Additional informatikon regarding the nature of capital and risk of Šiaulių Bankas AB

Transcription

1 Additional informatikon regarding the nature of capital and risk of Šiaulių Bankas AB

2 Hereby we provide additional information following the chapter eight of Regulation (EU) No 575/2013 of the European Parliament and of the Council on prudential requirements for credit institutions and investment firms. Information on risk, its management and capital of Šiaulių Bankas AB (hereinafter referred to as the Bank) is disclosed in the annual report of the Bank The document includes separate or consolidated information as of 31 December Three following key levels of consolidation are applied the Bank, separately. the Financial Group which includes the Bank and its subsidiary companies: SB lizingas UAB (nature of activities consumer funding), Šiaulių banko lizingas UAB (nature of activities finance leases (leasing) and leases), Šiaulių banko investicijų valdymas UAB (nature of activities investment management) and Šiaulių banko turto fondas UAB (nature of activities real estate management). The Group, which includes the Bank and its subsidiary companies: SB lizingas UAB, Šiaulių banko lizingas UAB, Šiaulių banko investicijų valdymas UAB, Šiaulių banko turto fondas UAB, SBTF UAB (nature of activities: management and administration of real estate), Minera UAB (nature of activities: real estate management activities), Pavasaris UAB (nature of activities: development of residential apartment area), Life insurance company Bonum Publicum UAB (nature of activities: life insurance), and Bank indirectly controls the following subsidiary Sandworks UAB (nature of activities: real estate management). A c t i v i t y R i s k M a n a g e m e n t The Group accepts, manages, analyses, and evaluates the risks arising from its activities. The purpose of risk management in the Group is to ensure the sufficient return on equity by managing risks in a conservative manner. By implementing an advanced risk management policy, the Group seeks not only to minimize the potential risks as much as possible, but also to ensure the optimal risk and profit ratio as well as an effective distribution of the capital. The risk management policy is approved by the Bank's Supervisory Council and its implementation controlled by the Board of the Bank. It specifies the risks incurred in the activities of the Group and the principles of the risk management system. The development of the proper risk management system, its constant improvement and application of its measures in the daily performance are among the key preconditions for the Group activities in the long run. The procedures for the management of various types of risks prepared on the basis of the policy specify the principles of management of particular risks and ensure the integrity of the risk management process throughout the Group. The Group revises its risk management policies and systems regularly, at least once a year, with regard to market changes, new products, and newly applied principles best practices. Risk management is a structured, consistent and on-going process taking place in all levels of the Group which assists establishing and assessing possibilities and threats affecting the achievement of the Group's goals and allows making decisions with respect to certain actions. Since various risks encountered by the Group are interdependent, their management is centralized and performed by the Bank s Risk Management Committee. Organization and coordination of the experienced risk management system is one of the main goals of the Bank s Risk Management Committee. Seeking to avoid the conflict of interest, the Bank s units performing the risk management functions are separated from the units, the direct performance of which are related to the emergence of various types of the banking activity risks. Internal Capital Adequacy Assessment Process (ICAAP) is one of key elements in the Group s risk management and decision-making. The purpose of the Group s ICAAP is to implement the processes ensuring calculation of the requirement of the Group's capital sufficient to cover the activity risks and to ensure the continuity of the performance as well as appropriate formation of the capital base. ICAAP includes the Bank's self-assessment, stress testing and establishment of the internal capital requirement. During the internal self-assessment risks that are characteristic to the Group's activities are identified and evaluated applying selected methods of assessment. An impact of a certain risk on the Group's income and capital is assessed while determining the level of risk. The major

