Pillar 3 Disclosure Index BNG Bank 2016 BANK

Pillar 3 Disclosure Index BNG Bank 216 BANK

CONTENTS 2 Contents 1 Introduction 4 2 Scope of disclosure 6 3 Frequency and means of disclosure 7 4 Pillar 3 disclosures 8 Annex 1 Capital main features template 42 Annex 2 Own Funds Disclosure Template 49 Annex 3 Capital requirements for risk weighted exposure amounts 7 Annex 4 Exposure categories 73 Annex 5 Geographical distribution exposures 78 Annex 6 Exposure to type of counterparty and exposure category 81 Annex 7 Exposure value by risk weighting and exposure category 86

CONTENTS 3 Annex 8 Exposure equity category 89 Annex 9 Securitisation positions 91 Annex 1 Leverage ratio disclosure template 94

1 INTRODUCTION 4 1 Introduction The current international regulatory framework for banks consists of a comprehensive set of measures developed by the Basel Committee on Banking Supervision (known as Basel III). Basel III has been implemented in the European Union through the Capital Requirements Directive IV (CRD IV) and is applicable as of January 1st 214. CRD IV is formed by two legal acts (a Directive and a Regulation) and includes various transitional provisions which allow for a gradual phasing in of the new requirements. The Basel framework (and thus CRD IV) is based upon three pillars: The first pillar consists of minimum capital requirements for three main categories of risk: credit risk, market risk and operational risk. The second pillar provides a framework for banks to review their capital (and liquidity) adequacy for both the risks identified in Pillar 1 as well as all other risks (e.g. concentration risk, strategic risk, etc.). This internal review by banks is known as the Internal Capital/Liquidity Adequacy Assessment Process (ICAAP/ILAAP). Supervisors independently assess these processes in their Supervisory Review and Evaluation Process (SREP). Finally the third pillar aims to introduce market discipline to complement the capital and liquidity requirements from the first and second pillar. Therefore Basel III (and CRD IV) contains a set of disclosure requirements which will allow market participants to have a sufficient understanding of a bank s activities, the risks that are involved and the controls that are implemented to manage these risks.

1 INTRODUCTION 5 This report is drafted in response to the last pillar. Since most Basel III information is currently disclosed in the financial statements, this report mainly serves as a reference guide to clearly indicate where relevant information can be found. However, some of the disclosures in the context of Pillar 3 are included in Annexes to this report as the information does not fit well into the context of the financial statements. Furthermore, references are made to the website of BNG Bank in some cases as well. All amounts in this document are in millions of euros, unless stated otherwise. The level of application is consolidated.

2 SCOPE OF DISCLOSURE 6 2 Scope of disclosure The Pillar 3 disclosures provide a comprehensive overview of the risk profile of BNG Bank. Central to the Pillar 3 disclosure requirements is to promote the transparency of financial institutions and provide market participants with an adequate and comparable picture of the risks of a financial institution. This contributes to a proper functioning of financial markets, improves efficiency of market discipline and helps in building trust between market participants.

3 FREQUENCY AND MEANS OF DISCLOSURE 7 3 Frequency and means of disclosure The Pillar 3 disclosure of BNG Bank is published annually. This Pillar 3 Report is published on the website of BNG Bank in conjunction with the publication of the Annual Report. This document currently mainly serves as a reference guide to clearly indicate where the Basel III information is disclosed in the financial statements 1. However, compared to the previous Pillar 3 disclosure report more information is included in Annexes to this report itself as it was deemed less relevant for the financial statements. In section 4 each Pillar 3 disclosure requirement is addressed. An annual publication of a comprehensive Pillar 3 disclosure report is deemed sufficient. BNG Bank is characterized by a stable business model with a limited range of activities and exposures. The resulting risk profile of BNG Bank is not prone to any rapid changes and an annual disclosure suffices. 1 On 14 December 216 EBA had published its final report on Guidelines on disclosure requirements under Part Eight of Regulation (EU) No 575/213. In accordance with timelines included in these guidelines BNG Bank will review this report in 217 and incorporate any necessary changes in the next Pillar 3 disclosure per end 217. However, BNG Bank does publish an interim report on its website which is reviewed by an external auditor. Any sudden changes in the financial position or in the markets in which BNG Bank operates will be addressed in this interim report. If these circumstances would lead to material changes in the risk profile of BNG Bank an additional disclosure of some or all of the Pillar 3 requirements will be contemplated. Finally, it should be noted that the appropriateness of the disclosed information is approved by the Executive Board of BNG Bank. Information that is considered to be proprietary or confidential will not be published, but is disclosed in a more general manner. The Annual Report itself is audited by an external auditor.

4 PILLAR 3 DISCLOSURES 8 4 Pillar 3 disclosures The Pillar 3 disclosure requirements are included in the Capital Requirements Regulation (no. 575/213). More specifically the individual criteria are addressed in Part Eight, articles 435-455. For each criterion a reference is provided below to indicate where the relevant information is included in the Annual Report. Reference is made to the English version of the Annual Report and where applicable some additional remarks are included.

