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Evolving landscape and strategic adaptation
In a rapidly evolving operating environment, the banking sector faces heightened expectations from regulators, investors, customers, employees and communities, alongside increasing uncertainty from macroeconomic conditions, technology change and climate and other sustainability-related developments. These shifts influence not only demand for financial services but also the risk landscape and the resilience expected of systemically important institutions. The Bank responds by continuously strengthening its business model, governance and risk management, and by integrating sustainability considerations into strategy and decision-making to support long-term value creation.
Our approach to materiality
Material matters are the issues that can reasonably be expected to influence the decisions of our report users and/or affect the Bank’s ability to create value over the short, medium and long term. Our materiality approach is informed by the principle of decision usefulness: information is prioritised when it has predictive value (helping users anticipate future outcomes) and/or confirmatory value (helping users assess performance against expectations).
We apply a double materiality perspective in this Annual Report by considering two dimensions:
- Financial materiality – Sustainability-related risks and opportunities that could reasonably be expected to affect the Bank's prospects.
- Impact materiality – the Bank’s significant impacts on people and the environment, including through financing activities and operations, which influence stakeholder relationships and social licence to operate.
SLFRS Sustainability Disclosure Standards alignment (2025): Sustainability-related financial disclosures prepared under SLFRS S1/S2 are based on financial materiality. Accordingly, while this “Material matters” section presents our broader double-materiality view for integrated reporting, the Sustainability-related Financial Disclosures focus on financially material sustainability-related risks and opportunities (SRROs), including climate-related risks and opportunities (CRROs).
Integrating material matters into strategy and governance
To ensure effective management of material matters, we integrate them into our strategic planning, performance management and risk governance processes. Accountability for managing material matters is assigned to relevant senior management roles, with oversight through Board and management governance structures. Material matters are embedded into planning, policies and internal controls, and are monitored through Key Performance Indicators (KPIs) and management reporting to support disciplined execution and transparent accountability.
Materiality determination process
Since our initial assessment, we have continuously refreshed our materiality analysis each year, incorporating internal and external inputs and aligning the outcome to strategic priorities, risk management and stakeholder expectations. Inputs include stakeholder engagement, enterprise risk assessments, regulatory developments, market trends, portfolio performance signals, and sustainability-related considerations.
In 2025, the process was strengthened to support first-time adoption of SLFRS Sustainability Disclosure Standards (SLFRS S1/S2), including:
- clearer linkage between the Bank’s material matters and financially material CRROs;
- emphasis on the pathways through which CRROs may translate into financial effects (e.g., credit quality, sector and geographic concentration, operational disruption, access to funding and market confidence); and
- improved connectivity through cross-references between this section and the Sustainability-related Financial Disclosures.
Thematic material matters and value/risk drivers
We present our material matters through six Thematic Material Matters and their corresponding value/risk drivers which are detailed in Table 04 to provide a structured, decision-useful view of how value is created and protected over the short, medium or long term. The tabulation links each driver to the Bank’s strategy, relevant capitals, Sustainability Framework pillars and key management measures, and provides cross-references to related content across the Annual Report. With the first-time application of SLFRS Sustainability Disclosure Standards (SLFRS S1/S2) in 2025, these linkages are enhanced by identifying where material matters connect to financially material CRROs disclosed in the Sustainability-related Financial Disclosures.
Double materiality matrix
Figure 11 illustrates the Bank’s double materiality assessment across two dimensions: financial materiality (impact on the Bank) and impact materiality (impact on people and the environment). The matrix guides the prioritisation of sustainability topics and explains their integration into our strategy, risk governance and reporting, demonstrating alignment with our sustainable value creation model.
In accordance with SLFRS Sustainability Disclosure Standards, sustainability-related financial disclosures are based on financial materiality, while impact materiality is presented to provide a broader stakeholder perspective. As part of the first year of adoption of the SLFRS Sustainability Disclosure Standards this year, disclosures prioritise climate-related risks and opportunities (CRROs), with further enhancements to follow.
Ongoing commitment
We remain committed to reviewing and refining our material matters annually to reflect evolving stakeholder expectations, regulatory developments and global best practice. As our data, methodologies and disclosure maturity develop under SLFRS Sustainability Disclosure Standards (SLFRS S1/S2), we will continue to enhance the depth, consistency and connectivity of our reporting so that material information is not obscured by immaterial detail.
Transforming risks into opportunities
Each identified risk driver, when effectively managed, presents an opportunity to create value, strengthen resilience and support strategic priorities. By integrating material matters into strategy, risk management and performance oversight, the Bank seeks not only to mitigate downside risks but also to improve customer outcomes, enhance operational efficiency, build confidence and support long-term value creation.
