[Legal & General]
Annual Report and Accounts 2009

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Risk management.

The effective management of risk is essential to delivery of the group’s strategy and the generation of shareholder value

RISK MANAGEMENT AT A GLANCE

Identification

We understand the risks inherent in our business and we continuously review them as the business develops and markets change. Identified risks are recorded and responsibility is allocated to an owner to assess and manage the risk.

Analysis

Risks are assessed and analysed so that there is a full understanding of the nature of the risk, its probability, and its likely impact on the business area and the Group’s overall strategy. We stress test our risks to understand their impact on the business in the event of extreme market conditions.

Mitigation

Risk mitigation plans are developed and implemented to manage or respond to risks so that we continue to operate within our chosen risk appetite.

These plans are kept under regular review to ensure that they remain robust and appropriate as the nature, probability or impact of risks may change over time.

Reporting

Regular reporting of risks and the mitigation strategies occurs through the individual business level risk committees to the executive level risk committees, and ultimately to the Board committees.

RISK MANAGEMENT

The Group’s approach to risk management is aimed at the early identification of key risks to the Group’s businesses and the Group’s overall strategy, followed by a full understanding of the nature of those risks, the probability of them occurring and their likely impact or effect if they did occur. Robust mitigation action plans are developed and implemented with the aim of reducing or removing the likelihood of the risk occurring or managing the impact if the risk cannot be avoided.

The management of risk, particularly a full understanding of the risks inherent in the business areas, markets and geographies in which the Group operates, is linked to the development and implementation of the Group’s strategy.

Risk management governance: Chart showing L&G's Risk management approach (chart)
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The Board has overall responsibility for setting the risk appetite and tolerance for the Group. The Board is assisted by advice and recommendations received from the Board committees.

Subsequent to the year end, the Company carried out a review of its corporate governance arrangements with particular regard to recent commentary on the Board’s role in risk governance. The Board agreed that it would be in the best interests of shareholders and the Company for the Group risk committee to be chaired by a non-executive director. Due to Board changes expected to take place in the first half of 2010 as a result of director retirements, the Group risk committee will initially be chaired by the Chairman and membership will comprise the Chairman and up to four other non-executive directors. The risk committee will operate under formal terms of reference approved by the Board, copies of which will be available on the Company’s website following approval. It is expected that the non-executive chaired risk committee will meet in early 2010. Risk management and oversight will be delegated by the Board to the risk committee.

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Overview

Mitigation

Regulation and legislation

Changes in regulation or legislation may have a detrimental effect on our strategy or profitability.
Regulation defines the overall framework for the design, marketing and distribution of our products; the acceptance and administration of business; and the prudential capital that we hold. Current areas of significant regulatory change include Solvency II and the Retail Distribution Review. In addition to these known areas of change, there remains potential for new regulation in response to recent market events as well as possible changes in the regulatory landscape following the 2010 general election.

Legislation and government fiscal policy can also influence our product design, the retention of existing business and our required reserves for future liabilities. Areas of new insurance law include that being developed by the Law Commission. Potential changes to personal and corporate taxation also present uncertainty with respect to the profitability and continued attractiveness of our products.

The Group bases its business strategy upon prevailing regulation and legislation, and known/anticipated change. To mitigate the risk of legislation or regulation adversely impacting the sectors in which we operate, the Group seeks to engage with regulatory and legislative authorities to assist in the evaluation of change and develop outcomes that meet the needs of all stakeholders.

Financial market and economic conditions

Investment market performance or conditions in the broader economy may adversely impact our results.
The Group holds a broad range of investment assets to meet the obligations arising from writing insurance business. The performance and liquidity of investment markets, interest rate movements and inflation can impact the value of these assets as well as the value of the underlying obligations. The income derived by our investment management activities can also be impacted by significant falls in investment asset values, whilst broader economic conditions can influence the purchase by customers of retail financial services products and how long they are retained. Whilst 2009 has seen a recovery of major markets from their position in 2008, broader economic conditions remain less certain, with possible consequences to investment values. Investment markets may also suffer considerable disruption should a significant macro-economic event, for example a sovereign debt crisis, occur within a developed world economy.