4 PILLAR 3 DISCLOSURES 9 ARTICLE REQUIREMENT REFERENCE REMARKS 435 1 RISK MANAGEMENT OBJECTIVES AND POLICIES Institutions shall disclose their risk management objectives and policies for each separate category of risk, including the risks referred to under this Title. These disclosures shall include: (a) the strategies and processes to manage those risks; Annual Report 216, Risk Section, pp. 21-217 (b) the structure and organisation of the relevant risk management function including information on its authority and statute, or other appropriate arrangements; Annual Report 216, Risk Section, pp. 218-221 (c) the scope and nature of risk reporting and measurement systems; Annual Report 216, Risk Section, pp. 22-221 (d) the policies for hedging and mitigating risk, and the strategies and processes for monitoring the continuing effectiveness of hedges and mitigants; Annual Report 216, pp. 158-159, 35-37

4 PILLAR 3 DISCLOSURES 1 ARTICLE REQUIREMENT REFERENCE REMARKS (e) a declaration approved by the Annual Report This is part of the overall in control management body on the adequacy 216, statement which is prepared each of risk management arrangements of Report of the year. the institution providing assurance that Executive Board, the risk management systems put in pp. 91-93, 124 place are adequate with regard to the institution s profile and strategy; (f) a concise risk statement approved by the Annual Report The four components of the risk management body succinctly describing 216, appetite statement comprise the institution s overall risk profile Risk Section, profitability, solvency, liquidity and associated with the business strategy. pp. 213-217 reputation. The qualitative ambitions This statement shall include key ratios have been included in the Annual and figures providing external report and subsequently this appetite stakeholders with a comprehensive view is translated into individual risks. of the institution s management of risk, Quantitative targets are not disclosed including how the risk profile of the due to their confidential nature. institution interacts with the risk tolerance set by the management body.

4 PILLAR 3 DISCLOSURES 11 ARTICLE REQUIREMENT REFERENCE REMARKS 2 Institutions shall disclose the following information, including regular, at least annual updates, regarding governance arrangements: (a) the number of directorships held by Annual Report Next to the description in the Annual members of the management body; 216, Report an overview is included on Organisation, the website which provides more pp. 19-21 and context on the nature of the individual website BNG Bank directorships. (b) the recruitment policy for the selection Annual Report A short summary of the work of members of the management body 216, performed by the Selection and and their actual knowledge, skills and Report of the Appointments Committee in 216 expertise; Supervisory Board, is included in the Annual Report. pp. 29-3, 36, Details on the required profile of the 39-42 and supervisory and executive boards is website BNG Bank provided on the website of BNG Bank. (c) the policy on diversity with regard to Annual Report Changes in the composition of the selection of members of the management 216, boards are reported in the Annual body, its objectives and any relevant Report of the Report. The policy on diversity is part targets set out in that policy, and the Supervisory Board, of the profile of the supervisory and extent to which these objectives and pp. 29-3, 36, executive boards that is disclosed on targets have been achieved; 39-42 and the website of BNG Bank. website BNG Bank

4 PILLAR 3 DISCLOSURES 12 ARTICLE REQUIREMENT REFERENCE REMARKS (d) whether or not the institution has set up a separate risk committee and the number of times the risk committee has met; Annual Report 216, Report of the Supervisory Board, pp. 32, 34-36, 41-42 (e) the description of the information flow on risk to the management body. Annual Report 216, Risk Section, pp. 218-221 436 SCOPE OF APPLICATION Institutions shall disclose the following information regarding the scope of application of the requirements of this Regulation in accordance with Directive 213/36/EU: (a) the name of the institution to which the Annual Report N.V. Bank Nederlandse Gemeenten requirements of this Regulation apply; 216, Report of the Supervisory Board, p. 45

4 PILLAR 3 DISCLOSURES 13 ARTICLE REQUIREMENT REFERENCE REMARKS (b) an outline of the differences in the basis Annual Report There is no difference in scope of of consolidation for accounting and 216, consolidation for accounting and prudential purposes, with a brief Accounting prudential purposes for BNG Bank description of the entities therein, Principles, and BNG Bank consolidates 2 small explaining whether they are: pp. 14, 411-412 entities. An overview of these entities (i) fully consolidated; is included in Annex A of the Annual (ii) proportionally consolidated; Report. (iii) deducted from own funds; (iv) neither consolidated nor deducted; (c) any current or foreseen material practical or legal impediment to the prompt transfer of own funds or repayment of liabilities among the parent undertaking and its subsidiaries; (d) the aggregate amount by which the actual own funds are less than required in all subsidiaries not included in the consolidation, and the name or names of such subsidiaries;

4 PILLAR 3 DISCLOSURES 14 ARTICLE REQUIREMENT REFERENCE REMARKS (e) if applicable, the circumstance of making Annual Report BNG Bank makes use of the use of the provisions laid down in Articles 216, Derogation from the application 7 and 9. Risk Section, of prudential requirements on an pp. 281-282 individual basis in Article 7. 437 OWN FUNDS Institutions shall disclose the following information regarding their own funds: (a) a full reconciliation of Common Equity Tier 1 items, Additional Tier 1 items, Tier 2 items and filters and deductions applied pursuant to Articles 32 to 35, 36, 56, 66 and 79 to own funds of the institution and the balance sheet in the audited financial statements of the institution; Annual Report 216, Risk Section, pp. 28-288

4 PILLAR 3 DISCLOSURES 15 ARTICLE REQUIREMENT REFERENCE REMARKS (b) a description of the main features of the Annual Report The capital instruments of BNG Bank Common Equity Tier 1 and Additional 216, are limited to share capital and hybrid Tier 1 instruments and Tier 2 instruments pp. 164-166, capital, which are both not publicly issued by the institution; 185-188 and traded and lack any complex features. Annex 1 BNG Bank has opted for a concise to this report description of the main features in its Annual Report. The capital instruments main features template as included in the EU Implementing Regulation no 1423/213 is provided in Annex 1 to this report. (c) the full terms and conditions of all BNG Bank own funds consists of Common Equity Tier 1, Additional Tier 1 share capital (which is limited to and Tier 2 instruments; Dutch public authorities by its articles of association) and hybrid capital. These instruments are only placed privately with a limited number of investors. Therefore terms and conditions for these instruments are only made available to these parties on the basis of confidentiality.

