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Job Title: Senior Manager - Market Conduct Risk
Reports to: CRO
Division: Risk Management Division
Section/Unit: Market Conduct Risk Unit

Job Purpose

The Senior Manager – Market Conduct Risk is responsible for establishing, maintaining and enhancing the Bank's independent Market Conduct Risk Framework as part of the Second Line of Defence, ensuring effective oversight of conduct risks across the Bank in accordance with the UAE Central Bank Consumer Protection Regulation, Consumer Protection Standards, Market Conduct Risk-Based Supervision Framework, SME Customer Protection Regulation and other applicable regulatory requirements.

The role is responsible for providing independent challenge and oversight over the effectiveness of the First Line's management of conduct risks throughout the customer lifecycle, promoting fair customer outcomes, strengthening conduct culture, overseeing market conduct governance arrangements, assessing emerging conduct risks using a risk-based supervisory approach, and providing assurance and reporting to Senior Management, the Board and relevant Board Committees.

The role also supports regulatory engagements, thematic reviews, conduct risk assessments and continuous enhancement of the Bank's conduct risk governance framework.

Key Accountabilities

Governance and Oversight

• Ensure the bank's conduct risk policy is reviewed regularly by senior management in accordance with regulatory requirements
• Define and communicate clear roles and responsibilities to operationalize consumer protection standards and conduct risk frameworks
• Conduct oversight of functions owning and embedding Code of Conduct, Conflicts of Interest, Whistleblowing, ABC in line with Consumer Protection Standards and Regulations
• Develop, maintain and continuously enhance the Bank's Market Conduct Risk Framework, methodology, taxonomy and governance standards
• Establish a risk-based conduct supervision methodology covering all business lines, products, customer segments and distribution channels
• Ensure conduct risk is appropriately integrated within the Bank's Enterprise Risk Management Framework and Risk Appetite Framework
• Provide independent oversight and challenge over First Line implementation of Consumer Protection Standards throughout the customer lifecycle
• Oversee governance relating to Vulnerable Customers and Financial Inclusion

Risk Assessment

• Review controls established by first-line owners to mitigate misconduct risks in third-party dealings; escalate gaps to senior management
• Establish, maintain and regularly review a risk register for misconduct risks across all business units
• Perform enterprise-wide conduct risk assessments using a risk-based supervisory methodology
• Identify inherent and residual conduct risks across products, services, channels and customer journeys
• Conduct thematic reviews based on emerging risks, complaints, regulatory findings, incidents and market developments
• Develop and maintain the Conduct Risk Universe and Conduct Risk Register
• Recommend enhancements to mitigate identified conduct risks

Consumer Protection Regulations

• Independently oversee implementation of Consumer Protection Regulation and Consumer Protection Standards
• Challenge effectiveness of customer disclosures, transparency and communications
• Oversee product governance arrangements including target market assessments and product suitability
• Review fair value / Value for Money assessments for products
• Provide oversight over customer onboarding, servicing, complaints, vulnerable customer treatment and account closures
• Challenge the effectiveness of complaint root cause analysis and remediation

Product Governance

• Independently challenge New Product Approval processes to ensure customer risks have been adequately assessed
• Review customer outcomes throughout the product lifecycle
• Ensure conduct risk assessments are completed before launch of new products or material product changes

Regulatory Engagement

• Lead Market Conduct regulatory engagements with CBUAE
• Coordinate responses to regulatory examinations
• Track remediation plans arising from supervisory reviews
• Monitor implementation of regulatory developments

Talent Management

• Assess and enhance existing training programs on conduct risk, ensuring employees understand and comply with conduct standards
• Provide input and oversight to ensure conduct risk considerations are incorporated into the HR performance evaluation framework

Market Abuse & Integrity

• Oversee reporting and escalation of market abuse incidents per insider trading policies, and challenge the adequacy of remedial actions
• Provide oversight and input to Insider Trading policy and procedures to manage market abuse risks associated with the bank's customers

Conflicts of Interest

• Provide oversight and challenge on the bank's Conflict of Interest policy and controls; review and escalate significant conflicts to Senior Management

Culture and People

• Collaborate with product development and marketing teams to ensure the suitability and appropriateness of products and services for customers

Specialized Risk Areas

• Collusion Risk: Oversee risks of collusion between parties aimed at manipulating market conditions
• Consumer Mobility Risk: Oversee risks related to consumer ease in switching providers
• Cooling Off Risk: Ensure customers are provided with adequate cooling-off periods
• Sales, Marketing, Advertising, and Promotional Risk: Oversee risks associated with these activities, ensuring regulatory compliance
• Solicitation Risk: Oversee risks associated with solicitation practices

Qualifications & Experience

• Bachelor's degree in Business, Law, Education, or a related field
• 3-5 years of experience in regulatory compliance, controls and governance within the banking industry
• Strong knowledge of regulatory compliance; excellent communication skills

Areas of Competency

• Excellent verbal and written communication skills
• Deep knowledge of compliance standards, particularly those related to conduct risk and consumer protection
• Knowledge of how conduct risk intersects with operational risk and ability to implement effective control measures
• Strong skills in analysing data related to conduct risk incidents, customer complaints, and market abuse, and developing appropriate mitigation strategies
• Experience working across compliance, legal, human resources, and business units to ensure alignment on conduct risk matters
• Excellent communication skills to engage with internal stakeholders (senior management, business units) and external bodies (regulators, auditors) on conduct risk issues