Introduction to Reputational Risk
Risk Management and Compliance Division
NFRM Department
Non Operational Risk Management Unit
Introduction to Reputational Risk Management
January 2025
1. Introduction
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Introduction to Reputational Risk
Reputational risk is the potential 2. Definition of
loss arising when outcomes from Reputational Risk
a bank’s actions, omissions, or According to Basel Committee on
compliance failures reduce Banking Supervision (BCBS)
stakeholder trust or impair explains reputational risk as
corporate standing. These arising from non-compliance with
situations can lead to income legal regulations, operational
erosion, higher funding costs, errors and other sources. Due to
capital impairment, regulatory the nature of banking activities,
sanctions, and diminished it is important to ensure the trust
franchise value. In banking— of depositors, markets and
where confidence is a core asset creditors. For this reason,
—reputation protection is a reputational risk can cause
board-level priority. significant negative effects for
banks (BCBS 1997:23). This
In supervisory terms,
definition considers reputational
reputational risk reflects the
risk as harmful, following the
possibility that negative
manifestation of compliance and
perceptions among customers,
operational risks and sources not
counterparties, investors,
fully determined.
employees, regulators, analysts,
and the public could impede a Reputational risk can also be
bank’s ability to maintain or defined as the losses that may
create business relationships and be incurred as a result of
to access funding markets. It is damage to the trust in the
inherently multidimensional, business and corporate
spans all functions and products, reputation due to operational
and is closely linked to the failure or non-compliance with
strength of internal control legal regulations. The concept of
environments and the reputational risk refers to
responsiveness of management potential threats and losses.
to external signals. According to Board of Governors
of the Federal Reserve System
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(1995) “Reputational risk is the expectations of shareholders and
potential that negative publicity stakeholders, and the
regarding an institution’s business understanding of the benefits of
practices, whether true or not, will good reputation are the factors
cause a decline in the client base, that have increased the
costly litigation, or revenue importance of reputational risk
reductions.” management in both financial and
non-financial sectors in recent
3. Reputational Risk in
years.
Banks
Reputational risk in banks can be
Banks serve a large number of
defined as the possibility of loss
customers, both individual and
that may arise as a result of
corporate. They offer a wide
negative perceptions of current or
range of products and services
potential customers, regulatory
such as loans, deposits, credit
authorities, competitor banks and
cards, insurance, internet
shareholders towards the bank,
banking, etc. to their customers
loss of confidence in the bank or
through head office units and/or
damage to the bank's reputation.
branches. Considering the
The ability of banks to maintain
product variety, product and
existing relations, establish new
customer volumes, banks are
relations or access various
expected to face very different
financing resources may be
types of risks such as credit,
adversely affected due to
operational, liquidity, market,
negative thoughts and
reputational, etc.
perceptions that may occur in the
Reputational risk is classified as presence of shareholders or
one of the main types of risk stakeholders (BCBS, 2009:19).
faced by banks. Globalization, the Reputational risk is a type of risk
widespread use of social media, that is inherently involved in all
increasing legal regulations, the activities of banks.
recognition that reputation is an
Sources of reputational risk
intangible asset, the differing
should be determined by banks,
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and processes and controls for Governance-related:
their management should be Enhance transparency,
established. The possible sources implement enterprise
of reputational risk that banks monitoring, adopt credible
may be exposed to are listed by standards (e.g. Equator
BRSA as financial performance, Principles), improve non-
customer satisfaction, compliance financial reporting, calibrate
with applicable legal regulations, remuneration to balanced
rumors, shareholding structure, risk-taking, and embed self-
risk management, corporate regulatory practices, etc.
governance, accountability, 4. Factors of Reputational
transparency, personnel Risk
competence, etc. (BRSA, 2016:2- Unlike other quantifiable risks
3). (e.g., financial or operational),
Given the different source of reputational risk is largely
reputational risk, BRSA, 2016: 2-3 subjective, driven by public and
Mitigation levers cluster into three stakeholder perception, making it
domains : 1
challenging to predict and
Strategy-related: Map manage. It can stem from an
stakeholder expectations, internal issue but quickly spiral
align strategy with societal out of control due to the speed of
and regulatory priorities, modern media and social
and set clear risk appetite networks. Moreover, reputational
for reputational exposures. risk factors can be grouped into
Management-related: non-financial and financial
Build delivery capacity indicators.
