The Policy sets out in writing the Group’s strategy in assessing the fitness and probity of persons who hold, or who are appointed or elected to an assessed position. This is in line with the professional values and long-term interests of the Group and its Code of Conduct. As part of the governance structure of the Group it serves the purpose of providing for prudent management and of strengthening the efficiency of risk management of the Group.

In brief the responsibilities of the Bank in relation to the above legal and regulatory framework are:

• To make the initial and continuous assessment of the fitness and probity of assessed persons
• To ensure that assessed persons have the requisite experience, specialisation and knowledge for the discharge of their duties and responsibilities
• To ensure that the assessed persons act in honesty, reliability and integrity, characteristics which promote the culture of compliance in an organisation
• To ensure that the NCG Committee adopts the necessary internal policies for the assessment of the fitness and probity of assessed persons. 

This document sets out the criteria for the assessment of the suitability of persons which hold specific and important positions within the Group and the appropriate procedure to be adopted and implemented in order to ensure that the persons involved are suitable for the position they hold on a continuous basis.

The requisite knowledge, experience and abilities of each individual as well as the general requirements for the composition of the Board of Directors are factors that may ensure that informed and professional decisions are taken for the direction of the Bank, the risk management oversight and the regulatory environment it operates in. (The full policy forms part of the Board manual app 17)