ShareIn has implemented a Risk Framework to measure, monitor and control risks across all aspects of its business.
The ShareIn Risk Framework explains the intent of each of these parts, how they interact to provide a picture of the level of risk in the business at any time and identify areas where remedial action is required. A brief description of each part of the framework is provided below.
4.1 ShareIn ICAAP / ICARA
The ICAAP considers the level of risks in the business and looks to attribute a monetary value to these risks. This then forms the basis for calculating the level of financial resources to be held as capital in the business in response to those risks and as required by the FCA’s Threshold Conditions.
ShareIn will transition to the new ICARA process in 2022. We are mindful of the transition from ICAAP to ICARA.
4.2 ShareIn Risk Appetite Statement
The Risk Appetite Statement is an articulation of the level of risk that the Board considers appropriate for the firm to assume in pursuit of its strategic objectives. Risk Appetite or Tolerance to Risk represents the “worst case scenario” on a per risk basis. Risk Indicator represents the point at which an early warning would be triggered and ShareIn should review the underlying reasons for the adverse trend. The Tolerance to Risk is a core component of the firm’s risk management framework, and provides the context for policy-setting and decision-making throughout the organisation.
4.3 ShareIn Risk and Controls Matrix
Material risks are detailed on the ShareIn Risk and Controls Matrix, and is used as the basis of generating the Monthly Risk Metrics Reporting which is reported on a regular basis to the ShareIn Board to highlight any Risk Indicators which have arisen during the reporting period.
To ensure our risk assessments are effective, we assess the impact and likelihood of the risk arising; review the risks regularly to ensure they do not change out of proportion to the level of risk we wish to hold; and identify any potential aggregation of risk that may then become an unacceptable risk to the firm.
4.4 Compliance Calendars
The Compliance team have compiled a number of calendars detailing the activities to be completed each month in response to the key risks. These activities cover risks within the core ShareIn business and also through its AR community.
4.5 Risk Reporting
Each month the Compliance team provides a report to the ShareIn Board summarising results from the risk management activities, identifying where action is required. This includes monthly Risk Metrics Reporting which is reported on a regular basis to the ShareIn Board to highlight any Risk Indicators which have arisen during the reporting period. Concerns highlighted as part of the Compliance Calendars are also raised as part of the compliance Board reporting.
4.6 Professional Indemnity Insurance
ShareIn have set an internal policy that all ARs must have Professional Indemnity Insurance in place to cover their activities.
ShareIn Compliance will review any Insurance documents provided by the AR against the internal Professional Indemnity Insurance Review Procedures, to ensure the level of cover is up to ShareIn standards and covers the appropriate risks identified.
4.7 Wind Down Planning
ShareIn has a documented ‘wind-down’ plan to enable us to cease regulated activities and achieve cancellation of our permission with minimal adverse impact on our clients, counterparties, or the wider markets. Our obligations to treat customers fairly continues to apply during the wind-down period.
Further information on this can be found in the ShareIn Wind Down Plan.