What are the material issues the company has identified?

In its 2019 ESG Report FAB identified a range of material issues, such as financial and economic performance, systemic risk management, responsible customer relations, financial inclusion and accessibility, responsible lending and investing. Among these, combatting financial crime stands out as a key material issue for FAB.

Stakeholder engagement in accordance with the GRI Standards

The Global Reporting Initiative (GRI) defines the Principle of Stakeholder Inclusiveness when identifying material issues (or a company’s most important impacts) as follows:

“The reporting organization shall identify its stakeholders, and explain how it has responded to their reasonable expectations and interests.”

Stakeholders must be consulted in the process of identifying a company’s most important impacts and their reasonable expectations and interests must be taken into account. This is an important cornerstone for CSR / sustainability reporting done responsibly.

Key stakeholder groups FAB engages with: 

Stakeholder Group	Method of engagement
Customers	·      Branches ·      Digital channels and social media ·      Relationship managers ·      Customer Experience Department ·      Customer surveys
Employees	·      Training and development programmes ·      Employee engagement ·      Recognition programmes ·      Transparent, accountable management ·      Whistleblower hotline
Shareholders and Investors	·      Board of Directors meetings ·      Public reports ·      Road shows
Government and Regulators	·      Group Internal Audit, Group Compliance and External Audit ·      Code of Ethics Policy ·      Public reporting
Environment	·      Sustainability report ·      Green bond report ·      Engagements with NGOs ·      External memberships
Local Community	·      CSR activities ·      Local procurement ·      Social media and website ·      Partnerships
Suppliers	·      Bidding and tendering ·      Supplier portal ·      Supplier Environmental & Social Code of Conduct

How stakeholder engagement was made to identify material issues

To identify and prioritise material topics FAB conducted interviews and workshops with stakeholder groups, to identify what is important to them.

What actions were taken by FAB to combat financial crime?

In its 2019 ESG Report FAB reports that it took the following actions for combatting financial crime:

• Combatting fraud
• FAB’s global financial crime unit includes dedicated experts who specialise in crime prevention and managing threats posed to FAB. They undertake activities including fraud risk assessments, review new products before roll-out from a fraud risk perspective, conduct mystery shopping and spot checks to proactively test fraud controls, and update staff and customers about the latest trends in financial crime. The financial crime unit also works together with law enforcement agencies and industry peers to share intelligence, coordinate efforts and help fight financial crime in the wider community. FAB has a Group Vulnerability Assessment and Penetration Testing Policy and procedures to identify possible vulnerabilities on all bank assets and infrastructure, including payment card systems. FAB also uses advanced analytics that provide better insights and real-time data to uncover and act on potential threats.

• Fighting bribery and corruption
• FAB does not tolerate any deliberate breach of anti-bribery and corruption (AB&C) laws and regulations. The group AB&C policy was revised in December 2019, incorporating UK Bribery Act and Foreign Corrupt Practices Act (FCPA) requirements. Also, proper AB&C related controls have been embedded into the relevant business and support functions, to mitigate any bribery and corruption risks. The AB&C function provided a tailored training programme to certain functions with heightened bribery & corruption risks, along with the mandatory AB&C e-learning programme. The training programmes were provided to the Board, Senior Management and the wider bank personnel.

• Raising employee awareness
• FAB’s approach to fraud prevention includes an employee background check process, mandatory fraud awareness training as part of staff induction and an annual mandatory Anti-Money Laundering (AML), AB&C and Sanctions e-learning programme, which requires a minimum pass rate of 80%. FAB trains its people on how to identify, prevent and deal with financial crime and provides risk-assessment tools and models. Various polices are in place to guide employees and articulate FAB’s commitments, including AB&C Policy and the Prevention of Money Laundering and Counter Financing of Terrorism and Sanction Compliance Policy.

• Screening customers and transactions
• To verify and onboard legitimate customers, FAB’s due diligence process reflects international best practices and complies with relevant laws and regulations with respect to Know Your Customer (KYC) and other client identification requirements. FAB continuously updates its deterrence and detection infrastructure, which includes sophisticated tools to monitor, track and report criminals and any suspicious transaction activity across channels. Customers and counterparties are regularly screened against listed terrorist organisations and sanctioned names issued by the UN, US, EU, UK and UAE.

Which GRI Standards and corresponding Sustainable Development Goals (SDGs) have been addressed?

The GRI Standards addressed in this case are:

1) Disclosure 205-1 Operations assessed for risks related to corruption

2) Disclosure 205-2 Communication and training about anti-corruption policies and procedures 

 

Disclosure 205-1 Operations assessed for risks related to corruption corresponds to:

• Sustainable Development Goal (SDG) 16: Peace, Justice and Strong Institutions
• Targets: 16.5

Disclosure 205-2 Communication and training about anti-corruption policies and procedures corresponds to:

• Sustainable Development Goal (SDG) 16: Peace, Justice and Strong Institutions
• Targets: 16.5

 

78% of the world’s 250 largest companies report in accordance with the GRI Standards

SustainCase was primarily created to demonstrate, through case studies, the importance of dealing with a company’s most important impacts in a structured way, with use of the GRI Standards. To show how today’s best-run companies are achieving economic, social and environmental success – and how you can too.