against promises, elevate
I. Non-Financial Factor
organization-wide
awareness, strengthen Non-financial risk factors are
controls, and ensure becoming increasingly important
operational resilience. in modern risk management
because their financial effects can
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Gaby Frangieh, Risk Assessment and Management, September 2025
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be intimidating if poorly Reputational risk measurement
managed, creating a "feedback involves assessing potential
loop" that impacts long-term damage to an organization's
viability. public perception through
quantitative and qualitative
Non- financial factors of
approaches. Common methods
reputational risk include; strategic
involve data analytics, sentiment
missteps, culture and conduct
tracking, and financial modeling
issues, governance weaknesses,
to quantify impacts on revenue,
conflicts of interest, inadequate
stock value, or customer loyalty.
oversight, poor stakeholder
communication, environmental I. Sentiment Analysis
and social harm, service failures, Social media listening tools track
third-party incidents, mentions, sentiment, and trends
misinformation, and sector across platforms, demographics,
contagion. and markets to detect negative
II. Financial Factors public perception early.
Customer feedback from reviews,
Financial related determinants surveys, and direct inquiries
comprise of quantifiable, provides multi-faceted insights
observable factors that affect the into satisfaction and loyalty risks.
reputational risks of banks. II. Quantification Models
These include scale and
Models like reputation scorecards
profitability, financing of
or key risk indicators (KRIs) link
controversial projects,
reputation to KPIs such as
asymmetry of profit to risk ratio,
revenue loss, customer churn, or
bonus-based remuneration,
regulatory scrutiny from specific
social responsibility, operational
scenarios.
failures, productivity, resource
availability etc. Scenario Analysis to
estimate the impact of
5. Reputational Risk
plausible reputation events
Measurement
on revenue, costs, funding
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spreads, deposit churn, and viability and even causing
capital. bankruptcy, stemming from issues
Equity/Share Price like ethical breaches, poor
Volatility and abnormal performance, security failures, or
return studies to infer negative media. Moreover,
market-assessed reputational risks can:
reputation effects of
Adverse impact on a bank's
events.
capacity to maintain current
III. Behavioral Metrics
or forge new business
To assess the health of banks relationships;
reputation, monitor engagement Have an adverse impact on
indicators, consumer actions a bank's capacity to
linked to trust, and referral rates. continue to access funding
For proactive evaluation, possible sources or various financing
risks are scored on likelihood and resources;
severity scales using matrices or Result in the possibility of
scorecards. By separating noise loss of income or capital
from emergencies/crises, these due to a decrease in
techniques allow for well- customer trust or damage
informed decisions. to the corporate reputation;
6. Impact of Reputational Lead to legal action,
Risk reduced customer numbers;
Have systematic effect; a
The impact of reputational risk is
crisis starting in one bank
severe and wide-ranging, leading to
can spread to the whole
significant financial losses
system;
(decreased sales, higher costs),
Result in the loss of
customer & talent outflow, damaged
confidence in banks and a
stakeholder trust (investors,
significant deterioration in
partners), increased regulatory
economic stability and
scrutiny, and operational disruption,
public order;
ultimately threatening long-term
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Affect the agreement price and “clients, products,
in merger and acquisition and business practices”
processes (by causing an event types are also
increase or decrease); related to significant
Adversely affect other risk reputational losses.
categories, especially II. Effect of Media Tone:
operational risk; identify reputational risk
as being a major threat
7. Themes & Frameworks associated with the use of
of Reputational Risk social media while social
media exposed banks to
It was found that only developed
data and information
countries (i.e., the United States
risks.
and Europe) have been actively
[Link]
contributing to research on
Implication: The impact
reputational risks in banks,
of reputational risk
suggesting that reputational risks
management (RRM) on a
management of banks has not
firm's overall
gained the global attention it
performance.
deserves.
IV. Sustainability
7.1. Key Reputational Risk Practices: The role of
Themes environmental, social,
I. Operational Losses: and governance (ESG)
operational losses to the considerations and
market while the event sustainability practices in
type generating the shaping a bank's
greatest impact in terms reputation.
of reputation was V. Measurement and
“external fraud”. Methodology: various
“employment practices quantitative and
and workplace safety”, qualitative methods used
“execution, delivery and to assess and measure
process management”,
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reputational risk, Reputational risk management is an
highlighting the difficulty important component of banks' risk
in quantifying it precisely. management processes. Strong risk
management system to be
established by banks will ensure the
7.2. Reputational risk management of reputational risks,
management Framework as in other risk types.