Material matters – Holistic view
Table – 04
Table 04 presents the Bank’s material matters in a structured format, linking each value/risk driver to the key risks and opportunities, strategic implications, relevant capitals, Sustainability Framework pillar, and principal management measures. For 2025, the table has been refined to strengthen connectivity with financially material CRROs disclosed under SLFRS S1/S2, where applicable Refer Sustainability-related Financial Disclosures.
| Value/Risk driver | Risks | Opportunities | Impact on strategy | Relevant capital(s) | Bank’s sustainability framework pillar |
Management measures | Relevant SDG(s) | Financial impact drivers | Time horizon | |
Thematic material matter 1: Risk, Compliance, and Governance |
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| 1.1 Credit risk and asset quality |
Deterioration in borrower cash flows or collateral values can increase ECL, reduce earnings and capital, and constrain growth capacity. | Strong risk selection, monitoring and remediation improve risk-adjusted returns and resilience through cycles. | Maintaining disciplined growth through sector/segment focus, stronger early warning, and active portfolio rebalancing. |
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Risk-based underwriting; portfolio monitoring and early warning; concentration limits; remediation/recovery governance. | Credit/ECL; Capital adequacy; Earnings | ||||
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1.2 Cybersecurity and data privacy |
Breaches or outages can disrupt services, cause regulatory/legal exposure, and weaken customer and market confidence. | Strong cyber resilience protects franchise value, enables safe digital growth and improves operational continuity. | Investing in IT infrastructure and cybersecurity systems to strengthen digital resilience, security-by-design and data protection to support scalable digital banking. |
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Cyber governance and controls, continuous monitoring and testing, incident response, and staff awareness, privacy compliance. | Operations (disruption); Legal/regulatory; Revenue; Reputation/market confidence | ||||
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1.3 Regulatory compliance and ethical conduct |
Non-compliance can lead to penalties, restrictions, remediation costs and reputational damage impacting funding and growth. | Strong compliance and ethics improve trust, reduce conduct risk and support stable access to capital and partnerships. | Maintaining a strong control environment and consistent conduct standards across channels and products. |
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Compliance governance; policies and training; monitoring/testing; escalation and corrective action; audit assurance. | Legal/regulatory; Reputation/market confidence; Operations | ||||
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1.4 Enterprise risk management framework |
Weak risk governance can allow emerging risks to accumulate, impairing capital, liquidity and strategic execution. | Strong ERM enables forward-looking decisions, better allocation of capital and improved resilience. | Strengthening risk appetite, stress testing and scenario thinking to support resilient growth and timely rebalancing. |
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Risk appetite framework; ICAAP/ILAA and stress tests; limits and triggers; management reporting; Board oversight. | Capital & liquidity resilience; Credit/ECL; Funding/cost of capital | ||||
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1.5 Fraud prevention and |
Fraud and financial crime can cause direct losses, regulatory scrutiny, legal exposure, service disruption and trust erosion. | Strong prevention reduces losses, improves efficiency and strengthens customer confidence. | Enhancing prevention capabilities and controls across products, channels and third parties. |
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AML/CFT and fraud controls; monitoring and analytics; customer due diligence; investigations; awareness and reporting. | Direct losses; Legal/regulatory; Reputation/market confidence; Operations | ||||
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1.6 Corporate governance |
Weak governance can impair decision quality, increase regulatory risk and erode stakeholder confidence and attract scrutiny. | Strong governance supports disciplined execution, transparency and lower cost of capital over time. | Reinforcing oversight and accountability for strategy, risk appetite and performance outcomes. |
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Board/committee oversight; governance policies; performance and risk reporting; assurance functions and disclosures. | Funding/cost of capital; Reputation/market confidence; Legal/regulatory | ||||
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1.7 Reputation and conduct risk management |
Conduct failures or service issues can trigger customer attrition, regulatory scrutiny, funding confidence impacts and affect brand value. | Strong conduct culture improves retention, reduces complaints/remediation costs and supports franchise strength. | Embedding fair conduct and transparency into product design, sales practices and service delivery. |
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Conduct standards; complaints/grievance handling; monitoring and root-cause fixes; staff training and accountability. | Funding/cost of capital; Revenue; Depositor/investor confidence | ||||
Thematic material matter 2: Financial performance and economic contribution |
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2.1 Financial performance and capital adequacy |
Earnings volatility or capital pressure can constrain growth, reduce resilience and impact funding confidence. | Sustainable profitability supports investment, buffers and consistent stakeholder returns. | Optimising risk-adjusted returns and maintain capital strength to support resilient growth. |
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Capital planning; portfolio optimisation; cost discipline; stress testing; performance monitoring and governance | Capital adequacy; Earnings; Funding/cost of capital | ||||
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2.2 Asset and liability management (including liquidity and funding resilience) |
Funding concentration, liquidity stress or repricing shocks can increase cost of funds and constrain lending capacity. | Stable, diversified funding improves resilience and supports competitive pricing and growth. | Strengthening funding diversification and balance sheet management to protect liquidity and margins. |
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ALCO governance; liquidity buffers; funding diversification; interest rate risk management; contingency funding plans. | Funding/cost of capital; Liquidity; Net interest income | ||||
