The Bank has approved and has in place an internal regulation on collaboration between the Bank's subdivisions and Legal Department to rule out the risk of unconformity of the Bank's internal documents to provisions of new federal laws, laws of administrative units of the Russian Federation, other regulations and law-enforcement practice.
To follow the Bank of Russia's recommendations on bank risk assessment and the Basel Agreement, in 2011 the Bank took measures to build the system for integrated management of risks (including the legal risk) of the Group of OJSC Sberbank of Russia.
As of 1 January 2012 there were claims pending against the Bank and filed by retail clients for 129.4 bn. rubles. Following examination of similar claims in 2011, the Bank expects courts to make an award in favor of the Bank and the Bank will make no payments under them.
Strategic Risk
For Sberbank as the largest universal lending institution of the country, strategic risks are closely related to the adequate assessment of prospects of development of the Russian economy and accurate projections of the dynamics of corporate and individual needs for financial services.
The Bank's development strategy approved by Sberbank's Supervisory Board in October 2008 was designed in the context of a rapidly changing situation in financial markets and the economy in general. Its developers had an important goal of striking a balance between solutions required by the short-term market conditions and long-term objectives pursued by the Bank.
The strategy defines main mechanisms of implementation of this objective that require changing the Bank's internal operating arrangements, increasing staff performance, modifying approaches to client services, boosting employee professionalism and interest in the outcomes of their effort.
The primary result that was achieved through implementation of the Strategy was an improved quality of client service, faster modernization of key banking processes and technologies, an implemented incentive system oriented on achieving growth targets.
Development within the growth paradigm established by the Strategy allowed the Bank to avoid realization of risks related to a rapid outflow of liabilities in 2009, the period of an active crisis phase. However, the loan portfolio structure diversified by sectors and borrowers helped to maintain the share of overdue debt at a level which was significantly better than market figures.
Risks related to integration and development of subsidiaries in the territory of the Russian Federation and overseas, risks of an adverse change in laws and regulations that determine activities of lending institutions are also very relevant to Sberbank.
Sberbank carefully analyzes each transaction for setting up or acquiring companies and banks both in Russia and abroad. Comprehensive assessment of such projects covers the maximum possible scenarios and only then a positive or negative decision is made.
Even though negative consequences of stricter rules and requirements to operations of lending institutions that might be introduced on the national and supra-national level will affect primarily medium and small banks, Sberbank also takes into account the risk of tighter regulations in its activity, is involved in interdepartmental commissions on improvement of banking laws.
To secure sustainable development on the context of a volatile external environment, Sberbank regularly monitors all strategic projects it is carrying out. In the event of significant changes in external or internal factors affecting operations within a certain project, urgent relevant adjustments are made in its progress.
The Bank regularly reports on the status of the Strategy's implementation to the Supervisory Board and the Annual General Shareholders’ Meeting of Sberbank, holds special sessions that may be attended by members of the Supervisory Board and leading global specialists in economy and finance on bringing targets of strategic development up to date.
Operating Risk
The operating risk is managed to prevent and reduce losses caused by imperfections in internal processes, failures and errors in the operation of IT system, personnel's actions and the impact of external factors.
In the reporting year, Sberbank held an open tender for a software platform for the operating risk management system. As a result, it selected SAS OpRisk Management, a platform used by leading global financial institutions. The Bank started a strategic project for automation of the operating risk management system and commenced implementation effort.
In order to increase responsibility of subdivisions on issues of managing the operating risk, special focus was put on the institute of risk coordinators – the link on issues of collaboration between risk subdivisions and the Bank's subdivisions in the course of operating risk management.
The Bank continuously carried out a risk audit of key processes and then implemented new technologies to reduce operating risk levels:
to lower the risk of fraud by external parties and the Bank's staff when accessing a client's accounts;
to differentiate features allowing operations in automated systems which reduced the risk of unauthorized transactions carried out by one person;
to centralize the granting of privileges of access to automated systems.
The Bank's top-priority processes for optimization in 2012 include those exposed to a high level of operating risk, including cash management for corporate clients, unallocated bullion accounts, broking services, bank wires, bank card accounts, execution and support of the universal bank service agreement etc.
As of 1 January 2012, the ratio of expenses related to realization of an operating risk to Sberbank's earnings was 1.2% or much lower than in largest Russian banks. The average figure based on the profit and loss statement of ten largest banks by working assets was, on 1 January 2011, 4.2%.