A risk management framework is
The process for managing
a systematic blueprint that helps
reputational risk in banks consists of
companies handle risks by
the stages of defining, assessing,
defining clear processes for
controlling, monitoring, reporting,
identification, analysis, mitigation,
communicating and publicizing
and monitoring. It establishes
risks. The main responsibility of the
consistent practices to address
senior management and the board
uncertainties, align risk strategies
is to establish processes related to
with organizational goals, and
the management of reputational
support compliance and decision-
risk, to ensure their functionality
making.
and to establish and approve
internal regulations (BRSA, 2016:4).
Reputational risk management
should be integrated into the
enterprise risk management (ERM)
architecture and overseen by the
board and senior management.
Typical lifecycle:
A. Policies and Procedures:
Approve a dedicated policy
defining appetite, roles,
escalation, and controls for
7.2.1. Reputational Risk
reputational risk and its
Management in Banks
managements including linked to
codes of conduct.
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B. Identification, Assessment, maintain crisis communication
and Control: playbooks and spokesperson
Identify internal/external protocols.
sources and new-product 8. Best Practices
risks; maintain a taxonomy
Effective reputational risk
and risk registers.
management in the banking
Assess likelihood and impact
sector is a proactive, strategic
using stakeholder mapping,
discipline focused on aligning
control self-assessments,
institutional conduct with ethical
stress tests, and quantitative
standards and stakeholder
scenarios.
expectations. This approach
Control via action plans,
transcends mere crisis aversion,
design of controls,
building robust trust that directly
remediation timelines, and
translates into several positive
periodic effectiveness
outcomes:
reviews.
C. Monitoring and Reporting: a. Effective Crisis
Track key indicators Management (e.g., Post-2008
(complaints, outages, legal Financial Crisis): The most
cases, press sentiment, prominent positive examples are
social media trends, how well-managed institutions,
whistleblower cases, audit often with regulatory support,
findings, regulatory maintained public confidence
notices). during systemic crises.
Implement early-warning The Resolution of the
triggers and dashboards; KSF Bank Failure:
report to risk committees Following the 2008 financial
and the board. crisis, the administration of
D. Communication and Kaupthing Singer &
Disclosure: Ensure transparent, Friedlander (KSF) in the UK
accurate, consistent, and timely was managed by Ernst and
communications to stakeholders Young (EY) with rapid and
via owned and earned channels;
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transparent communication. financially, but also in social
The use of the Financial and environmental terms.
Services Compensation Actionable
Scheme (FSCS) enabled the Transparency: They gain
prompt repayment of positive reputation by being
depositors, which helped completely transparent
maintain wider public about where customer
confidence in the financial money is invested.
system and demonstrated Customers know their
accountability. This deposits are used
effective, organized exclusively to finance
response resulted in a projects with positive social
positive outcome for the or environmental impacts
regulators and creditors (e.g., renewable energy,
involved, reinforcing the organic farming, affordable
importance of robust crisis housing, non-profits) and
planning. are explicitly not used for
b. The Success of Ethical controversial industries like
Banking Models (e.g., Triodos fossil fuels or arms
Bank, Amalgamated Bank) manufacturing.
these institutions have built
Positive Outcome: This
strong, positive reputations by
values-based approach
making their social and
attracts a specific, highly
environmental commitments the
loyal customer base that
core of their operations, directly
aligns with the bank's
addressing the trust deficit faced
mission. This loyalty
by conventional banks after
translates into a stable and
major financial scandals.
resilient deposit base,
Core Principle: These improved financial
banks operate with a "triple performance, and a
bottom line" approach, "cushion of goodwill" that
measuring success not just helps them weather minor
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operational issues far better projects that have tangible
than their conventional social impacts. For instance,
counterparts. Their they provided an $18.4
reputation for integrity million construction loan to
becomes a key competitive renovate 160 affordable
advantage. senior housing units in
Certification and Tampa, Florida, ensuring
Recognition: Many of that 100% of the units were
these banks pursue third- income-restricted.