The Group seeks to reduce the impact of these risks through ensuring the profile of cash flows of our assets and liabilities are appropriately matched. Matching techniques include using financial instruments as part of formal risk management strategies to reduce volatility in returns from investment assets, the effect of changes in interest rates and inflation, and the broader effects of adverse market conditions. We seek to reduce the impact of market and economic conditions upon our investment businesses through the utilisation of a low cost scalable business model and by maintaining a diversified portfolio of products.

Counterparty and third party risks

In dealing with issuers of debt and other types of counterparty, the Group is exposed to the risk of default.
As part of our strategies to appropriately match long term assets and liabilities, exposures can arise to the issuers of corporate debt and other financial instruments.
As part of our day to day business we also have exposures to banking, money market and reinsurance counterparties, as well as the providers of investment settlement and custody services. Third party risks also arise through reliance upon external suppliers for certain administration and IT development services.

Recent market events have demonstrated the importance of sound counterparty management. In this context the Group seeks to limit the potential exposure to loss from counterparty and third party failure through setting robust selection criteria and exposure limits covering factors such as counterparty financial strength, sectors and geography. Exposures against limits are actively monitored, with trigger levels being set and management action being taken to pre-empt loss from default events.

UK financial services sector contagion risks

As a UK based Group, earnings are influenced by the perception of the UK financial services sector as a whole.
Factors such as investment market performance, actions by regulators against organisations operating in the sector and shock events, including matters such as significant market failures, can impact the confidence of retail investors in the sector as a whole and their purchase or retention of financial service products.

2009 has seen a general downturn in business volumes across the sectors in which the Group operates. We continue to seek to differentiate our business model from that of our competitors. This includes a diversified portfolio of risk, savings and investment management businesses in the UK, further details of which are set out in the What We Do section, and a broad distribution mix. In addition, as set out in the International section, we are focused on developing our international businesses, with joint ventures in India and the Gulf being established in 2009, complementing our existing portfolio of overseas activities, as well as our investment management business winning its first mandates in the US.

Mortality catastrophe and other assumption uncertainties

Revisions to assumptions may require adjustments to reserves.
The writing of long term insurance business necessarily requires the setting of assumptions for long term trends in factors such as mortality, persistency, valuation interest rates and credit defaults. The writing of household insurance business also requires assumptions to be set for factors such as extreme weather and other catastrophic events. Whilst a prudent approach is taken to evaluating required reserves for these risks, extreme events, such as a rapid advance in medical science leading to significantly enhanced annuitant longevity or an event causing widespread mortality/morbidity, coupled with a reinsurer default may require assumptions to be recalibrated impacting profitability and capital.

The Group uses its pricing capabilities and the significant experience data it has accumulated to assess and charge an appropriate premium for known risk factors, and to ensure that reserves remain appropriate on an ongoing basis. The evaluation of reserves is supported by stress and scenario testing which seeks to validate the appropriateness of key assumptions to combinations of extreme events, including economic conditions, investment performance and product specific matters.

Industry change

The Group may not maximise opportunities from structural changes within the financial services sector.
The financial services sector is going through a period of change and consolidation. This presents a range of challenges as well as opportunities to providers of sufficient scale such as Legal & General. Recent examples have included the merger of banks and building societies resulting in a change to the distribution landscape. The emergence of niche product providers with new business models continues to drive innovation within a number of the sectors in which the Group operates.

We seek to ensure it has market leading expertise in the core fields in which it operates, and actively focuses on retaining the best personnel with the knowledge to design and support our products, and manage their evolution as market and consumer expectations change. In response to consolidation by banks and building societies, we have established a number of new distribution partnerships. Within our annuities business, a disciplined and selective approach to pension buyout business was maintained throughout 2009, and whilst we continue to lead in the traditional smaller schemes bulk purchase market, increased product and pricing sophistication and increased distribution opportunities helped individual annuities sales to grow. Our savings business has seen a transformation of the mix of products sold towards more modern, less capital intensive offerings.