Risk Management & Business Resilience

Economic Dimension

Risk Management &
Business Resilience

 

We operate in a dynamic global environment, with emerging risks that may not yet be fully recognised or understood but could significantly impact society, organisations, individuals and the planet. Effective risk management is therefore critical to strengthening business resilience by mitigating these impacts and enabling a quick and adaptive response. 

 

A robust risk management framework guides us in ensuring business continuity. Our goal is to enhance our risk management capabilities to meet regulatory expectations, safeguard the Bank’s interests, as well as those of our stakeholders, and promote long-term value creation. 

Enterprise-Wide Risk Management (EWRM) Framework​

CIMB operates under a comprehensive Enterprise-Wide Risk Management (EWRM) Framework, which provides a structured and standardised approach to identifying, assessing, managing and monitoring risks across the Group.

 

The framework integrates a top-down strategic perspective with bottom-up risk identification, enabling proactive management of evolving business, market and regulatory developments. Key risk categories include credit, market, operational, liquidity and sustainability risks.

 

Risk management processes are embedded across the Group, encompassing:

  • Risk identification and assessment
  • Risk measurement, including stress testing 
  • Risk management and control through defined limits and mitigation actions
  • Ongoing monitoring and reporting to senior management and the Board

Process for Determining Risk Appetite

The determination of CIMB’s risk appetite is an integral part of the Group’s risk management process. It is guided by: 

Risk Management Process

Application of Risk Appetite to Specific Risks

Risk appetite is cascaded across all risk categories, including sustainability risk. For instance:

  • Sustainability Risks: The Sustainability Risk Management Framework integrates risk appetite into sectoral policies and transaction assessments, ensuring alignment with CIMB’s commitment to sustainable finance
  • Credit Risks: Credit risk limits are set based on the likelihood and impact of default scenarios, informed by stress testing and historical data

Ongoing Review & Adjustment

CIMB conducts periodic reviews of the risk appetite framework to ensure alignment with evolving business needs, market conditions and regulatory developments. These reviews include scenario analyses, stress testing and consultation with key stakeholders to recalibrate risk thresholds where necessary.

Governance & Accountability

CIMB adopts a Three Lines of Defence model to ensure clear ownership, independent oversight and assurance across all risk types.

This structure reinforces accountability and supports disciplined risk-taking across the Group.

Sustainability Risk Management Framework

Sustainability risk is embedded within CIMB’s EWRM Framework and is treated as a cross-cutting risk that can influence traditional financial risk categories, including credit, market, liquidity, operational and reputational risks.

 

Environmental, social and governance considerations — including climate change, nature, human rights and institutional integrity — are systematically integrated into risk assessment and decision-making processes.

 

Sustainability risks are:

  • Identified and assessed using established frameworks, policies and procedures 
  • Measured using tools such as scenario analysis and stress testing
  • Managed within defined risk appetite through controls, due diligence and client engagement 
  • Monitored and reported regularly to relevant management and Board-level committees
Sustainability Risk Management Framework

We assess a wide range of factors in our business transactions and operations, including environmental issues such as climate change, nature impacts and resource use; social considerations, including community wellbeing and workplace practices; economic challenges, such as market shifts and resource costs; and ethical concerns, including transparency and responsible governance. By addressing these considerations, we aim to mitigate potential risks to CIMB and our stakeholders who depend on our products and services, reinforcing our commitment to long-term stability and shared success.

The environmental, social, economic and ethircal risks outlined can result in financial risks to our clients and other stakeholders, and ultimately to CIMB. In making financing and business decisions, we consider these risks in line with our sustainability commitments.

Governance and Risk Diagram

Emerging Risks

We assess our company-specific risk exposure using a risk matrix to depict the likelihood of each individual risk, as well as its potential short- and long-term impact.

 

For two identified risks — namely, biodiversity loss and ecosystem collapse and anti-ESG sentiments — the likelihood and impact are rated as High-High and Medium-High, respectively. 

Emerging RiskPotential Business ImpactMitigating Actions

Biodiversity Loss and Ecosystem Collapse

(high likelihood; high impact)

 

Biodiversity Loss  
The decline in species diversity and abundance, along with the degradation of ecosystems and their services. This can result from habitat destruction, pollution, climate change, overexploitation of resources and the introduction of invasive species. 


Ecosystem Collapse  
The rapid and irreversible deterioration of an ecosystem’s structure, function, and services. This can be triggered by major disturbances such as natural disasters, disease outbreaks, or human interventions that disrupt the delicate balance between species and their environment.

