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Contents
MB Statement
SB Statement
Key Highlights
Strategy
Risk Factors & Outlook
Sustainability
Performance Overview
Risk Management
Events After 2022
Financial Report
with the aim of efficient credit risk management and optimal
capital consumption. The Group has a system for monitoring
and reporting collateral at fair (market) value in accordance
with the International Valuation Standards (IVS). The eligibility
of collateral, by types and ratios referring to prudent lending
criteria, is set within internal lending guidelines. Credit risk
mitigation principles and rules in NLB Group are described in
more relevant details in the section ‘Credit risk management.’
When hedging market risks, namely interest rate risk and
foreign exchange risk, in line with the set risk appetite,
NLB Group follows the principle of natural hedge or using
derivatives in line with hedge accounting principles.
b) Risk management structure and organisation
NLB Group’s corporate governance framework is based
on the principles of sound and responsible governance, in
accordance with the applicable legislation of the Republic
of Slovenia, particularly the provisions of the Companies
Act (ZGD-1) and the Banking Act (ZBan-3), the Regulation on
Internal Governance Arrangements, the Management Body,
and the Internal Capital Adequacy Assessment Process for
Banks and Savings Banks, the EBA Guidelines on internal
governance, the EBA Guidelines on the assessment of the
suitability of members of the management body, and key
function holders, as well as the EBA Guidelines on remuneration
practices. Several layers of management provide cohesive risk
management governance in NLB Group.
NLB Group established three lines of a defence framework with
the aim of managing risks effectively. The three lines of defence
concept provides a clear division of activities and defines roles
and responsibilities for risk management at different levels
within the Group. Risk management in the Group acts as a
second line of defence, accountable for appropriate managing,
assessing, monitoring, and reporting of risks in the Bank as the
main entity in Slovenia, and as the competence centre in charge
of six banking members and other non-core subsidiaries which
are in a controlled wind-out.
Overall, the organisation and delineation of competencies in
NLB Group’s risk management structure is designed to prevent
conflicts of interest and ensure a transparent and documented
decision-making process, subject to an appropriate upward
and downward flow of information. Risk management in NLB
Group is managed within the Risk management competence
line, which is a specialised competence line encompassing
several professional areas for which the Global Risk
Department, the Credit Risk – Corporate Department, the
Credit Risk – Retail Department and the Evaluation and Control
Department are responsible within NLB, and which reports to
the Assets and Liabilities Committee (ALCO) of the Management
Board and the Risk Committee of the Supervisory Board. The
risk management competence line is in charge of formulating
and controlling the risk management policies of NLB Group,
setting limits, establishing methodologies, overseeing the
harmonisation of risk management policies within the NLB
Group, monitoring NLB Group’s risk exposures, and preparing
external and internal reports.
All members of NLB Group that are included in the financial
statements of NLB Group, report their exposure to risks to the
competent organisational units within the Risk management
competence line. These organisational units then report all
relevant risk information to the Assets and Liabilities Committee
(ALCO) of the Management Board, the Management Board and
the Risk Committee of the Supervisory Board, which is where
the Management Board and the Supervisory Board, adopt
appropriate measures.
The credit ratings of clients that are materially important
to NLB Group and the issuing of credit risk opinions are
centralised via the Credit Committee of NLB. The process
follows the co-decision principle, in which the credit committee
of the respective Group member first approves their decision,
following which the Credit Committee of NLB gives their
opinion. The resolution of the Credit Committee of NLB is
made on the basis of all available documentation, including
a non-binding rating opinion prepared by the underwriting
department of NLB. This same principle and process is also set
for the issuing of credit exposures for the materially important
clients of NLB Group.
Risk monitoring in NLB Group members is operating within
an independent and/or separate organisational unit. This
way, monitoring of risks is established based on standardised
and systemic risk management approaches. This monitoring
enables a comprehensive overview of the Group’s and of each
member’s statement of financial position. In compliance with
the risk appetite, risk management strategy, and policies of NLB
Group, risk monitoring in each NLB Group member is separated
from its management and/or business function to maintain
the objectivity required when assessing business decisions
(three lines of defence concept). The organisational unit for
managing risks directly reports to the Management Board and
its committees (Credit Committee, ALCO and the Operational
Risk Committee) and Management Board, which report to the
Supervisory Board (the Risk Committee of the Supervisory
Board or Board of Directors).
c) Risk measurement and reporting systems
As a systemic banking group, NLB Group is subject to the Single
Supervisory Mechanism (SSM), which is supervised by the Joint
Supervisory Team (JST) of the ECB and the Bank of Slovenia.
The Group member complies with the ECB regulation, while
NLB Group subsidiaries operating outside Slovenia are also
compliant with the rules set by the local regulators. A third-party
equivalent was approved in Serbia, Bosnia and Herzegovina,
and North Macedonia, resulting in alignment of local regulation
with CRR rules. With regards to capital adequacy, based on the
provisions of the Directive (CRD), Decision (CRR), NLB Group
applies a standardised approach to credit and market risk,
and the basic approach (a simplified approach with less data
granularity) to operational risks, with the exception of NLB
which applies the standardised approach.
Across the Group, risks are assessed, monitored, managed,
or mitigated in a uniform manner, as defined in the Group’s
Risk management standards, and consider the specifics of the
markets in which individual NLB Group members operate. For
the purposes of measuring exposure to credit risk, liquidity
risk, interest rate, and credit spread risk in the banking book,
operational risk, market risk, ESG, and non-financial risks,
in addition to the prescribed regulations, NLB Group uses
internal methodologies and approaches that enable more
detailed monitoring and management of risks. These internal
methodologies are aligned with ECB, EBA, and Basel guidelines,
as well as best practices in banking methodologies.
As for risk reporting, NLB Group’s internal guidelines reflect, in
addition to internal requirements, the substance and frequency
of reporting required by the Bank of Slovenia and the ECB.
In addition, each member of NLB Group also complies with
the requirements of its local regulations. Risk reporting is
carried out in the form of standardised reports, pursuant to
risk management policies based on common methodologies
for measuring exposure to risks, uniform database structure
within Data Warehouse (DWH), comprehensive data quality
assurance, and automated report preparation, which ensures
the quality of reports and reduces the possibility of errors.
d) Data and IT system
Risk data are calculated and stored in NLB Group DWH,
collected from NLB and other Group member’s DWH. The
established process provides an integrated information in