On 19 November, DNB published the SIRA Good Practices for consultation. These aim to provide institutions with practical tools to make their Systematic Integrity Risk Analysis (SIRA) more dynamic and goal-oriented. Unlike the current DNB Guidance, the proposed Good Practices offer more concrete examples and are less prescriptive regarding the steps to follow.
With our experience in guiding SIRAs, we welcome this approach. By focusing on customisation and a less rigid methodology, DNB creates space for institutions to better align with their specific risks and circumstances. Furthermore, the move away from a heavily theoretical approach to risk assessment—often seen as detached from genuine risk discussions within organisations—marks a positive shift towards fostering meaningful dialogue about actual risks with employees.
At Projective Group, we advise our clients to centre their approach on the core question: “Are we effectively and efficiently in control of the integrity risks relevant to our organisation?” This methodology aligns seamlessly with the SIRA Good Practices currently under consultation. We see the proposed Good Practices as a valuable step towards a more practical and efficient SIRA approach.
We have summarised the key highlights from the consultation documents for you (in Dutch):
Our Services
We offer a wide range of services tailored to the specific needs of your organisation. Our SIRA support includes:
- Developing and/or validating your organisational risk profile, ensuring all relevant aspects of your institution are included in the analysis.
- Creating and/or validating a Risk Appetite Statement, clearly defining the risks your institution is willing to accept.
- Training sessions through our partner, “The Ministry of Compliance”, conducted either on-site or remotely, focusing on performing a SIRA.
- Validation of the risk assessment and Risk Appetite Statement, based on your institution’s unique characteristics.
- Conducting the risk assessment using the Risk Assessment Tool.