3 goal of the stress testing is to establish if the Group s capital is adequate to cover the likely loss which could be incurred from the deterioration of the Group s financial status. Additional capital requirement for the risks, which during self assessment were identified as significant, is subject to the regular stress testing and Internal Capital Adequacy Assessment Process. C a p i t a l M a n a g e m e n t The capital of the Bank and Financial Group is calculated and allocated for the risk coverage following the requirement provided for in the Capital Requirements Directive (CRD) and Capital Requirements Regulation (CRR) No.575/2013. The capital management objectives are as follows: 1) to comply with the own funds requirements set by the European Parliament and the Council of the European as well as the higher target capital requirements set by the major shareholder; 2) to safeguard the Bank s and Financial Group s ability to continue as a going concern so that it can provide returns for shareholders and benefits for other stakeholders; 3) to support the development of the Bank and Financial Group s business with the help of the strong capital base. Information regarding capital adequacy is submitted to the supervising authority quarterly in accordance with the CRR/CRD IV requirements. At 31 December 2015, institutions operating in Lithuania are subject to capital buffers, which are added to the capital ratios mentioned above: Countercyclical capital buffer: rate currently applied in Lithuania is 0%. The countercyclical capital buffer may be increased under conditions of the unsustainable credit growth in Lithuania; Capital conservation buffer: rate of 2.5% is applied; Additional capital requirement of 2.0% is allocated for the risks that are identified as material in the process of self-assessment using stress tests and internal capital adequacy assessment (Pillar II). This requirement is subject to annual review in the process of supervisory review and evaluation (SREP). On 17 December 2015 the Bank received a resolution from its supervisory institution (Bank of Lithuania) indicating that it was recognized to be other systematically important institution. An extra other systemically important institution buffer (O-SII) of 0.5% will apply to the Bank starting from 31 December The Bank shall at all times satisfy the following own funds requirements: 1) A Common Equity Tier 1 capital ratio of 9%. The Common Equity Tier 1 capital ratio is the Common Equity Tier 1 capital of the institution expressed as a percentage of the total risk exposure amount. 2) A Tier 1 capital ratio of 10.5%. The Tier 1 capital ratio is the Tier 1 capital of the institution expressed as a percentage of the total risk exposure amount. 3) A total capital ratio of 12.5%. The total capital ratio is the own funds of the institution expressed as a percentage of the total risk exposure amount

4 FINANCIAL BANK EUR thousand GROUP GROUP Common equity tier 1 capital eligible as CET1 Capital Paid up capital instruments 91,226 91,226 91,226 Share premium Previous years retained earnings 16,194 19,078 18,874 Interim profit eligible for inclusion 11,708 10,748 7,996 Other reserves Statutory reserve 2,290 2,464 2,468 Part of financial assets revaluation reserve (-) Goodwill ,752 (-)Intangible assets ,018 (-)Deferred tax assets that rely on future profitability (-)Value adjustments due to requirements for prudent valuation TIER 1 CAPITAL 121, , ,347 Capital instruments and subordinated loans eligible as T2 Capital: Subordinated loan capital 20,000 20,000 20,000 Part of financial assets revaluation reserve TIER 2 CAPITAL 20,538 20,538 20,538 OWN FUNDS 141, , ,885 Own funds requirements for:: Risk weighted exposure amount for credit risk under the Standardized Approach 845, , ,386 Traded debt instruments 26,835 26,943 35,609 Equity Foreign exchange Operational risk under the Basic Indicator Approach 98, , ,907 Other capital requirements (credit value adjustment risk) Total risk exposure amount 971, , ,031 CET1 Capital ratio (9%) 12.48% 12.70% 12.12% T1 Capital ratio (10.5%) 12.48% 12.70% 12.12% Total capital ratio (12.5%) 14.59% 14.82% 14.24% The risk-weighted assets are measured under a standardized approach using risk weights classified according to the nature of each asset and counterpart, taking into account collaterals and guarantees eligible for risk mitigation. A similar treatment with some adjustments is adopted for the off-balance sheet exposures. Capital requirements for operational risk are calculated using the Basic Indicator Approach. EUR million Original exposure BANK FINANCIAL GROUP GROUP RWA Capital requirements Original exposure RWA Capital requirements Original exposure RWA Capital requirements Credit, counterparty credit risk 1, , , Central governments or central banks Regional governments or local authorities Public sector entities Institutions Corporates of which subject to

5 SME Retail of which subject to SME Secured by mortgages on immovable property of which subject to SME Items associated with particular high risk of which subject to SME Exposures in default of which subject to SME Exposures in the form of units or shares in CIUs Equity Other items Central governments or central banks Position, foreign exchange and commodities risks Traded debt instruments Equity Foreign Exchange Operational risk Credit Valuation Adjustment Total amount 1, , , I n t e r n a l C a p i t a l A d e q u a c y A s s e s s m e n t P r o c e s s ( I C A A P ) Sound and comprehensive ICAAP is vital part of a strong risk management policy. The purpose of the Bank's ICAAP is to implement the processes ensuring calculation of the Bank's capital requirement sufficient to cover the activity risks and to ensure the continuity of the performance, calculation of capital requirement and well as appropriate formation of the capital base.

