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This role is pivotal in providing 2LOD independent oversight, challenge, support and guidance to the group on all aspects of conduct risk matters, helping to shape a culture of integrity and accountability and ensuring that regulatory obligations and conduct expectations are effectively managed. Reporting to the Group Chief Compliance Officer this is a critical senior leadership role within Group Compliance that leads the development and execution of the Group's conduct risk strategy, ensuring that customer outcomes, ethical behaviour, and regulatory expectations are embedded across the group.
Job Responsibility:
Setting Rules and Standards: Development and maintenance of Group wide Customer Protection Risk Policy
Overseeing Rules and Standards: Technical standards: Assess implementation of the Customer Protection Risk Policy by competing cyclical review and approval of 1LOD Technical standards
Committees: As required by the Business/Function Oversight Team, attendance at 1LOD Risk Committees/Steering/forums to challenge Customer Protection risk matters as they arise
Advisory: Provide advice on an ad hoc basis to 1LOD on queries related to Customer Protection
Targeted Reviews: Conduct targeted reviews of the management of Customer Protection Risk
Challenge of 1LOD: Challenge Papers: Production of 2LOD challenge papers for all 1LOD Customer Protection Risk papers presented to Executive Risk Committee and Board Risk Committee
Risk Issues/Risk Events: Review and approve action plans and closure requests for Consumer Protection Issues rated P0/P1/P2. Review material Customer Protection Events and review and challenge proposed response
Products: Review and challenge Customer Protection risks associated with New and amended Products and Services
RMPs: Review and approval of responses to Customer Protection risk mitigation programmes (RMPs)
Monitoring and Reporting Risk Profile: Design and oversee Key Risk Indicators (KRIs)/Metrics
monitor Customer protection risk profiles, Metrics and industry/regulatory developments
Reporting of Customer protection risk Appetite, adequacy of Control Environment and Risk profiles, including outlook for how the risk is managed
Promoting strong Risk Culture: Training staff on Customer Protection risk management practices
Emphasise the importance of Customer Protection risk event/near miss reporting through reminders/guidance notes etc
Leading a specialist team to delivery fast paced agenda: Lead and develop a high-performing conduct risk oversight team, fostering a culture of integrity, accountability, and continuous learning
Align team capabilities with evolving regulatory expectations and business needs
Act as a role model for ethical leadership and champion the Group's values and Code of Conduct
Customer Protection Policy: Lead the periodic review and enhancement of the Group Customer Protection Policy to ensure it remains aligned with evolving regulatory expectations, including the Central Bank of Ireland's Consumer Protection Code, SEAR, DORA, and EBA/ESMA guidelines
Develop and maintain the Customer Protection Risk Taxonomy and Risk Library, ensuring consistency with the broader Risk Management Framework
Support the embedding of Customer Protection considerations into Risk Appetite Statements, ensuring thresholds and metrics reflect customer fairness outcomes
Drive consistency in Customer Protection oversight across legal entities and jurisdictions, ensuring local teams adhere to group-wide standards and governance principles
Regulatory Engagement and Horizon Scanning: Act as the central liaison for all Customer Protection regulatory interactions, including CBI thematic reviews and Supervisory Risk Assessments
Conduct regulatory horizon scanning to identify emerging Customer Protection risks and translate upcoming regulatory changes into actionable impact assessments and implementation plans
Prepare briefing notes and regulatory updates for senior management, the Executive Risk Committee, and the Board Risk Committee
Thematic and Deep-Dive Reviews: Lead thematic reviews into areas of heightened Customer Protection risk such as product suitability, value for money, vulnerable customers, and complaints handling
Identify root causes of systemic issues and make recommendations for control enhancement and process improvement
Conduct post-implementation reviews following major product launches or regulatory changes to assess ongoing compliance and customer outcomes
Requirements:
Extensive experience and knowledge in conduct oversight within banking or financial services, ideally in a 2LOD role
Deep understanding of conduct risk principles, regulatory expectations (e.g. CBI, PRA, FCA) and cultural drivers
Evident knowledge of the risk, regulatory and legal environment in which the Group operates
Deep understanding of regulatory frameworks, and conduct risk
Can think strategically with excellent judgment and discernment with breadth of understanding and insight and will possess the ability to focus on the relevant detail
Able to combine effective critical thinking with efficient and practical management as well as the ability to promote new ways of working
Sound commercial judgement and critical thinking skills with the ability to simplify, analyse, explain complex issues
Confidence and the ability to build positive relationships with senior business stakeholders where robust constructive challenge is encouraged while maintaining independence and objectivity
Pro-active with shown ability to handle diverse and conflicting priorities while delivering at pace in an agile way
Experience contributing to senior governance forums and risk committees
Strong leadership skills, personal credibility, and the ability to lead, coach and empower the team to perform at the highest standard
Professional Industry recognised Compliance, Risk Management, Legal and /or Internal Audit qualification supported by significant shown experience