Research by well-recognised institutions is clearly proving that responsible companies can look to the future with optimism.

7 GRI sustainability disclosures get you started

Any size business can start taking sustainability action

GRI, ISEP, CPD Certified Sustainability courses (2-5 days): Live Online or Classroom  (venue: London School of Economics)

• Exclusive FBRH template to begin reporting from day one
• Identify your most important impacts on the Environment, Economy and People
• Formulate in group exercises your plan for action. Begin taking solid, focused, all-round sustainability action ASAP. 
• Benchmarking methodology to set you on a path of continuous improvement

See upcoming training dates.
References:

1) This case study is based on published information by FAB, located at the link below. For the sake of readability, we did not use brackets or ellipses. However, we made sure that the extra or missing words did not change the report’s meaning. If you would like to quote these written sources from the original, please revert to the original on the Global Reporting Initiative’s Sustainability Disclosure Database at the link:

http://database.globalreporting.org/

2) https://www.globalreporting.org/standards/gri-standards-download-center/

Note to FAB: With each case study we send out an email requesting a comment on this case study. If you have not received such an email please contact us.

What are the material issues the company has identified?  

In its 2019 Sustainability Report DBS identified a range of material issues, such as cyber security, financial inclusion, talent management and retention, responsible financing, climate change. Among these, combatting financial crime stands out as a key material issue for DBS.

Stakeholder engagement in accordance with the GRI Standards              

The Global Reporting Initiative (GRI) defines the Principle of Stakeholder Inclusiveness when identifying material issues (or a company’s most important impacts) as follows:

“The reporting organization shall identify its stakeholders, and explain how it has responded to their reasonable expectations and interests.”

Stakeholders must be consulted in the process of identifying a company’s most important impacts and their reasonable expectations and interests must be taken into account. This is an important cornerstone for CSR / sustainability reporting done responsibly.

Key stakeholder groups DBS engages with:

To identify and prioritise material topics DBS engaged with its stakeholders through the following channels:

Stakeholder Group	Method of engagement
Customers	·      Focus group study to evaluate interest of retail customers for sustainable products ·      Annual Future Leaders Programme to raise awareness of DBS’ sustainability strategy and commitment ·      Seminars on emerging issues including environmental sustainability, women and children in Asia, and ageing populations ·      Singapore Creator Awards 2019 to promote uniquely local designs and ideas to inspire” Recycle more, Waste less” ·      Sustainability disclosures on DBS’s websites
Shareholders	·      Meetings with investors to understand their expectations on Sustainability Reporting and green bond financing ·      Ongoing conversations with major ESG rating agencies
Employees	·      “DBS Open” – quarterly group-wide townhalls hosted by CEO Piyush Gupta ·      “Tell Piyush” – an online forum where employees can freely share their feedback and post questions to the CEO ·      Regular department townhalls and events held by senior management include discussion on sustainability-related initiatives ·      Annual employee engagement and sustainability awareness survey ·      Employee sustainability focus groups ·      Sustainability intranet portal ·      Sustainability interest groups – volunteers lead initiatives within DBS ·      Annual group leadership conference for senior management
Society	·      Meetings with social enterprises (SEs) to discuss their progress, share experiences, and understand their specific challenges ·      Community partners/ social service agencies were engaged to understand concerns from ground up, such as the challenges DBS’s beneficiaries – the elderly, underprivileged and disadvantaged – face and areas where DBS can effectively support them ·      Connecting to government bodies and associations including Singapore Centre for Social Enterprise, Community Chest as well as networks such as Asian Venture and Philanthropy Network and UN Global Compact to continue dialogue, engage and support where necessary ·      Strong partnerships such as academic institutions like Singapore Management University – Institute of Innovation and Entrepreneurship and Lien Centre for Social Innovation to support tackling real-world sustainability challenges ·      Being the “People’s Bank”, POSB plays an active role in engaging the community within DBS’s neighbourhoods and partnering with various agencies such as Community Development Councils, Infocomm Media Development Authority (IMDA) and the People’s Association to make a difference in society at large ·      Meeting with NGOs about their specific concerns ·      Participating in various industry sustainability-related forums organised by World Wide Fund for Nature (WWF) Singapore, World Business Council for Sustainable Development, Global Compact Network Singapore and GRI Regional Hub in Singapore
Regulators and policy makers	·      Consultations with United Nations bodies including Sustainable Digital Finance Alliance (SDFA) with Piyush as a member of the advisory board, and UN Secretary-General’s Task Force on Digital Financing of the SDGs ·      Meetings with governments and regulators including Monetary Authority of Singapore (MAS) ·      Advising public policy agencies including IMDA with CEO Piyush Gupta as a council member to the Advisory Council on the Ethical Use of Artificial Intelligence (AI) and Data ·      Active participation in various industry sustainability-related forums organised by the Association of Banks in Singapore and Singapore Institute of International Affairs

What actions were taken by DBS to combat financial crime?