6 The ICCAP goal is to ensure an efficient mechanism functioning within the Bank to measure an internal capital requirement covering the following areas: 1) functional and efficient Bank's management measures, including the Bank's clear organizational structure with well-defined, transparent and consistent lines of responsibility; 2) efficient processes of establishment, management and monitoring of risks faced by the Bank or which may be faced by the Bank as well as process of delivery of information on such risks; 3) appropriate internal control mechanisms including reliable management and accounting procedures; 4) stress-testing as an integral part of the Bank's ICAAP. The initial stages of the ICAAP include the risk identification and risk assessments which are realized during the Bank's self-assessment. During this process, types of risks typical to the Bank's activities are identified and evaluated under the chosen assessment approaches. During the Bank's self-assessment, a factual structure of the risks assumed by the Bank is reviewed and a level of individual risk types is evaluated. An impact of risk on the Bank's income and capital is assessed while determining the level of risk. Stress testing is an integral part of the ICCAP used to assess the internal capital requirement. The major goal of the stress testing is to establish if the Bank s capital is adequate to cover the likely loss which could be incurred from the deterioration of the Bank s financial status. In order to determine the capital requirement necessary for management of individual risk types as well as total risk incurred by the Bank, various scenarios of the stress testing are applied. The capital adequacy ratio of the Bank and Financial Group under Pillar 1 comprised 14,59 and 14,82 per cent respectively at the end of October the Board of the Bank of Lithuania has confirmed additional capital requirement of 2 percent from risk weighted assets until the next consideration of the Bank supervision and evaluation process results. Results of internal capital adequacy assessment are provided in the table below: EUR thousand BANK FINANCIAL GROUP Own funds 141, ,630 Capital adequacy ratio 14.59% 14.82% Internal capital add-on as percentage points of capital adequacy ratio 2.00% 1.98% Risks Pillar 1 capital requirement Add-on Pillar 2 Internal capital Pillar 1 capital requirement Add-on Pillar 2 Internal capital Credit 67,614 6,607 74,221 66,574 6,549 73,123 Market 2,203 3,244 5,447 2,212 2,991 5,203 Operational 7, ,875 8, ,737 Other 34 9,597 9, ,654 9,688 Total 77,726 19,448 97,174 77,557 19,194 96,751 Moreover, the Bank is preparing a Recovery Plan. This document is prepared following the Bank Recovery and Resolution Directive 2014/59/ES approved by the European Commission and foresees all likely assumptions for recovery of financial stability of the Bank in emergency cases.