party certifications like Addressing the Housing
being a Certified B Corp Gap: Since 2021, JPMorgan
or joining the Global Chase has helped create or
Alliance for Banking on preserve over 250,000
Values (GABV), which affordable housing units.
publicly validate their They committed a
ethical claims and further significant amount of
enhance their reputable philanthropic capital ($400
image. million) to a five-year
initiative focused on
c. JPMorgan Chase's
improving housing
Community Development
affordability and stability
Banking: JPMorgan Chase has
specifically for Black,
actively worked to build a
Hispanic, and Latino
positive reputation and address
households.
community needs by focusing on
Supporting Underserved
large-scale community
Businesses: They partner
development investments and
with organizations like the
initiatives, especially in low- and
Raza Development Fund to
moderate-income areas.
provide New Market Tax
Credit investments, such as
Actionable Investment:
a $5 million investment to
The bank commits
help a community center
substantial capital to
serving underserved
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populations renovate a Reputational Risk with
church into a charter Financial Impact
school. (Illustrations)
9. The Business Case for Wells Fargo (Unauthorized
Reputation Accounts Scandal): In 2016,
employees, driven by
Reputation is a core intangible
aggressive sales targets,
asset that drives financial
opened millions of
performance. Proactive
unauthorized customer
management is more cost-
accounts. The ensuing scandal
effective than crisis remediation
led to significant financial
and creates value through five
penalties from regulators,
channels:
leadership changes (the CEO
was fired), loss of customers,
A. Financial Growth
and international reputational
Financial growth and the damage.
business case for reputational Tesco (Horsemeat
risk management are intrinsically Incident): In 2013, beef
linked, with a company's burgers sold by the grocery
reputation acting as a key driver chain were found to contain
of financial performance. A horsemeat due to a supply
strong reputation can enhance chain issue. The consumer
financial growth, while backlash was significant,
reputational risks, if leading to a 43% drop in beef
mismanaged, can lead to burger sales and a substantial
significant financial losses. The drop in the company's market
business case for managing value.
reputational risk is that proactive British Airways (Data
investment in reputation Breaches): Multiple data
protection is more cost-effective breaches exposed customer
than reactive crisis management. and staff personal and financial
details, leading to a £20 million
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fine from the UK data retail operations,
protection watchdog, an highlighting how severe
undisclosed settlement in a reputational damage can
class-action lawsuit, and disrupt a bank's operations
ongoing damage to customer and financial health.
trust and brand image. Silicon Valley Bank (SVB)
TD bank Anti-Money (2023) Reputational Event: -
Laundering Scandal (2024) On March 8, 2023, SVB
Reputational Event: - In announced a large,
October 2024, TD Bank was hit unexpected loss from selling
with a record $4 billion its bond holdings, along with a
settlement for violating anti- capital raise, to shore up its
money laundering (AML) laws. balance sheet.
The violations included Reputational Failure: -
enabling drug trafficking and The news spread rapidly
facilitating money laundering. among the bank's
concentrated client base of
Reputational Failure: -
tech companies and
The massive penalty and
venture capital firms. Social
the public acknowledgment
media and tech industry
of widespread compliance
chat rooms amplified the
failures severely damaged
fear and panic, leading to a
the bank's credibility,
"digital bank run".
especially regarding its
Outcome: - Customers
commitment to combating
attempted to withdraw $42
financial crime.
billion in deposits in a single
Outcome: - While TD Bank
day, overwhelming the
did not fail, the
bank's liquidity and forcing
reputational damage
regulators to step in and
resulted in significant
shut it down.
financial costs, including
B. Competitive Edge
fines, a stock price decline,
and restrictions on its U.S.
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Managing reputational risk when cyanide was found in
provides a direct path to a Tylenol capsules, Johnson &
competitive edge, and this Johnson implemented an
relationship forms the core of the immediate, nationwide product
business case for proactive recall and transparent
reputation management. The true communication strategy,
competitive advantage in prioritizing consumer safety
managing reputational risk lies over short-term profits. This
not in the risk itself, but in the established a gold standard for
proactive approaches taken to crisis management, reinforced
address it. immense public trust, and
These approaches involve ultimately strengthened their
implementing a solid ethical and brand reputation and
corporate governance structure, competitive edge.
effective crisis response plans, Starbucks and Racial Bias
and a focus on corporate social Training: Following the
responsibility (CSR). By actively wrongful arrest of two Black
managing these areas, companies men in a Philadelphia store,
can strengthen trust, improve Starbucks took decisive action
their brand image, and increase beyond an apology. They
their resilience to challenges closed all U.S. stores for a day
ultimately fostering stronger to conduct mandatory racial
stakeholder relationships and bias training for employees,
achieving sustained long-term making the training materials
success. publicly available. This
transparent and systemic
Reputational Risk approach helped restore trust
Management Creating and demonstrated a genuine
Competitive Edge commitment to their stated
(Illustrations) values, differentiating them
from brands that might have
Johnson & Johnson and the
only issued a press release.