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2.3 Economic impact and contribution (including support to priority sectors and productivity) |
Weak economic conditions can reduce credit demand, increase defaults and slow balance sheet growth. | Financing productive sectors and SMEs supports economic resilience and strengthens long-term franchise value. | Prioritising lending to productive and resilience-enhancing activities while maintaining risk discipline. |
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Sector strategies; SME/agri focus; product propositions; monitoring of sector concentration and performance outcomes. | Revenue growth; Portfolio diversification; Franchise strength | ||||
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2.4 Strategic partnerships (including development finance and ecosystem partnerships) |
Misaligned partnerships can create execution risk, governance issues or reputational exposure. | Partnerships can unlock funding, capability and product innovation to scale inclusion and sustainable finance. | Building partnerships that strengthen capability, funding access and customer solutions with clear governance. |
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Partner due diligence; governance frameworks; performance monitoring; clear accountability and reporting. | Funding access; Product development; Revenue; Capability uplift | ||||
Thematic material matter 3: Customer centricity and experience |
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3.1 Customer satisfaction and service quality |
Persistent service issues can increase complaints, churn and remediation costs and weaken growth. | Better service improves retention, cross-sell and brand strength, supporting sustainable earnings. | Improving service quality and reliability across channels to strengthen customer outcomes and loyalty. |
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Service standards and monitoring; complaint analytics; process fixes; staff capability; channel performance oversight. |
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Revenue; Costs (efficiency/complaints); Reputation/market confidence | |||
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3.2 Customer experience |
Friction and access barriers can reduce adoption and increase cost-to-serve, limiting growth. | Seamless journeys increase adoption, reduce cost and expand access to underserved customers. | Simplifying journeys and expand accessible channels to improve adoption and cost efficiency. |
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Channel strategy; digital onboarding and self-service; service availability monitoring; inclusion-friendly design. |
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Revenue; Cost-to-income; Operational efficiency | |||
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3.3 Product suitability and diversification |
Poor product fit or affordability issues can increase conduct risk, defaults and customer harm. | Well-designed products improve customer outcomes, loyalty and sustainable revenue growth. | Strengthening product governance and suitability to meet evolving needs while controlling conduct risk. |
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Product governance; pricing/affordability checks; disclosures; monitoring of outcomes (arrears/complaints). |
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Revenue; Conduct risk; Credit quality (mis-selling/affordability) |
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3.4 Digital engagement and reputation dynamics |
Negative digital experiences or misinformation can accelerate reputational impacts and customer attrition. | Strong digital engagement supports growth, service efficiency and faster issue resolution. | Strengthening digital engagement, communication and rapid response to protect franchise value. |
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Digital service quality monitoring; customer communication protocols; social listening; complaint response governance. |
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Revenue; Reputation/market confidence; Customer attrition risk | |||
Thematic material matter 4: Innovation and digital transformation |
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4.1 Digital transformation (customer journeys and process digitisation) |
Poor execution can increase operational risk, create customer friction and fail to deliver productivity gains. | Digitisation reduces cost-to-serve, improves turnaround times and expands scalable access. | Accelerating digitisation to improve efficiency and customer outcomes while maintaining controls. |
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Transformation governance; process redesign; change management; control testing; benefits tracking. |
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Cost efficiency; Revenue; Operational resilience | |||
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4.2 Technological infrastructure and resilience |
System outages or capacity constraints can disrupt services and increase operational and reputational risk. | Resilient infrastructure enables reliable scaling of digital services and operational continuity. | Investing to strengthen IT platforms resilience and continuity to support dependable multi-channel service. |
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DR/BCP readiness and testing; infrastructure upgrades; security controls; service availability monitoring. |
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Operations (resilience); Cost; Service continuity | |||
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4.3 Competitive advantage through technology and data analytics |
Lagging capability can weaken competitiveness and decision quality, increasing cost and risk. | Advanced analytics improves risk selection, customer targeting and operational efficiency. | Investing in analytics and automation to strengthen decision quality and scalable growth. |
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Data/analytics capability; model governance; dashboards and portfolio monitoring; workforce upskilling. |
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Revenue; Risk selection (credit); Cost efficiency | |||
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4.4 Data and reporting capabilities |
Data gaps and inconsistent methodologies can weaken SRRO/CRRO assessment, reduce decision quality, and increase regulatory and market confidence risk (including SLFRS S1/S2 readiness). | Strong data and reporting improves risk selection, portfolio oversight and disclosure credibility, supporting funding confidence and better risk-adjusted decisions. | Strengthening SRRO/CRRO data capture, governance and reporting connectivity across risk, finance and business functions. |
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Data governance and controls; portfolio mapping (sector/geography); consistent SRRO/CRRO methodologies; internal assurance and disclosure governance. |