7 Capital instruments main features template (1) C a p i t a l i n s t r u m e n t s ' m a i n f e a t u r e s t e m p l a t e 1 Issuer Šiaulių bankas AB 2 Unique identifier (e.g. CUSIP, ISIN or Bloomberg identifier for private placement) LT Governing law(s) of the instrument The Republic of Lithuania Regulatory treatment 4 Transitional CRR rules Common equity tier 1 5 Post-transitional CRR rules Common equity tier 1 6 Eligible at solo/(sub-)consolidated/ solo & (sub-)consolidated Solo and (Sub- )Consolidated 7 Instrument type (types to be specified by each jurisdiction) Ordinary shares 8 Amount recognized in regulatory capital (currency in million, as of most recent EUR 91,226, reporting date) 9 Nominal amount of instrument EUR a Issue price Various 9b Redemption price N/A 10 Accounting classification Shareholders equity 11 Original date of issuance Perpetual or dated Perpetual 13 Original maturity date No maturity 14 Issuer call subject to prior supervisory approval No 15 Optional call date, contingent call dates and redemption amount N/A 16 Subsequent call dates, if applicable N/A Coupons / dividends 17 Fixed or floating dividend/coupon Floating 18 Coupon rate and any related index N/A 19 Existence of a dividend stopper No 20a Fully discretionary, partially discretionary or mandatory (in terms of timing) Partially discretionary 20b Fully discretionary, partially discretionary or mandatory (in terms of amount) Partially discretionary 21 Existence of step up or other incentive to redeem N/A 22 Noncumulative or cumulative Noncumulative 23 Convertible or non-convertible Non-convertible 24 If convertible, conversion trigger(s) N/A 25 If convertible, fully or partially N/A 26 If convertible, conversion rate N/A 27 If convertible, mandatory or optional conversion N/A 28 If convertible, specify instrument type convertible into N/A 29 If convertible, specify issuer of instrument it converts into N/A 30 Write-down features No 31 If write-down, write-down trigger(s) N/A 32 If write-down, full or partial N/A 33 If write-down, permanent or temporary N/A 34 If temporary write-down, description of write-up mechanism N/A 35 Position in subordination hierarchy in liquidation (specify instrument type N/A immediately senior to instrument) 36 Non-compliant transitioned features No 37 If yes, specify non-compliant features N/A (1) Insert 'N/A' if the question is not applicable.

8 O w n f u n d s d i s c l o s u r e t e m p l a t e Amount at disclosure date, thousands EUR Common Equity Tier 1 (CET1) capital: Instruments and reserves Financial Bank Group group 1 Capital instruments and the related share premium accounts 91,226 91,226 91,226 of which: Instrument type 1 of which: Instrument type 2 of which: Instrument type 3 2 Retained earnings 16,194 19,078 18,874 3 Accumulated other comprehensive income (and other reserves) 1,114 1,114 1,114 3a Funds for general banking risk 2,290 2,464 2,468 4 Amount of qualifying items referred to in Article 484 (3) and the related share premium accounts subject to phase out from CET1 5 Minority interests (amount allowed in consolidated CET1) 5a Independently reviewed interim profits net of any foreseeable charge or 11,708 10,748 7,996 dividend 6 Common Equity Tier 1 (CET1) capital before regulatory adjustments 122, , ,678 Common Equity Tier 1 (CET1) capital: regulatory adjustments 7 Additional value adjustments Intangible assets (net of related tax liability) ,770 9 Empty set in the EU 10 Deferred tax assets that rely on future profitability excluding those arising from temporary differences (net of related tax liability where the conditions in Article 38 (3) are met) 11 Fair value reserves related to gains or losses on cash flow hedges 12 Negative amounts resulting from the calculation of expected loss amounts 13 Any increase in equity that results from securitized assets (negative amount) 14 Gains or losses on liabilities valued at fair value resulting from changes in own credit standing 15 Defined-benefit pension fund assets 16 Direct and indirect holdings by an institution of own CET1 instruments 17 Direct, indirect and synthetic holdings of the CET 1 instruments of financial sector entities where those entities have reciprocal cross holdings with the institution designed to inflate artificially the own funds of the institution 18 Direct, indirect and synthetic holdings by the institution of the CET1 instruments of financial sector entities where the institution does not have a significant investment in those entities (amount above 10 % threshold and net of eligible short positions) 19 Direct, indirect and synthetic holdings by the institution of the CET1 instruments of financial sector entities where the institution has a significant investment in those entities (amount above 10 % threshold and net of eligible short positions) 20 Empty set in the EU 20a Exposure amount of the following items which qualify for a RW of 1250 %, where the institution opts for the deduction alternative 20b of which: qualifying holdings outside the financial sector 20c of which: securitization positions 20d of which: free deliveries 21 Deferred tax assets arising from temporary differences (amount above 1