4 PILLAR 3 DISCLOSURES 16 ARTICLE REQUIREMENT REFERENCE REMARKS (d) separate disclosure of the nature and Annual Report Items included in the table in the amounts of the following: 216, Annual Report are limited to those (i) each prudential filter applied pursuant Risk Section, that are relevant for BNG Bank. The to Articles 32 to 35; pp. 284-288 complete standardized template is (ii) each deduction made pursuant to and Annex 2 included in Annex 2 to this report. Articles 36, 56 and 66; to this report (iii) items not deducted in accordance with Articles 47, 48, 56, 66 and 79; (e) a description of all restrictions applied Annual Report Items included in the table in the to the calculation of own funds in 216, Annual Report are limited to those accordance with this Regulation and Risk Section, that are relevant for BNG Bank. The the instruments, prudential filters and pp. 284-288 complete standardized template is deductions to which those restrictions and Annex 2 included in Annex 2 to this report. apply; to this report (f) where institutions disclose capital ratios calculated using elements of own funds determined on a basis other than that laid down in this Regulation, a comprehensive explanation of the basis on which those capital ratios are calculated.

4 PILLAR 3 DISCLOSURES 17 ARTICLE REQUIREMENT REFERENCE REMARKS 438 CAPITAL REQUIREMENTS Institutions shall disclose the following information regarding the compliance by the institution with the requirements laid down in Article 92 of this Regulation and in Article 73 of Directive 213/36/EU: (a) a summary of the institution s approach Annual Report to assessing the adequacy of its internal 216, capital to support current and future Risk Section, activities; pp. 28-289 (b) upon demand from the relevant No such demand has been received, competent authority, the result of the and as referred to in point (a) a institution s internal capital adequacy summary description of the ICAAP assessment process including the is provided for in the risk paragraph composition of the additional own funds of the Annual Report. The SREP requirements based on the supervisory requirement which is based on the review process as referred to in point (a) ICAAP is included in the Risk Section of Article 14 (1) of Directive 213/36/EU; (p. 281). (c) for institutions calculating the risk- Annex 3 As the overview on risk-weighted weighted exposure amounts in to this report exposures is no longer included in the accordance with Chapter 2 of Part Three, context of the Annual Report, the Title II, 8% of the risk-weighted exposure overview is now included in Annex 3 amounts for each of the exposure classes to this report. specified in Article 112;

4 PILLAR 3 DISCLOSURES 18 ARTICLE REQUIREMENT REFERENCE REMARKS (d) for institutions calculating risk-weighted BNG Bank does not apply an Internal exposure amounts in accordance with Ratings Based Approach when Chapter 3 of Part Three, Title II, 8% of the calculating its risk-weighted exposure risk-weighted exposure amounts for each amounts. of the exposure classes specified in Article 147. For the retail exposure class, this requirement applies to each of the categories of exposures to which the different correlations in Article 154 (1) to (4) correspond. For the equity exposure class, this requirement applies to: (i) each of the approaches provided in Article 155; (ii) exchange traded exposures, private equity exposures in sufficiently diversified portfolios, and other exposures; (iii) exposures subject to supervisory transition regarding own funds requirements; (iv) exposures subject to grandfathering provisions regarding own funds requirements;

4 PILLAR 3 DISCLOSURES 19 ARTICLE REQUIREMENT REFERENCE REMARKS (e) own funds requirements calculated in BNG Bank has no trading book and accordance with points (b) and (c) of no separate own fund requirement is Article 92 (3); calculated for settlement risk. (f) own funds requirements calculated in Annex 3 As the overview on risk-weighted accordance with Part Three, Title III, to this report exposures is no longer included in the Chapters 2, 3 and 4 and disclosed context of the Annual Report, the separately. overview is now included in Annex 3 to this report. The institutions calculating the risk- BNG Bank does not apply an Internal weighted exposure amounts in Ratings Based Approach when accordance with Article 153 (5) or Article calculating its risk-weighted exposure 155 (2) shall disclose the exposures amounts. assigned to each category in Table 1 of Article 153 (5), or to each risk weight mentioned in Article 155 (2). 439 EXPOSURE TO COUNTERPARTY CREDIT RISK Institutions shall disclose the following information regarding the institution s exposure to counterparty credit risk as referred to in Part Three, Title II, Chapter 6:

4 PILLAR 3 DISCLOSURES 2 ARTICLE REQUIREMENT REFERENCE REMARKS (a) a discussion of the methodology used to Annual Report assign internal capital and credit limits for 216, counterparty credit exposures; Risk Section, pp. 245, 288-289 (b) a discussion of policies for securing Annual Report collateral and establishing credit reserves; 216, Risk Section, pp. 245-252 (c) a discussion of policies with respect to BNG Bank has not identified any Wrong-Way risk exposures; Wrong-Way risk. (d) a discussion of the impact of the amount Annual Report of collateral the institution would have to 216, provide given a downgrade in its credit Risk Section, rating; p. 248

4 PILLAR 3 DISCLOSURES 21 ARTICLE REQUIREMENT REFERENCE REMARKS (e) gross positive fair value of contracts, Annual Report netting benefits, netted current credit 216, exposure, collateral held and net Risk Section, derivatives credit exposure. Net pp. 245-248 derivatives credit exposure is the credit exposure on derivatives transactions after considering both the benefits from legally enforceable netting agreements and collateral arrangements; (f) measures for exposure value under the Annual Report methods set out in Part Three, Title II, 216, Chapter 6, Sections 3 to 6 whichever Risk Section, method is applicable; pp. 245-246 (g) the notional value of credit derivative BNG Bank has no credit derivative hedges, and the distribution of current hedges. credit exposure by types of credit exposure;

4 PILLAR 3 DISCLOSURES 22 ARTICLE REQUIREMENT REFERENCE REMARKS (h) the notional amounts of credit derivative transactions, segregated between use for the institution s own credit portfolio, as well as in its intermediation activities, including the distribution of the credit derivatives products used, broken down further by protection bought and sold within each product group; (i) the estimate of α if the institution has received the permission of the competent authorities to estimate α. 44 1 CAPITAL BUFFERS An institution shall disclose the following information in relation to its compliance with the requirement for a countercyclical capital buffer referred to in Title VII, Chapter 4 of Directive 213/36/EU:

