Pillar 3 Disclosures
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Pillar 3 Disclosures Translation from the Italian original which remains the definitive version st as at 31 December 2016 1 8° Joint Stock Company Registered office: Bergamo, Piazza Vittorio Veneto 8 Operating offices: Bergamo, Piazza Vittorio Veneto 8; Brescia, Via Cefalonia 74 Member of the Interbank Deposit Protection Fund and the National Guarantee Fund Tax Code, VAT No. and Bergamo Company Registration No. 03053920165 ABI (Italian Banking Association) 3111.2 Register of Banks No. 5678 Register of banking groups No. 3111.2 Parent of the Unione di Banche Italiane Banking Group Share capital as at 31st December 2016: €2,440,750,987.5 fully paid up www.ubibanca.it 2 Contents Introduction .......................................................................................................................... 5 Risk management objectives and policies ............................................................................... 7 The Scope of application ...................................................................................................... 39 Own funds .......................................................................................................................... 43 Leverage ratio ..................................................................................................................... 69 Credit risk: general disclosures and impairment for all banks .............................................. 73 Credit risk: disclosures for portfolios subject to the standardised approach and the use of ECAIs ................................................................................................................................. 83 Credit risk: use of the IRB approach .................................................................................... 85 Credit risk mitigation techniques ....................................................................................... 105 Exposure to counterparty risk ........................................................................................... 111 Exposures in positions to securitisations ........................................................................... 125 Operational risk ................................................................................................................ 133 Exposures to equity instruments not included in the trading portfolio ................................ 135 Exposure to interest rate risk on positions not included in the trading portfolio .................. 139 Encumbered and unencumbered assets ............................................................................ 143 The Group Remuneration and Incentive Policy ................................................................... 145 Statement of the Senior Officer Responsible for the preparation of corporate accounting documents ........................................................................................................................ 147 3 4 Introduction Pillar 3 regulations require compulsory disclosures on capital adequacy, exposure to risks and the general characteristics of systems designed to identify, measure and manage these risks. Where internal systems are used to calculate capital requirements for credit and operational risks, disclosure of this information constitutes a necessary condition for recognition of these approaches for regulatory purposes. From 1st January 2014, Pillar 3 Disclosures are regulated by Part Eight and Part Ten (Title I, Chapter 3) of Regulation EU 575/2013 (the "CRR") and by regulatory and implementation provisions issued by the European Commission with regulations for the following: standard templates for the public disclosure of information on own funds; standard templates for the public disclosure of information on own funds in the period running from 1st January 2014 to 31st December 2021; disclosure obligations concerning reserves in equity; standard templates for the disclosure of information on indicators of systemic importance; disclosures concerning balance sheet assets free from encumbrances; standard templates for the disclosure of information on leverage ratios. The information must be published on the bank’s website at least once per year, when its annual report is published. The CRR does not explicitly require interim disclosures, but it is left at the discretion of banks to publish some or all the information more frequently. The UBI Group has decided to maintain the content and frequency of its Pillar 3 disclosures (quarterly) the same as under the preceding regulations. Essentially the regulations require the same information content as for disclosures in force until 31st December 2013, with the addition of further information on governance, remuneration and unencumbered assets and with the disclosure of the leverage ratio indicator. The new regulations give a list of the minimum disclosure requirements without requiring special summary tables (the “Tables” of the previous regulations), except for those indicated above. The UBI Banca Group has defined a process for producing Pillar 3 public disclosures with the following aims: to produce adequate information on capital adequacy, exposure to risks and the general characteristics of the systems employed to identify, measure and manage them, which is then included in the Pillar 3 Disclosures; to formalise the processes used by the Group for the preparation and publication of the Pillar 3 Disclosures; to allow a structured approach to be taken to verifying the reliability and proper implementation of activities to produce, prepare and disclose the information. This Pillar 3 Disclosures document has been prepared by means of co-operation between the various bodies and units involved in the governance and execution of processes, consistent with their responsibilities as assigned by internal Group regulations. 5 For full information, the information published relates to the regulatory consolidation, which consists of those entities subject to banking consolidation for regulatory purposes. Any differences with respect to other sources (consolidated financial statements prepared with the same reporting date) are therefore attributable to differences in the scope of consolidation considered. The UBI Banca Group has published this Pillar 3 Disclosures document on its website in the investor relations section (www.ubibanca.it). Further information on risk and capital adequacy is reported in the Management Report and in the notes to the consolidated financial statements as at and for the year ended 31st December 20161. Furthermore, all information on the corporate governance of UBI Banca and on Group Remuneration and Incentive Policies is reported in the “Report on Corporate Governance and the Ownership Structure” and in the “Report on Remuneration”. These reports may be consulted on the corporate website of the bank at the address: www.ubibanca.it. NOTE: all the figures contained in the disclosure tables are stated in thousands of euros, unless otherwise stated. 1 See Part E and Part F of the notes to the financial statements. 6 Risk management objectives and policies Qualitative information The UBI Group has adopted a risk control system which provides regulations to implement the guidelines of the Internal Control System in an integrated manner in order to allow the Parent to perform its activities of policy setting and strategic, management and operational control effectively and economically. Group member companies co-operate pro-actively in identifying risks to which they are subject and in defining the relative criteria for measuring, managing and monitoring them. The key principles on which Group risk analysis and management are based for the pursuit of an increasingly more knowledgeable and efficient allocation of economic and regulatory capital are as follows: rigorous containment of financial and credit risks and strong management of all types of risk; the use of a sustainable value creation approach to the definition of risk appetite and the allocation of capital; definition of the Group’s risk appetite with reference to specific types of risk and/or specific activities in a set of policy regulations for the Group and for the single entities within it. The system of risk governance and management is reflected in the organisational structure of the Group, which is designed, from an organisational, regulatory and methodological viewpoint, to ensure that operations have an appropriate risk appetite. Risk objectives and governance and risk-taking policies are set by the Supervisory Board, with support from specific committees2 and from the Chief Risk Officer (CRO), who reports directly to the Chief Executive Officer. The Management Board is responsible for implementing the risk management process, supported by the work of management committees3. In detail the CRO is responsible for the risk control function, the implementation of governance policies and the risk management system, performing the control function and providing the governing bodies with an overview of the various risks (credit, market, operational, liquidity, reputational etc.). He co-ordinates the process of defining and managing the Risk Appetite Framework (RAF) in 2 One internal board committee with an important role is the Risk Committee formed at the end of 2015. Its purpose is to support the Supervisory Board with fact finding, advisory and proposal making functions in carrying out its responsibilities in its capacity as the strategic supervisory