In its 2019 Sustainability Report DBS reports that it took the following actions for combatting financial crime:

• Launching an in-house intelligent case management system
• In 2019, DBS unveiled an in-house intelligent case management system to strengthen its transaction surveillance team in their review of suspicious activities flagged by systems or frontline employees. DBS used Robotic Process Automation technology to aggregate data from multiple sources, for its investigators to have a holistic view of customer information and transactional activities. This accelerates their ability to determine whether the unusual behaviours warrant reporting to the authorities. Post-deployment, DBS’s analysts tripled the percentage of time spent investigating genuine cases, as onerous manual processes were eliminated through back-end automation.

• Using network link analysis
• As money launderers and terrorist networks are increasingly sophisticated in the methods they use to conceal their transactions and activities, DBS built link analysis capability to visually represent connections between customers and counterparties, flow of funds, and to uncover complex and hidden networks. This new way of working enhances DBS’s detection capability from transaction and account level, to include customer and network level detection. DBS applied this to companies using typology-based data analytics and its work was featured by the Monetary Authority of Singapore (MAS) as an effective mechanism to detect and mitigate the risk of misuse of legal persons. 

• Implementing machine learning
• To complement its infrastructure, DBS invested in human capabilities to leverage on the proliferation of data and to transform these reliably into signals. DBS’s data scientists developed machine learning models that can prioritise system alerts based on risk and likelihood of money laundering. As a result, DBS’s investigators can focus on reviewing genuine alerts, whilst a different set of machine learning models manage false positives. Furthermore, DBS introduced models that detect new and emerging threats based on specific typologies. These models flag out unusual activities over and above those generated by DBS’s monitoring systems.

• Introducing a Dynamic Review Assessment process
• DBS has introduced a Dynamic Review Assessment (DRA) process, which through DBS’s regular data analytics validation on its customers and facilitated with designated risk scenarios, will generate timely and risk focused trigger reviews. DRA helps DBS to concentrate its resources on identifying customer risk early in the game, whilst reducing unnecessary inconvenience faced by its largely good and law-abiding customers.

• Providing training
• DBS believes in equipping its employees with the relevant financial crime knowledge and continues to invest in mandatory training and awareness programmes. Every employee is expected to recognise, prevent and detect financial crime to the extent possible. All DBS employees must complete both AML (Anti-Money Laundering) and Code of Conduct refresher training annually, and attest to it.

Which GRI Standards and corresponding Sustainable Development Goals (SDGs) have been addressed?

The GRI Standards addressed in this case are:

1) Disclosure 205-2 Communication and training about anti-corruption policies and procedures

2) Disclosure 205-3 Confirmed incidents of corruption and actions taken

 

Disclosure 205-2 Communication and training about anti-corruption policies and procedures corresponds to:

• Sustainable Development Goal (SDG) 16: Peace, Justice and Strong Institutions
• Targets: 16.5

Disclosure 205-3 Confirmed incidents of corruption and actions taken corresponds to:

• Sustainable Development Goal (SDG) 16: Peace, Justice and Strong Institutions
• Targets: 16.5

 

78% of the world’s 250 largest companies report in accordance with the GRI Standards

SustainCase was primarily created to demonstrate, through case studies, the importance of dealing with a company’s most important impacts in a structured way, with use of the GRI Standards. To show how today’s best-run companies are achieving economic, social and environmental success – and how you can too.

Research by well-recognised institutions is clearly proving that responsible companies can look to the future with optimism.

7 GRI sustainability disclosures get you started

Any size business can start taking sustainability action

GRI, ISEP, CPD Certified Sustainability courses (2-5 days): Live Online or Classroom  (venue: London School of Economics)

• Exclusive FBRH template to begin reporting from day one
• Identify your most important impacts on the Environment, Economy and People
• Formulate in group exercises your plan for action. Begin taking solid, focused, all-round sustainability action ASAP. 
• Benchmarking methodology to set you on a path of continuous improvement

See upcoming training dates.
References:

1) This case study is based on published information by DBS, located at the link below. For the sake of readability, we did not use brackets or ellipses. However, we made sure that the extra or missing words did not change the report’s meaning. If you would like to quote these written sources from the original, please revert to the original on the Global Reporting Initiative’s Sustainability Disclosure Database at the link:

http://database.globalreporting.org/

2) https://www.globalreporting.org/standards/gri-standards-download-center/

Note to DBS: With each case study we send out an email requesting a comment on this case study. If you have not received such an email please contact us.