4 PILLAR 3 DISCLOSURES 23 ARTICLE REQUIREMENT REFERENCE REMARKS (a) the geographical distribution of its credit No countercyclical capital buffer is exposures relevant for the calculation of required for BNG Bank and therefore its countercyclical capital buffer; no disclosure on this buffer is provided. As the overview in Annex 5 shows the credit exposures are mainly concentrated in The Netherlands. (b) the amount of its institution specific countercyclical capital buffer. 441 INDICATORS OF GLOBAL SYSTEMIC IMPORTANCE BNG Bank has not been identified as a global systemically important institution. 442 CREDIT RISK ADJUSTMENTS Institutions shall disclose the following information regarding the institution s exposure to credit risk and dilution risk:

4 PILLAR 3 DISCLOSURES 24 ARTICLE REQUIREMENT REFERENCE REMARKS (a) the definitions for accounting purposes of Annual Report past due and impaired ; 216, Risk Section, p. 24 (b) a description of the approaches and Annual Report Further details are considered methods adopted for determining 216, confidential and seem redundant specific and general credit risk pp. 151-153, 173, considering the limited materiality adjustments; 195-196, 24-244 in relation to the balance size. (c) the total amount of exposures after Annual Report Material information on the credit accounting offsets and without taking 216, risk profile is included in the Annual into account the effects of credit risk Risk Section, report. A detailed overview broken mitigation, and the average amount of pp. 222-228 down by exposure category is the exposures over the period broken and Annex 4 included in Annex 4 to this report. down by different types of exposure to this report classes; (d) the geographic distribution of the Annual Report Material information on the credit exposures, broken down in significant 216, risk profile of BNG Bank is included areas by material exposure classes, and Risk Section, in the Annual report. A more detailed further detailed if appropriate; pp. 228-233 overview of the geographical and Annex 5 distribution is included in Annex 5 to to this report this report.

4 PILLAR 3 DISCLOSURES 25 ARTICLE REQUIREMENT REFERENCE REMARKS (e) the distribution of the exposures by Annual Report Material information on the credit industry or counterparty type, broken 216, risk profile of BNG Bank is included down by exposure classes, including Risk Section, in the Annual report. A more detailed specifying exposure to SMEs, and further pp. 233-239 overview of the distribution by detailed if appropriate; and Annex 6 counterparty and exposure category to this report is included in Annex 6 to this report. (f) the residual maturity breakdown of all the Annual Report This is especially relevant for the exposures, broken down by exposure 216, liquidity and funding risk and a classes, and further detailed if appropriate; Risk Section, breakdown is therefore included in pp. 26-265 that section of the Annual Report. Due to the limited number of exposure classes a further breakdown is not material. (g) by significant industry or counterparty Annual Report The amount of impaired exposures is type, the amount of: 216, limited for BNG Bank, which is in line (i) impaired exposures and past due pp. 173, 24-243 with the safe risk profile of BNG Bank. exposures, provided separately; A further break-down of information (ii) specific and general credit risk could potentially be linked to individual adjustments; counterparties and is deemed (iii) charges for specific and general credit confidential. risk adjustments during the reporting period;

4 PILLAR 3 DISCLOSURES 26 ARTICLE REQUIREMENT REFERENCE REMARKS (h) the amount of the impaired exposures Annual Report Due to the limited impaired exposures and past due exposures, provided 216, and the limited geographical spread separately, broken down by significant pp. 173, 24-243 of these impairments a separate break geographical areas including, if practical, down of geographic areas is not the amounts of specific and general material and therefore not provided. credit risk adjustments related to each geographical area; (i) the reconciliation of changes in the Annual Report Although limited in materiality specific and general credit risk 216, reconciliation is provided on the adjustments for impaired exposures, pp. 173, 195-196, incurred loss provision for loans on shown separately. The information 24-244 consolidated level is provided on page shall comprise: 173 as well as a split of the opening (i) a description of the type of specific and closing balances in specific and general credit risk adjustments; and general provisioning. The (ii) the opening balances; methodology as well as any other (iii) the amounts taken against the credit impairment are clarified in the other risk adjustments during the reporting sections of the Annual Report. period;

4 PILLAR 3 DISCLOSURES 27 ARTICLE REQUIREMENT REFERENCE REMARKS (iv) the amounts set aside or reversed for estimated probable losses on exposures during the reporting period, any other adjustments including those determined by exchange rate differences, business combinations, acquisitions and disposals of subsidiaries, and transfers between credit risk adjustments; (v) the closing balances. Specific credit risk adjustments and recoveries recorded directly to the income statement shall be disclosed separately. Annual Report 216, Notes to Financial Statements, pp. 195-196 443 UNENCUMBERED ASSETS

4 PILLAR 3 DISCLOSURES 28 ARTICLE REQUIREMENT REFERENCE REMARKS EBA shall issue guidelines specifying the disclosure of unencumbered assets, taking into account Recommendation ESRB/212/2 of the European Systemic Risk Board of 2 December 212 on funding of credit institutions (1) and in particular Recommendation D Market transparency on asset encumbrance, by 3 June 214. Those guidelines shall be adopted in accordance with Article 16 of Regulation (EU) No 193/21. Annual Report 216, Risk Section, pp. 269-27 On 3rd of March 217 EBA published a report on regulatory technical standards that further builds on the previous guidelines for disclosure on unencumbered assets. These standards will be further incorporated in the next Pillar 3 disclosure of BNG Bank. EBA shall develop draft regulatory technical standards to specify disclosure of the balance sheet value per exposure class broken down by asset quality and the total amount of the balance sheet value that is unencumbered, taking into account Recommendation ESRB/212/2 and conditional on EBA considering in its report that such additional disclosure offers reliable and meaningful information.