Tylenol Crisis: In the 1980s,
Coca-Cola's Product Recall
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Handling: In contrast to a retaining top talent difficult for
competitor's negative an organization. A strong,
outcome, effective risk positive corporate reputation is,
management during a product in fact, a significant attraction for
recall event meant the incident potential employees.
had little impact on Coca-
Cola's reputation and long- Reputational Risk Impacting
term consequences were Talent Attraction
minimal. Their swift and (Illustrations)
effective response preserved Several companies have faced
market trust and operational significant challenges in talent
continuity. attraction and retention following
Britvic's Supplier Quality reputational crises:
Assurance: The soft drink
Virgin Mobile (UK case
manufacturer Britvic
study): A poor candidate
implemented stringent quality
experience during recruitment
control and meticulous
resulted in negative social
supplier vetting processes.
media commentary and news
This proactive quality
coverage. This directly caused
management approach
a loss of 6% of its customer
minimizes product defect risks,
base to a competitor,
safeguards their reputation for
demonstrating how talent-
consistent quality, and helps
related reputation issues can
maintain a competitive
impact the bottom line and
advantage through reliability.
broader business perception.
C. Talent Attraction Oil and Gas Companies:
Firms in the oil and gas
Reputational risk does not attract
industry often face ongoing
talent; rather, a poor or
reputational challenges from
damaged reputation is a major
environmental activists. This
deterrent and consequence
negative perception can make
that makes attracting and
it difficult to attract talent
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concerned with sustainability Responsibility (CSR): A long-
and environmental impact, term, consistent track record
especially among younger of ethical behavior and
generations who often prefer commitment to social and
employers with clear CSR environmental responsibility
strategies. (CSR) is a primary buffer. It
Data Breaches: Companies generates moral capital and a
that suffer major data "halo effect," making
breaches face a loss of public stakeholders more likely to
trust and can struggle to attribute a crisis to an
recruit qualified cyber-security unfortunate, external event
and IT professionals, as the rather than a systemic failure
incident highlights internal or managerial irresponsibility.
weaknesses in security and Stakeholder Trust and
risk management. Goodwill: By consistently
meeting or exceeding
D. Crisis buffer
stakeholder expectations
(customers, employees,
A crisis buffer (or reputational
investors, regulators, etc.)
capital) refers to the reservoir of
during normal operations, a
goodwill a company builds with
company builds a reservoir of
stakeholders over time, which
trust. This established trust
helps mitigate damage during a
acts as a cushion during a
crisis. The business case for
crisis, helping to maintain
managing reputational risk
support and loyalty.
involves demonstrating the
Proactive and Transparent
tangible financial value of this
Communication: Engaging in
buffer and the preventative
regular, open dialogue with
measures that build it.
stakeholders before a crisis
Key crisis buffers include: and maintaining transparency
during one helps control the
Strong Ethical Culture and
narrative and reinforce
Corporate Social
credibility. Honesty and
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prompt communication losses and invest in the
demonstrate accountability, necessary recovery efforts
which can mitigate the (e.g., product recalls,
severity of a reputational hit. compensation, new initiatives)
A Comprehensive Crisis without immediately
Management Plan: Having a jeopardizing its viability.
well-developed plan in place
E. Consumer Trust
allows for a quick, efficient,
and coordinated response
Major consumer trust issues that
when an issue arises. The
act as sources of reputational
ability to respond quickly and
risk center on an institution’s
effectively helps minimize
failure to meet stakeholder
potential damage, whereas a
expectations regarding ethics,
slow or tone-deaf response can
quality, security, and
worsen the situation.
responsibility. When an
Robust Internal Controls
organization breaks this trust, its
and Risk Management:
public image and market value
Strong internal controls,
can be significantly harmed.
regular audits, and proactive
risk assessments help identify
Reputational Risk and
vulnerabilities and prevent
Consumer Trust
many potential crises from
(Illustrations)
escalating in the first place.