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Funding/cost of capital (investor confidence); Regulatory risk; Risk management effectiveness | |||
Thematic material matter 5: Sustainability |
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5.1 Climate-related risks and opportunities (CRROs) – transition and physical |
Physical events and transition shifts (policy/technology/market) can impair borrower cash flows and collateral values, increase credit losses, disrupt operations, and affect funding access/cost of capital. | Financing transition and resilience solutions can diversify growth, improve portfolio resilience and strengthen access to funding/partnerships as market demand evolves. | Embedding CRRO assessment into origination, underwriting, portfolio management and operations; strengthen sector/geography analytics and resilience planning. |
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CRRO governance and integration; climate risk identification and monitoring; sector/geography guidance; scenario analysis roadmap and reporting governance (SLFRS S2). |
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Credit/ECL; Collateral values; Operations disruption; Funding/cost of capital | |||
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5.2 Environmental and social risk management in financing (ESMS/sector guidance) |
Weak E&S risk management can increase credit risk (project delays/closures), regulatory and legal exposure, and reputational risk, particularly in higher-risk sectors and larger exposures. | Strong ESMS improves underwriting discipline and portfolio quality, supports responsible growth and strengthens confidence among regulators and funding partners. | Applying risk-based E&S/ESG due diligence and monitoring for higher-risk sectors and large exposures; strengthen escalation and accountability. |
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ESMS screening and scoring; sector guidance; covenants/conditions where relevant; monitoring and independent review; enhanced due diligence for higher-risk cases. |
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Credit/ECL; Legal/regulatory; Reputation/market confidence; Portfolio concentration risk | |||
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5.3 Sustainable finance and transition/resilience financing solutions |
Misaligned products or weak eligibility/verification can create greenwashing risk and reduce funding partner confidence; missed transition demand can weaken growth opportunities. | Directing capital toward transition and resilience priorities can create new revenue streams, strengthen funding access and improve long-term portfolio resilience. | Scaling sustainable finance within risk appetite using clear eligibility criteria, monitoring and performance tracking; align product design to national priorities. |
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Sustainable finance criteria and governance; product performance tracking; partner programmes (where applicable); disclosures and controls supporting credibility. |
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Revenue growth; Funding access (DFIs/markets); Portfolio resilience; Cost of capital |
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Thematic material matter 6: People and community |
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6.1 Employee development, capability and retention |
Capability gaps or high turnover can weaken service quality, increase operational errors and raise costs. | Strong capability improves execution quality, productivity and customer outcomes. | Building skills in priority areas (risk, data, technology, sustainability) and strengthen retention of critical talent. |
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Learning and development; talent pipelines; succession planning; role-based capability frameworks; retention actions. |
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Operational capacity; Cost; Service quality; Risk execution quality |
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6.2 Health, safety and wellbeing |
Poor wellbeing can reduce productivity, increase absenteeism and create compliance exposure. | Strong wellbeing supports stable service delivery and sustainable performance. | Strengthening wellbeing and safety practices to support productivity and continuity. |
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H&S governance; wellbeing programmes; monitoring and interventions; workplace safety compliance. |
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Operations continuity; Cost; Legal/regulatory | |||
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6.3 Work-life balance and productivity enablers |
Ineffective work design can reduce engagement and productivity and increase attrition risk. | Better work design improves productivity, capability retention and service outcomes. | Improving productivity through better work practices, tooling and flexible arrangements where appropriate. |
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Workforce planning; productivity tools; flexible practices; engagement feedback loops and management accountability. |
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Cost efficiency; Operational capacity; Service quality | |||
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6.4 Financial inclusion |
Persistent access barriers can limit franchise growth and increased reliance on informal financial channels in underserved segments. | Inclusion expands the customer base, supports deposit mobilisation and diversifies portfolios, strengthening long-term franchise resilience. | Expanding practical access and adoption through multi-channel delivery and segment propositions, supported by capability-building. |
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Inclusion propositions and delivery channels; targeted segment strategies (SME/agri/youth); literacy and adoption enablement; monitoring of inclusion outcomes. |
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Revenue growth; Portfolio diversification; Deposit mobilisation | |||
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6.5 Community engagement and social investment |
Weak community trust can affect social licence and stakeholder relationships, increasing reputational and operational friction. | Targeted community investment strengthens trust and supports long-term stakeholder relationships in priority areas. | Focusing community investment on priority outcomes with clear governance and measurable reach. |
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CSR governance; needs-based programme design; monitoring and reporting of outcomes; stakeholder engagement. |
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Reputation/market confidence; Social licence; Franchise strength | |||
Note: 2025 SLFRS disclosures prioritise CRROs due to first-year transitional relief.