4 PILLAR 3 DISCLOSURES 29 ARTICLE REQUIREMENT REFERENCE REMARKS EBA shall submit those draft regulatory technical standards to the Commission by 1 January 216. Power is delegated to the Commission to adopt the regulatory technical standards referred to in the first subparagraph in accordance with Articles 1 to 14 of Regulation (EU) No 193/21. 444 USE OF ECAI S For institutions calculating the risk-weighted exposure amounts in accordance with Part Three, Title II, Chapter 2, the following information shall be disclosed for each of the exposure classes specified in Article 112: (a) the names of the nominated ECAIs and Annual Report Clients of BNG Bank generally do not ECAs and the reasons for any changes; 216, have an external credit rating. Instead Risk Section, the bank determines creditworthiness pp. 236-237, 245 using internally developed rating models. For financial counterparties BNG Bank uses S&P, Moody s, Fitch and DBRS.

4 PILLAR 3 DISCLOSURES 3 ARTICLE REQUIREMENT REFERENCE REMARKS (b) the exposure classes for which each ECAI Annual Report or ECA is used; 216, Risk Section, pp. 245, 249-252 (c) a description of the process used to Annual Report Since most assets do not have an transfer the issuer and issue credit 216, external credit rating BNG Bank assessments onto items not included Risk Section, generally uses internally developed in the trading book; pp. 236-237, 245 rating models. Where applicable external ratings are used as an input in these models. (d) the association of the external rating of Used rating agencies are part of the each nominated ECAI or ECA with the published list of ECAIs by EBA. credit quality steps prescribed in Part Three, Title II, Chapter 2, taking into account that this information needs not be disclosed if the institution complies with the standard association published by EBA;

4 PILLAR 3 DISCLOSURES 31 ARTICLE REQUIREMENT REFERENCE REMARKS (e) the exposure values and the exposure Annex 7 As this overview is no longer included values after credit risk mitigation to this report in the context of the Annual Report, associated with each credit quality it is now included in Annex 7 to this step prescribed in Part Three, Title II, report. Chapter 2 as well as those deducted from own funds. 445 EXPOSURE TO MARKET RISK The institutions calculating their own funds requirements in accordance with points (b) and (c) of Article 92 (3) shall disclose those requirements separately for each risk referred to in those provisions. In addition, the own funds requirement for specific interest rate risk of securitisation positions shall be disclosed separately. Annual Report 216, Risk Section, pp. 281-282 and Annex 3 to this report BNG Bank has no trading book.

4 PILLAR 3 DISCLOSURES 32 ARTICLE REQUIREMENT REFERENCE REMARKS 446 OPERATIONAL RISK Institutions shall disclose the approaches for the assessment of own funds requirements for operational risk that the institution qualifies for; a description of the methodology set out in Article 312 (2), if used by the institution, including a discussion of relevant internal and external factors considered in the institution s measurement approach, and in the case of partial use, the scope and coverage of the different methodologies used. Annual Report 216, Risk Section, pp. 281-282 and Annex 3 to this report It should be noted that in 216 BNG Bank changed to the standardized approach instead of the previously applied basis indicator approach. BNG Bank considers this new approach is more in line with expectations from for example supervisors. This new approach did not lead to any significant changes in the actual calculated risk weighted exposures for operational risk. 447 EXPOSURES IN EQUITIES NOT INCLUDED IN THE TRADING BOOK Institutions shall disclose the following information regarding the exposures in equities not included in the trading book:

4 PILLAR 3 DISCLOSURES 33 ARTICLE REQUIREMENT REFERENCE REMARKS (a) the differentiation between exposures Annex 8 BNG Bank has a small exposure in based on their objectives, including for to this report equities. As this overview is no longer capital gains relationship and strategic included in the context of the Annual reasons, and an overview of the Report, it is now included in Annex 8 accounting techniques and valuation to this report. methodologies used, including key assumptions and practices affecting valuation and any significant changes in these practices; (b) the balance sheet value, the fair value Annex 8 and, for those exchange-traded, a to this report comparison to the market price where it is materially different from the fair value; (c) the types, nature and amounts of Annex 8 exchange-traded exposures, private to this report equity exposures in sufficiently diversified portfolios, and other exposures; (d) the cumulative realised gains or losses Annex 8 arising from sales and liquidations in the to this report period; and

4 PILLAR 3 DISCLOSURES 34 ARTICLE REQUIREMENT REFERENCE REMARKS (e) the total unrealised gains or losses, the total latent revaluation gains or losses, and any of these amounts included in Common Equity Tier 1 capital. Annex 8 to this report 448 EXPOSURE TO INTEREST RATE RISK ON POSITION NOT INCLUDED IN THE THE TRADING BOOK Institutions shall disclose the following information on their exposure to interest rate risk on positions not included in the trading book: (a) the nature of the interest rate risk and the key assumptions (including assumptions regarding loan prepayments and behaviour of non-maturity deposits), and frequency of measurement of the interest rate risk; Annual Report 216, Risk Section, pp. 253-257 (b) the variation in earnings, economic value or other relevant measure used by the management for upward and downward rate shocks according to management s method for measuring the interest rate risk, broken down by currency. Annual Report 216, Risk Section, pp. 255-256

4 PILLAR 3 DISCLOSURES 35 ARTICLE REQUIREMENT REFERENCE REMARKS 449 EXPOSURE TO SECURITISATION POSITIONS Institutions calculating risk-weighted exposure amounts in accordance with Part Three, Title II, Chapter 5 or own funds requirements in accordance with Article 337 or 338 shall disclose the following information, where relevant, separately for their trading and nontrading book: Items (a) to (r) 2. Annual Report 216, Risk Section, pp. 249-252 and Annex 9 to this report In the Annual Report only high-level information is provided on the investments of BNG Bank in interestbearing securities. Further details on the exposure to securitisations are included in Annex 9 to this report. 45 REMUNERATION POLICY 2 Due to limited materiality and high level of detail of these items they are not included in this report.