This demonstrates a Balenciaga (Advertising
commitment to sound Campaign): In 2022, the
governance and operational luxury brand faced intense
quality. public backlash over an ad
Strong Financial campaign featuring children
Position/Capital: While with BDSM-themed items,
reputation is an intangible which was widely perceived as
asset, a solid financial standing promoting child abuse. The
can provide a tangible cushion, resulting social media storm
allowing a company to absorb and public condemnation led
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to calls for boycotts and damage to its reputation and
eroded consumer trust, brand credibility.
directly impacting sales and Metro Bank Anti-Money
market value, despite the Laundering Fine (2024) of
company's apologies and legal UK Reputational Event: In
actions against the ad agency. November 2024, Metro Bank
Facebook (Data was fined £16.7 million by the
Breaches/Privacy FCA for monitoring failures
Concerns): The Company, related to money laundering.
now Meta, has faced ongoing
Reputational Failure: A
reputational risk due to
bug in the bank's
repeated data breaches and
automated monitoring
privacy scandals (e.g.,
system meant that
Cambridge Analytical). The
approximately 60 million
consistent erosion of consumer
transactions were not
trust has led to ongoing
adequately monitored for
negative media attention,
money laundering risks
regulatory scrutiny, and
between 2016 and 2020.
challenges in customer
Despite junior staff flagging
retention and new user
the issue, senior
acquisition, directly affecting
management failed to act
its business case for long-term
promptly. Outcome: The
stability and growth.
fine came at a sensitive
Volkswagen (Emissions
time for the bank, shortly
Scandal): Volkswagen's
after a near-collapse, and
deliberate deception of
further eroded trust in its
regulators and consumers
operational and compliance
about diesel car emissions (the
capabilities.
"Diesel gate" scandal) was a
profound breach of trust. This
10. Foundation of
led to massive fines, significant
Reputational Risk
legal costs, a sharp drop in
Management
sales, and severe, long-lasting
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Reputational risk management in I. Customer and Market
CBE relies on a foundation of Perception Metrics:
strong corporate governance and Indicators include analyzing
an ethical culture. Includes customer complaints, media
effective board oversight, a sentiment (negative
structured risk management mentions), customer churn
process, fostering employee rates, and negative market
competence and ethical conduct, indicators like dropping share
maintaining transparency with prices or credit ratings.
stakeholders, and implementing II. Internal Operations and
a comprehensive crisis Conduct Metrics: The bank
management plan for incident monitors employee
response. Particularly, the Bank misconduct, high staff turnover
uses a mix of qualitative and rates, operational failures, and
quantitative methods to measure overall fraud rates.
and monitor its reputational risk. III. Regulatory and Compliance
Metrics: This involves tracking
These methods involve gathering
the number of official
stakeholder feedback through
sanctions, audit ratings, and
surveys and customer analysis,
incidents of legal misconduct.
tracking public opinion via social
media, mainstream media and
Controls and Response
customer compliant feedbacks
for Reputational Risk
through NG screen and 951
hotlines, and employing CBE manages reputation risk
benchmarking to estimate management by aligning the
potential impacts. ERM framework and defining risk
taxonomy with ethical standards,
Despite data limitation and
customer-centricity, and active
difficulty to measure reputational
stakeholder engagement. The
risk, banks shall measure their
Bank maintains public confidence
reputational standing within the
through its CSR programs
following Specific categories:
Additionally, the Bank ensures
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accountability by transparently public, ensuring all concerns are
reporting risk events and addressed through established
grievances to senior mitigation mechanisms.
management, NBE, and the
Abbreviation
BCBS Basel Committee on Banking Supervision
BRSA Banking Regulation and Supervision Agency
CBE Commercial Bank of Ethiopia
ESG Environment, social and Governance
KRI Key Risk Indicators
RRM Reputational Risk Management
ERM Enterprise Risk Management
FSCS Financial Services Compensation Scheme
GABV Global Alliance for Banking on Values
AML Anti-Money Laundering
CSR Corporate Social Responsibility
IT Information System
FCA Financial Conduct Authority
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