9 0 % threshold, net of related tax liability where the conditions in Article 38 (3) are met) 22 Amount exceeding the 15 % threshold 23 of which: direct and indirect holdings by the institution of the CET1 instruments of financial sector entities where the institution has a significant investment in those entities 24 Empty set in the EU 25 of which: deferred tax assets arising from temporary differences 25a Losses for the current financial year 25b Foreseeable tax charges relating to CET1 items 27 Qualifying AT1 deductions that exceed the AT1 capital of the institution 28 Total regulatory adjustments to Common Equity Tier 1 (CET1) -1,327-1,538-4, Common Equity Tier 1 (CET1) capital 121, , ,347 Additional Tier 1 (AT1) capital: Instruments 30 Capital instruments and the related share premium accounts 31 of which: classified as equity under applicable accounting standards 32 of which: classified as liabilities under applicable accounting standards 33 Amount of qualifying items referred to in Article 484 (4) and the related share premium accounts subject to phase out from AT1 34 Qualifying Tier 1 capital included in consolidated AT1 capital (including minority interests not included in row 5) issued by subsidiaries and held by third parties 35 of which: instruments issued by subsidiaries subject to phase out 36 Additional Tier 1 (AT1) capital before regulatory adjustments Additional Tier 1 (AT1) capital: regulatory adjustments 37 Additional Tier 1 (AT1) capital: regulatory adjustments 38 Direct and indirect holdings by an institution of own AT1 instruments 39 Direct, indirect and synthetic holdings of the AT1 instruments of financial sector entities where those entities have reciprocal cross holdings with the institution designed to inflate artificially the own funds of the institution 40 Direct, indirect and synthetic holdings of the AT1 instruments of financial sector entities where the institution does not have a significant investment in those entities (amount above 10 % threshold and net of eligible short positions) 41 Direct, indirect and synthetic holdings by the institution of the AT1 instruments of financial sector entities where the institution has a significant investment in those entities (net of eligible short positions) 42 Empty set in the EU 43 Qualifying T2 deductions that exceed the T2 capital of the institution 44 Total regulatory adjustments to Additional Tier 1 (AT1) capital 45 Additional Tier 1 (AT1) capital 121, , ,347 Tier 2 (T2) capital: Instruments and provisions 46 Capital instruments and the related share premium accounts 20,538 20,538 20, Amount of qualifying items referred to in Article 484 (5) and the related share premium accounts subject to phase out from T2 48 Qualifying own funds instruments included in consolidated T2 capital (including minority interests and AT1 instruments not included in rows 5 or 34) issued by subsidiaries and held by third parties

10 49 of which: instruments issued by subsidiaries subject to phase out 50 Credit risk adjustments 51 Tier 2 (T2) capital before regulatory adjustments 20,538 20,538 20,538 Tier 2 (T2) capital: regulatory adjustments 52 Direct and indirect holdings by an institution of own T2 instruments and subordinated loans 53 Holdings of the T2 instruments and subordinated loans of financial sector entities where those entities have reciprocal cross holdings with the institution designed to inflate artificially the own funds of the institution 54 Direct and indirect holdings of the T2 instruments and subordinated loans of financial sector entities where the institution does not have a significant investment in those entities (amount above 10 % threshold and net of eligible short positions) 55 Direct and indirect holdings by the institution of the T2 instruments and subordinated loans of financial sector entities where the institution has a significant investment in those entities (net of eligible short positions) 56 Empty set in the EU 57 Total regulatory adjustments to Tier 2 (T2) capital 58 Tier 2 (T2) capital 20,538 20,538 20, Total capital (TC = T1 + T2) 141, , , Total risk weighted assets 971, , ,031 Capital ratios and buffers 61 Common Equity Tier 1 (as a percentage of total risk exposure amount) 12.48% 12.70% 12.12% 62 Tier 1 (as a percentage of total risk exposure amount) 12.48% 12.70% 12.12% 63 Total capital (as a percentage of total risk exposure amount) 14.59% 14.82% 14.24% 64 Institution specific buffer requirement (CET1 requirement in accordance 9.00% 9.00% 9.00% with article 92 (1) (a) plus capital conservation and countercyclical buffer requirements, plus systemic risk buffer, plus systemically important institution buffer expressed as a percentage of risk exposure amount) 65 of which: capital conservation buffer requirement 2.50% 2.50% 2.50% 66 of which: countercyclical buffer requirement 67 of which: systemic risk buffer requirement 67a of which: Global Systemically Important Institution (G-SII) or Other Systemically Important Institution (0-SII) buffer 68 Common Equity Tier 1 available to meet buffers (as a percentage of risk 3.48% 3.70% 3.12% exposure amount) 69 [non relevant in EU regulation] 70 [non relevant in EU regulation] 71 [non relevant in EU regulation] Amounts below the thresholds for deduction (before risk weighting) 72 Direct and indirect holdings of the capital of financial sector entities where the institution does not have a significant investment in those entities (amount below 10% threshold and net of eligible short positions) 73 Direct and indirect holdings by the institution of the CET1 instruments of financial sector entities where the institution has a significant investment in those entities (amount below 10% threshold and net of eligible short positions) 74 Empty set in the EU 75 Deferred tax assets arising from temporary differences (amount below 1 0 % threshold, net of related tax liability where the conditions in ,385