4 PILLAR 3 DISCLOSURES 36 ARTICLE REQUIREMENT REFERENCE REMARKS 1 Institutions shall disclose at least the Annual Report BNG Bank has a prudent system of following information, regarding the 216, remuneration which is in line with its remuneration policy and practices of the pp. 43-44, 311-315 simplicity. No variable components as institution for those categories of staff and website shares or options are included in the whose professional activities have a BNG Bank remuneration and no individuals are material impact on its risk profile: being remunerated EUR 1 million or Items (a) to (j) 3. more. Information regarding the remuneration in the reporting period 2 For institutions that are significant in is included in the Annual Report. terms of their size, internal organisation More details on the remuneration and the nature, scope and the complexity policy, committee, system and criteria of their activities, the quantitative are provided on the website (e.g. information referred to in this Article remuneration report). shall also be made available to the public at the level of members of the management body of the institution. 3 Due to high level of detail Institutions shall comply with the requirements set out in this Article in a manner that is appropriate to their size, internal organisation and the nature, scope and complexity of their activities and without prejudice to Directive 95/46/EC. these items are not individually addressed in this report.

4 PILLAR 3 DISCLOSURES 37 ARTICLE REQUIREMENT REFERENCE REMARKS 451 1 LEVERAGE Institutions shall disclose the following information regarding their leverage ratio calculated in accordance with Article 429 and their management of the risk of excessive leverage: (a) the leverage ratio and how the institution Annex 1 The standardised template for the applies Article 499 (2) and (3); to this report disclosure of the leverage ratio is included in Annex 1 to this report. (b) a breakdown of the total exposure Annex 1 measure as well as a reconciliation of the to this report total exposure measure with the relevant information disclosed in published financial statements; (c) where applicable, the amount of derecognised fiduciary items in accordance with Article 429 (11); (d) a description of the processes used to Annual Report Due to its materiality reference to manage the risk of excessive leverage; 216, the planning for the leverage ratio pp. 14-15, 35, 72, 76, is made in several sections of the 88, 28-281, 322 Annual Report. and Annex 1 to this report

4 PILLAR 3 DISCLOSURES 38 ARTICLE REQUIREMENT REFERENCE REMARKS (e) a description of the factors that had an impact on the leverage ratio during the period to which the disclosed leverage ratio refers. Annual Report 216, Risk Section, pp. 28-281 and Annex 1 to this report 452 USE OF THE IRB APPROACH TO CREDIT RISK BNG Bank does not apply the IRB Approach. 453 USE OF CREDIT RISK MITIGATION TECHNIQUES The institutions applying credit risk mitigation techniques shall disclose the following information: (a) the policies and processes for, and an Annual Report For annual reporting purposes indication of the extent to which the 216, balance sheet netting is not applied, entity makes use of, on- and off-balance Risk Section, while for regulatory purposes netting sheet netting; pp. 246-248 is applied to derivatives exposures.

4 PILLAR 3 DISCLOSURES 39 ARTICLE REQUIREMENT REFERENCE REMARKS (b) the policies and processes for collateral Annual Report valuation and management; 216, Risk Section, p. 234 (c) a description of the main types of Annual Report collateral taken by the institution; 216, Risk Section, pp. 234, 246-248 (d) the main types of guarantor and credit Annual Report Most loans (approximately 9%) derivative counterparty and their 216, provided by BNG Bank are mitigated creditworthiness; Risk Section, by Dutch government guarantee or pp. 234-235, guarantee funds backed by the Dutch 245-246 government. (e) information about market or credit risk Annual Report concentrations within the credit 216, mitigation taken; Risk Section, pp. 228-234

4 PILLAR 3 DISCLOSURES 4 ARTICLE REQUIREMENT REFERENCE REMARKS (f) for institutions calculating risk-weighted exposure amounts under the Standardised Approach or the IRB Approach, but not providing own estimates of LGDs or conversion factors in respect of the exposure class, separately for each exposure class, the total exposure value (after, where applicable, on or off-balance sheet netting) that is covered after the application of volatility adjustments by eligible financial collateral, and other eligible collateral; Annex 4 to this report (g) for institutions calculating risk-weighted exposure amounts under the Standardised Approach or the IRB Approach, separately for each exposure class, the total exposure (after, where applicable, on- or off-balance sheet netting) that is covered by guarantees or credit derivatives. For the equity exposure class, this requirement applies to each of the approaches provided in Article 155. Annex 4 to this report

4 PILLAR 3 DISCLOSURES 41 ARTICLE REQUIREMENT REFERENCE REMARKS 454 USE OF THE ADVANCED MEASUREMENT APPROACHES TO OPERATIONAL RISK BNG Bank does not apply the AMA approach to operational risk. 455 USE OF INTERNAL MARKET RISK MODELS BNG Bank does not apply internal market risk models.