 

Biodiversity loss and ecosystem collapse present significant risks to human wellbeing and both the ASEAN and global economies. Key impacts include: 

 

• Reduced agricultural productivity, disrupting supply chains and impacting food security

 

 

• Increased disease transmission due to the loss of natural pest control mechanisms

 

 

• Disproportionate harm to vulnerable communities

 

 

• Business disruptions for sectors dependent on ecosystem services 

 

For financial institutions, negative impacts can be both direct and indirect through lending, financing, investment and underwriting activities.

We recognise the importance of biodiversity protection and restoration in maintaining ecological balance. Our key actions include:

 
• Contributing to government policy consultations and industry working groups to shape future policies

 

 

• Engaging with industry players to understand challenges and explore ways forward

 

 

• Participating in international discussion forums to implement best practices.


We plan to develop our overarching Biodiversity Strategy and Roadmap in 2024.

 

In 2024, we published our Statement on Biodiversity and Nature and commenced development of a strategy and roadmap. Set for publication in 2025 alongside sectoral assessments, these initiatives build on our NDPE commitment requirement, which has been in place since 2022

Anti-ESG Sentiments

(medium likelihood; high impact)

 

The growing political divide on climate change has led to rising anti-ESG sentiments, particularly in the US, where regulatory pushback has resulted in bans on ESG-based investments and corporate retreats from sustainability commitments. Major banks, asset managers and insurers have exited climate coalitions, while some companies have scaled back Diversity, Equity and Inclusion (DEI) initiatives due to shifting political and investor pressures.

 

Despite these headwinds, global climate action continues. COP29 secured commitments to mobilise US$300 billion annually for developing nations by 2035, though this remains short of what experts say is needed. As the ESG landscape evolves, financial institutions must balance regulatory, political and stakeholder expectations while staying committed to longterm sustainability goals.

The rise of anti-ESG sentiments is reshaping the global sustainability landscape, introducing geopolitical and economic uncertainty. Key potential impacts include:


• Governments influenced by anti-ESG sentiments may introduce policies that weaken or oppose sustainability initiatives, creating an unpredictable business environment and hindering CIMB’s ability to meet its sustainability commitments

 

• A shift towards non-ESG sectors could divert financing away from sustainable projects, impacting the growth of green industries and increasing investment volatility

 

• Reduced policy support for ESG initiatives may delay advancements in green technologies, such as carbon capture and renewable energy, potentially slowing the transition to a low-carbon economy

We take a structured, science-based approach to climate commitments, upholding transparency, collaboration and measurable outcomes. We are therefore:

 

• Engaging policymakers, regulators, investors, industry bodies and businesses to share knowledge and develop solutions that drive meaningful progress

 

• Grounding our targets in scientific methodologies keeping them robust, data-driven and aligned with international frameworks

 

• Adhering to local regulations and referencing local taxonomies while actively contributing to the development of climate policies

 

• Monitoring evolving market trends and public sentiment to refine strategies

 

• Engaging and supporting high emission industries in transitioning sustainably

Greenwashing Risk

(medium likelihood; high impact)

 

CIMB’s commitments, such as achieving Net Zero by 2050, and No Deforestation, No Peat and No Exploitation are typically phased in across our operating markets. For example, in 2022, we rolled out our NDPE commitment requirement in larger markets, while smaller markets adopted the policy in 2023.

 

At the same time, expectations and standards for responsible banking are rising rapidly. With multiple parties within CIMB communicating sustainability efforts across various channels, there is a risk of miscommunication or overstating sustainability claims.

Greenwashing – or even an allegation of it – can harm the Bank’s reputation and erode trust, making it critical to maintain credibility in our commitments. Potential impacts include:
 
• Increased regulatory scrutiny, leading to stricter oversight and compliance requirements

 

• Reputational damage, affecting stakeholder trust and market competitiveness

 

• Loss of investor confidence, potentially impacting funding and partnerships

 

• Decline in employee morale and productivity

 

• Challenges in attracting quality candidates

To mitigate greenwashing risks, we focus on:

 

• Regularly reviewing policies and commitments to align with evolving expectations

 

• Strengthening governance and monitoring mechanisms to uphold transparency and accountability

 

• Minimising the time gap between announcing and implementing policies across our footprint

 

• Implementing the Sustainability Communications Procedure to guide sustainability-related communications

 

• Mitigating inaccurate disclosures by aligning with recognised reporting frameworks and obtaining third-party verification

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