11 Article 38 (3) are met) Applicable caps on the Inclusion of provisions In Tier 2 76 Credit risk adjustments included in T2 in respect of exposures subject to standardized approach (prior to the application of the cap) 77 Cap on inclusion of credit risk adjustments in T2 under standardized 845, , ,386 approach 78 Credit risk adjustments included in T2 in respect of exposures subject to internal ratings-based approach (prior to the application of the cap) 79 Cap for inclusion of credit risk adjustments in T2 under internal ratingsbased approach Capital instruments subject to phase-out arrangements (only applicable between 1 Jan 2014 and 1 Jan 2022) 80 - Current cap on CET1 instruments subject to phase out arrangements 81 - Amount excluded from CET1 due to cap (excess over cap after redemptions and maturities) 82 - Current cap on AT1 instruments subject to phase out arrangements 83 - Amount excluded from AT1 due to cap (excess over cap after redemptions and maturities) 84 - Current cap on T2 instruments subject to phase out arrangements 85 - Amount excluded from T2 due to cap (excess over cap after redemptions and maturities)

12 C R R L e v e r a g e R a t i o D i s c l o s u r e T e m p l a t e Reference date Entity name Bank Financial group Group Level of application Individual Consolidated Consolidated Table LRSum: Summary reconciliation of accounting assets and leverage ratio exposures Applicable Amount 1 Total assets as per published financial statements 1,657,857 1,667,626 1,695,040 2 Adjustment for entities which are consolidated for accounting purposes but are outside the scope of regulatory consolidation (Adjustment for fiduciary assets recognized on the balance sheet pursuant to the applicable accounting framework but excluded from the leverage ratio total exposure measure in accordance with Article 429(13) of Regulation (EU) No 575/2013) Adjustments for derivative financial instruments Adjustment for securities financing transactions (SFTs) (1,365) (1,365) (1,365) 6 Adjustment for off-balance sheet items (i.e. conversion to credit equivalent amounts of off-balance sheet exposures) 144, , ,151 EU-6a (Adjustment for intragroup exposures excluded from the leverage ratio total exposure measure in accordance with Article 429(7) of Regulation (EU) No 575/2013) EU-6b (Adjustment for exposures excluded from the leverage ratio total exposure measure in accordance with Article 429(14) of Regulation (EU) No 575/2013) (142,375) (142,830) (142,830) 7 Other adjustments (844) (1,170) (3,949) 8 Leverage ratio total exposure measure 1,658,384 1,664,697 1,687,688 Table LRCom: Leverage ratio common disclosure CRR leverage ratio exposures On-balance sheet exposures (excluding derivatives and SFTs) 1 On-balance sheet items (excluding derivatives, SFTs and fiduciary assets, but including collateral) 1,646,375 1,655,652 1,683,066 2 (Asset amounts deducted in determining Tier 1 capital) (798) (1,170) (3,949) 3 Total on-balance sheet exposures (excluding derivatives, SFTs and fiduciary assets) (sum of lines 1 and 2) 1,645,577 1,654,482 1,679,117 Derivative exposures 4 Replacement cost associated with all derivatives transactions (i.e. net of eligible cash variation margin) 8,754 9,292 9,292 5 Add-on amounts for PFE associated with all derivatives transactions (mark- to-market method) EU-5a Exposure determined under Original Exposure Method - - -