ANNEX 1 CAPITAL MAIN FEATURES TEMPLATE 42 Annex 1 Capital main features template

ANNEX 1 CAPITAL MAIN FEATURES TEMPLATE 43 N.V. BANK NEDERLANDSE GEMEENTEN 1 Issuer N.V. Bank Nederlandse N.V. Bank Nederlandse N.V. Bank Nederlandse Gemeenten Gemeenten Gemeenten 2 Unique identifier (eg CUSIP, ISIN XS131137433 XS145352378 or Bloomberg identifier for private placement) 3 Governing law(s) of the instrument Laws of the Laws of the Laws of the Netherlands Netherlands Netherlands REGULATORY TREATMENT 4 Transitional CRR rules Common Equity Tier 1 Additional Tier 1 Additional Tier 1 5 Post-transitional CRR rules Common Equity Tier 1 Additional Tier 1 Additional Tier 1 6 Eligible at solo / (sub-)consolidated Solo & Solo & Solo & / solo&(sub-)consolidated (sub-)consolidated (sub-)consolidated (sub-)consolidated 7 Instrument type (types to be Ordinary share Perpetual Capital Perpetual Capital specified by each jurisdiction) Security Security

ANNEX 1 CAPITAL MAIN FEATURES TEMPLATE 44 8 Amount recognised in regulatory EUR 145 EUR 424 EUR 39 capital (Currency in million, as of most recent reporting date) 9 Nominal amount of instrument EUR 139 EUR 424 EUR 39 9a Issue price 1% for 1st tranche at 1% for 1st tranche 16/11/215 (a 2 nd at 28/7/216 (two tranche was issued on follow-up tranches 15/12/215 on the same were issued in second terms with a price of half of 216 on same 1.61%) terms at 1.34% and 99.72% respectively) 9b Redemption price Subject to write down Subject to write down 1 Accounting classification Shareholders equity Equity Equity 11 Original date of issuance 23 December 1914 16 November 215 28 July 216 12 Perpetual or dated Perpetual Perpetual Perpetual 13 Original maturity date no maturity no maturity no maturity 14 Issuer call subject to prior No Yes Yes supervisory approval

ANNEX 1 CAPITAL MAIN FEATURES TEMPLATE 45 15 Optional call date, contingent call 16 May 221 and every 16 May 222 and every dates, and redemption amount interest payment date interest payment date thereafter, thereafter, tax and/or regulatory tax and/or regulatory event call, event call, redemption at redemption at prevailing principal prevailing principal amount amount 16 Subsequent call dates, if applicable Interest payment date Interest payment date (16 May) (16 May) COUPONS/DIVIDENDS 17 Fixed or floating dividend/coupon Floating Fixed Fixed 18 Coupon rate and any related index 3.622%, resettable on 3.277%, resettable on 16 May 221 and every 16 May 222 and every 5 years afterwards 5 years afterwards equal to prevailing equal to prevailing 5-year Mid-Swap Rate 5-year Mid-Swap Rate plus initial margin plus initial margin 19 Existence of a dividend stopper

ANNEX 1 CAPITAL MAIN FEATURES TEMPLATE 46 2a Fully discretionary, partially Mandatory Mandatory Mandatory discretionary or mandatory (in terms of timing) 2b Fully discretionary, partially Fully discretionary Fully discretionary Fully discretionary discretionary or mandatory (in terms of amount) 21 Existence of step up or other No No incentive to redeem 22 Noncumulative or cumulative Noncumulative Noncumulative Noncumulative 23 Convertible or non-convertible Nonconvertible Nonconvertible Nonconvertible 24 If convertible, conversion trigger(s) 25 If convertible, fully or partially 26 If convertible, conversion rate 27 If convertible, mandatory or optional conversion 28 If convertible, specify instrument type convertible into

ANNEX 1 CAPITAL MAIN FEATURES TEMPLATE 47 29 If convertible, specify issuer of instrument it converts into 3 Write-down features No Yes Yes 31 If write-down, write-down trigger(s) CET1 ratio < 5.125% CET1 ratio < 5.125% 32 If write-down, fully or partially Partially Partially 33 If write-down, permanent or Temporary Temporary temporary 34 If temporary write-down, Pro rata with other Pro rata with other description of write-up mechanism Discretionary Discretionary Temporary Write- Temporary Write- down Instruments, down Instruments, subject to MDA and subject to MDA and Maximum Write-up Maximum Write-up Amount Amount 35 Position in subordination hierarchy Additional Tier 1 Tier 2 instruments Tier 2 instruments in liquidation (specify instrument instruments type immediately senior to instrument) 36 Non-compliant transitioned No No No features

ANNEX 1 CAPITAL MAIN FEATURES TEMPLATE 48 37 If yes, specify non-compliant features

ANNEX 2 OWN FUNDS DISCLOSURE TEMPLATE 49 Annex 2 Own Funds Disclosure Template

ANNEX 2 OWN FUNDS DISCLOSURE TEMPLATE 5 TRANSITIONAL OWN FUNDS DISCLOSURE TEMPLATE Amounts in millions of euros COMMON EQUITY TIER 1 CAPITAL: INSTRUMENTS AND RESERVES (A) AMOUNT AT 31/12/216 (B) REGULATION (EU) NO 575/213 ARTICLE REFERENCE (C) AMOUNTS SUBJECT TO PRE- REGULATION (EU) NO 575/213 TREATMENT OR PRESCRIBED RESIDUAL AMOUNT OF REGULATION (EU) 575/213 1 Capital instruments and the related share premium accounts 145 26 (1), 27, 28, 29, EBA list 26 (3) of which: Ordinary shares 139 EBA list 26 (3) of which: Share premium 6 EBA list 26 (3) of which: Instrument type 3 EBA list 26 (3) 2 Retained earnings 2,961 26 (1) (c) 3 Accumulated other comprehensive income (and any other reserves) 278 26 (1) 3a Funds for general banking risk 26 (1) (f)

ANNEX 2 OWN FUNDS DISCLOSURE TEMPLATE 51 4 Amount of qualifying items referred to in Article 484 (3) and the related share premium accounts subject to phase out from CET1 486 (2) Public sector capital injections grandfathered until 1 january 218 483 (2) 5 Minority interests (amount allowed in consolidated CET1) 84, 479, 48 5a Independently reviewed interim profits 26 (2) net of any foreseeable charge or dividend 6 COMMON EQUITY TIER 1 (CET1 CAPITAL BEFORE REGULATORY ADJUSTMENTS 3,384 COMMON EQUITY TIER 1 (CET1) CAPITAL: REGULATORY ADJUSTMENTS 7 Additional value adjustments (negative amount) 8 34, 15 8 Intangible assets (net of related tax liability) (negative amount) 36 (1) (b), 37, 472 (4)

