations from the Uganda CFCC team and work in collaboration with risk and control partners.
• Accountable for the provision of ongoing training and development of people and ensure that holders of all critical functions are competent, suitably skilled and qualified for their roles ensuring that they have effective supervision in place to mitigate any risks for Uganda.
• Employ, engage and retain high quality people Uganda, with succession planning for critical roles. Create a one- team CFCC culture of openness, trust and risk awareness, where ethical, legal, regulatory and policy compliant conduct is the expectation of all and norm.
• Ensuring CFCC function in Uganda are adequately resourced and capacitised.
• Accountable for reviewing team structure/capacity plans and making people changes proactively and in line with HR guidance to meet requirements for Uganda.
• Set and monitor job descriptions and objectives for direct reports and provide feedback and rewards in line with their performance against those accountabilities, responsibilities and objectives on a continuous performance basis for Uganda.
• Regularly and on a timely basis appraise performance as well as proactively manage attrition when needed for Uganda.
• Assess capability and skill of the team on an ongoing basis to ensure alignment of skill set to the risk management demands of the business Uganda.
• Provide and establish regular communication, team engagement and management meetings for Uganda.

Risk Management

• Act as Risk Owner under the Group’s Risk Management Framework for Regulatory Compliance Processes for Uganda.
• Identify and assess sources of regulatory risks and ensure that systems and controls are appropriate to mitigate and manage risks within acceptable risk tolerance levels. Report on material regulatory, CFCC risks for Uganda.
• Implement and support, in collaboration with the relevant Group CFCC teams, effective programs for CFCC monitoring, surveillance and assurance in for Uganda.
• Accountable to effectively manage CFCC matters and to maintain oversight of risk mitigating action plans to manage issues for Uganda.
• In the event of senior breaches or where risk tolerances have been breached, be the main escalation point and inform senior management and relevant regulators and ensure that actions are taken quickly to remediate and/or activities are ceased for Uganda.
• Anticipate and escalate horizon risks in the area of CFCC that may have a significant impact on the Group and develop effective strategies to mitigate such horizon risks.
• Escalate and advise to the Cluster Head CFCC and CEO, for Uganda (where relevant) on material CFCC issues (as required) and to ensure appropriate steps are taken to manage and/or mitigate the issue.

Governance

• Accountable for senior oversight, guidance and direction of the CFCC function in Uganda including the various Group CFCC frameworks and programs within Uganda.
• Roll out and embed lessons learned from audit findings, CFCC assurance activities and ensure specific investigations are prepared and cascaded or escalated to relevant stakeholders for Uganda.
• Provide leadership to the CFCC network as part of the CFCC management team.
• Be the main point of contact to escalate, provide timely, relevant and accurate management information to Cluster CFCC head and CEOs, for Uganda on key regulatory risks and control effectiveness.
• Support the product program and country addendum framework in Uganda

Regulatory relationships and regulatory change

• Accountable for regulatory relationships in Uganda, including regulatory inspections management for Uganda and identification of regulatory reform initiatives with significant impact on Uganda.
• Provide guidance and maintain oversight over Uganda on regulatory relationships and regulatory inspections management to socialise functional best practices around regulatory inspections for Uganda.
• Drive the institutionalization of regulatory relationships across Uganda to ensure effective Regulatory Relationship Plans are in place.
• Support the CEO Uganda in ensuring proactive regulatory engagement and in establishing an effective regulatory relationship plan in Uganda.
• Drive proactive and timely identification, assessment, advice and dissemination in accordance with the respective Group framework, of evolving regulatory changes/practices and associated risks in and relating to Uganda.
• Drive proactive engagement in regulatory reform, including ensuring identification and escalation of regulatory reform proposals, participation in local internal regulatory relationship and reform forums and memberships of local external industry forum for Uganda.
• Communicate and escalate all material projects to the Regulators in accordance with local regulations for Uganda.

Regulatory & Business Conduct

• Display exemplary conduct and live by the Group’s Values and Code of Conduct.
• Take personal responsibility for embedding the highest standards of ethics, including regulatory and business conduct, across Standard Chartered Bank. This includes understanding and ensuring compliance with, in letter and spirit, all applicable laws, regulations, guidelines and the Group Code of Conduct.
• Lead the Uganda CFCC team to achieve the outcomes set out in the Bank’s Conduct Principles: Fair Outcomes for Clients; Effective Operation of Financial Markets; Financial Crime Prevention; The Right Environment
• Effectively and collaboratively identify, escalate, mitigate and resolve risk, CFCC matters for Uganda.

Exclusions

For clarity areas of control and oversight excluded from accountability include:

• fraud-prevention;
• BCP/ crisis management;
• conduct of business matters outside the Country;
• first line assurance (except for processes owned by CFCC);
• second line rules based assurance activity of any process not directly related to regulatory risk;
• all prudential related matters.

Key Stakeholders

• Relevant Uganda Regulators
• Country CEO’s, Uganda
• Heads of Businesses and Functions, Uganda
• Matrix reporting lines and their line managers
• GlA

Other Accountabilities

• Embed Here for good and Group’s brand and values in the CFCC Uganda.
• Perform other accountabilities assigned under Group, Country, Business or Functional policies and procedures.