13 6 Gross-up for derivatives collateral provided where deducted from the balance sheet assets pursuant to the applicable accounting framework (Deductions of receivables assets for cash variation margin provided in derivatives transactions) (Exempted CCP leg of client-cleared trade exposures) Adjusted effective notional amount of written credit derivatives (Adjusted effective notional offsets and add-on deductions for written credit derivatives) Total derivatives exposures (sum of lines 4 to 10) 9,395 9,933 9,933 SFT exposures 12 Gross SFT assets (with no recognition of netting), after adjusting for sales accounting transactions 2,682 2,682 2, (Netted amounts of cash payables and cash receivables of gross SFT assets) (1,365) (1,365) (1,365) 14 Counterparty credit risk exposure for SFT assets EU-14a Derogation for SFTs: Counterparty credit risk exposure in accordance with Articles 429b(4) and 222 of Regulation (EU) No 575/ Agent transaction exposures EU-15a (Exempted CCP leg of client-cleared SFT exposure) Total securities financing transaction exposures (sum of lines 12 to 15a) 1,317 1,317 1,317 Other off-balance sheet exposures 17 Off-balance sheet exposures at gross notional amount 144, , , (Adjustments for conversion to credit equivalent amounts) Other off-balance sheet exposures (sum of lines 17 and 18) 144, , ,151 Exempted exposures in accordance with Article 429(7) and (14) of Regulation (EU) No 575/2013 (on and off balance sheet) EU-19a (Intragroup exposures (solo basis) exempted in accordance with Article 429(7) of Regulation (EU) No 575/2013 (on and off balance sheet)) EU-19b (Exposures exempted in accordance with Article 429 (14) of Regulation (EU) No 575/2013 (on and off balance sheet)) (142,375) (142,830) (142,830) Capital and total exposure measure 20 Tier 1 capital 121, , , Leverage ratio total exposure measure (sum of lines 3, 11, 16, 19, EU-19a and EU-19b) 1,658,384 1,664,697 1,687,688 Leverage ratio 20 Leverage ratio 7.31% 7.39% 6.95%

14 Choice on transitional arrangements and amount of derecognised fiduciary items EU-23 Choice on transitional arrangements for the definition of the capital measure Transitional Transitional Transitional EU-24 Amount of derecognised fiduciary items in accordance with Article 429(11) of Regulation (EU) No 575/ Table LRSpl: Split-up of on balance sheet exposures (excluding derivatives, SFTs and exempted exposures) CRR leverage ratio exposures EU-1 Total on-balance sheet exposures (excluding derivatives, SFTs, and exempted exposures), of which: 1,511,240 1,519,958 1,544,593 EU-2 Trading book exposures 42,726 42,726 71,116 EU-3 Banking book exposures, of which: 1,468,514 1,477,232 1,473,477 EU-4 Covered bonds EU-5 Exposures treated as sovereigns 410, , ,253 EU-6 Exposures to regional governments, MDB, international organisations and PSE not treated as sovereigns 57,029 57,205 57,205 EU-7 Institutions 123, , ,551 EU-8 Secured by mortgages of immovable properties 317, , ,057 EU-9 Retail exposures 119, , ,799 EU-10 Corporate 324, , ,267 EU-11 Exposures in default 20,554 29,839 29,839 EU-12 Other exposures (e.g. equity, securitisations, and other non-credit obligation assets) 95, , ,506 Table LRQua: Free format text boxes for disclosure on qualitative items C R R L e v e r a g e R a t i o D i s c l o s u r e T e m p l a t e Row 1 Description of the processes used to manage the risk of excessive leverage 2 Description of the factors that had an impact on the leverage Ratio during the period to which the disclosed leverage Ratio refers Column Free format In 2015 Bank started to implement leverage risk management system which includes risk assessment procedures and provides processes which are intended for responding to changes in the leverage ratio. Leverage ratio grew by 1.08 p.p. in comparison to IQ of 2015 when the leverage ratio was started to use. This change was affected by Tier I capital growth of 17,4 EUR m and denominator (total position ratio) decrease of 8 EUR m. Leverage ratio growth was affected by the merge of Bank Finasta and growth of exposures (balance and off balance) exempted in accordance with Article 429 (14) of Regulation (EU) No 575/2013 (on and off balance sheet)).