ANNEX 2 OWN FUNDS DISCLOSURE TEMPLATE 52 9 Empty set in the EU 1 Deferred tax assets that rely on future profitability excluding those arising from temporary difference (net of related tax liability where the conditions in Article 38 (3) are met) (negative amount) 36 (1) (c), 38, 472 (5) 11 Fair value reserves related to gains or losses on cash flow hedges 3 33 (a) 12 Negative amounts resulting from the calculation of expected loss amounts 36 (1) (d), 4, 159, 472 (6) 13 Any increase in equity that results from securitised assets (negative amount) 32 (1) 14 Gains or losses on liabilities valued at fair value resulting from changes in own credit standing 43 33 (1) (b) (c) 15 Defined-benefit pension fund assets (negative amount) 36 (1) (e), 41, 472 (7) 16 Direct and indirect holdings by an institution of own CET1 instruments (negative amount) 36 (1) (f), 42, 472 (8)

ANNEX 2 OWN FUNDS DISCLOSURE TEMPLATE 53 17 Direct, indirect and synthetic holdings of the CET1 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 (negative amount) 36 (1) (g), 44, 472 (9) 18 Direct, indirect and synthetic holdings of the CET1 instruments of financial sector entities where the institution does not have a significant investment in those entities (amount above 1% threshold and net of eligible short positions) (negative amount) 36 (1) (h), 43, 45, 46, 49 (2) (3), 79, 472 (1) 19 Direct, indirect and synthetic holdings of the CET1 instruments of financial sector entities where the institution has a significant investment in those entities (amount above 1% threshold and net of eligible short positions) (negative amount) 36 (1) (i), 43, 45, 47, 48 (1) (b), 49 (1) to (3), 79, 47, 472 (11) 2 Empty set in the EU

ANNEX 2 OWN FUNDS DISCLOSURE TEMPLATE 54 2a Exposure amount of the following items 29 36 (1) (k) which qualify for a RW of 125%, where the institution opts for the deduction alternative 2b of which: qualifying holdings outside the 36 (1) (k) (i), financial sector (negative amount) 89 to 91 2c of which: securitisation positions 29 36 (1) (k) (ii) (negative amount) 243 (1) (b) 244 (1) (b) 258 2d of which: free deliveries (negative 36 (1) (k) (iii), 379 amount) (3) 21 Deferred tax assets arising from temporary difference (amount above 1% threshold, net of related tax liability where the conditions in Article 38 (3) are met) (negative amount) 36 (1) (c), 38, 48 (1) (a), 47, 472 (5) 22 Amount exceeding the 15% threshold (negative amount) 48 (1)

ANNEX 2 OWN FUNDS DISCLOSURE TEMPLATE 55 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 36 (1) (i), 48 (1) (b), 47, 472 (11) 24 Empty set in the EU 25 of which: deferred tax assets arising from temporary difference 36 (1) (c), 38, 48 (1) (a), 47, 472 (5) 25a Losses for the current financial year 36 (1) (a), 472 (3) (negative amount) 25b Foreseeable tax charges relating to CET1 36 (1) (l) 4 As a consequence of CRR the items (negative amount) revaluation reserve is gradually phased in, in 216 6% of the unrealized gains and losses from 26 Regulatory adjustments applied to Common Equity Tier 1 in respect of 11 11 4 this revaluation reserve are included. Since BNG Bank has amounts subject to pre-crr treatment fully included its net gain in its CET1, 4% of this gain is deducted as a regulatory 26a Regulatory adjustments relating to unrealised gains and losses pursuant to 11 11 adjustment (EUR 11 million in 216). When CRR is fully phased Articles 467 and 468 in, this deduction would no longer be necessary and this would lead to a.8% increase of the capital ratios.

ANNEX 2 OWN FUNDS DISCLOSURE TEMPLATE 56 26b Amount to be deducted from or added to 481 Common Equity Tier 1 capital with regard to additional filters and deductions required pre CRR 27 Qualifying AT1 deductions that exceeds the AT1 capital of the institution (negative amount) 36 (1) (j) 28 TOTAL REGULATORY ADJUSTMENTS TO COMMON EQUITY TIER 1 (CET1) 184 29 COMMON EQUITY TIER 1 (CET1) CAPITAL 3,2 ADDITIONAL TIER 1 (AT1) CAPITAL: INSTRUMENTS 3 Capital instruments and the related share premium accounts 733 51, 52 31 of which: classified as equity under applicable accounting standards 733 32 of which: classified as liabilities under applicable accounting standards

ANNEX 2 OWN FUNDS DISCLOSURE TEMPLATE 57 33 Amount of qualifying items referred to in Article 484 (4) and the related share premium accounts subject to phase out from AT1 486 (3) Public sector capital injections grandfathered until 1 january 218 483 (3) 34 Qualifying Tier 1 capital included in consolidated AT1 capital (including minority interest not included in row 5) issued by subsidiaries and held by third parties 85, 86, 48 35 of which: instruments issued by subsidiaries subject to phase-out 486 (3) 36 ADDITIONAL TIER 1 (AT1) CAPITAL BEFORE REGULATORY ADJUSTMENTS 733 ADDITIONAL TIER 1 (AT1) CAPITAL: REGULATORY ADJUSTMENTS 37 Direct and indirect holdings by an institution of own AT1 instruments (negative amount) 52 (1) (b), 56 (a), 57, 475 (2)