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SOCIETE GENERALE EXPRESSBANK AD
Announcement under Regulation 575/2013 Consolidated base
SOCIETE GENERALE EXPRESSBANK AD
ANNOUNCEMENT OF ANNUAL CONSOLIDATED RESULTS
PURSUANT TO PART EIGHT
OF REGULATION (EU) NO 575/2013 OF THE EUROPEAN PARLIAMENT AND OF THE
COUNCIL
as at 31.12.2014
SOCIETE GENERALE EXPRESSBANK AD
Announcement under Regulation 575/2013 consolidated base
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TABLE OF CONTENTS
І. Scope and methods of consolidation .................................................................................................3
1. Corporate information for the Bank ...................................................................................................3
2. Consolidation base .............................................................................................................................4
II. Policy and rules for risk management ................................................................................................5
ІІІ. Structure and elements of the capital base .......................................................................................10
ІV. Capital Requirements .......................................................................................................................11
1. Internal analysis of the capital ..........................................................................................................11
2. Capital requirements for credit risk under classes of exposures ......................................................12
V. Exposures to credit risk from the counter party ..............................................................................12
VІ. Exposures to credit risk and risk dispersion ....................................................................................12
VІІ. Information for the used recognized Credit Rating Agencies upon implementation of standardized
approach to the credit risk.........................................................................................................................14
VІІІ. Internal market risk models .............................................................................................................15
ІХ. Capital requirements for currency and position risk .......................................................................15
Х. Exposure to operational risk .............................................................................................................16
ХІ Capital Instruments in the Bank Portfolio .......................................................................................17
ХІІ. Interest risk in the Bank Portfolio ....................................................................................................17
ХІІІ. Securitization ...................................................................................................................................18
XІV. Announcement of the encumbered assets ........................................................................................19
ХV. Credit Risk Reduction Techniques ....................................................................................................21
ХVI. Remunerations Policy and Practice ................................................................................................22
XVII. Leverage ……………………………………………………………………………....…………..25
Appendix 1А ………………………………………………………………………………………......…26
Appendix 1B ………………………………………………………………………………………......…27
Appendix 1C ………………………………………………………………………………………......…28
Appendix 1D ………………………………………………………………………………………......…30
Appendix 2 ……………………………………………………………………………………….........…40
SOCIETE GENERALE EXPRESSBANK AD Announcement under Regulation 575/2013
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І. SCOPE AND METHODS OF CONSOLIDATION
1. Corporate information for the Group
Societe Generale Expressbank AD (the Bank) is a shareholder company founded in Bulgaria in June
1993 as a result of the merger of twelve commercial banks and is registered in the Commercial
Register with Varna District Court by virtue of Decision No 4024 of 26 June 1993.
Since 30 November 1999 the major shareholder in the Bank is Societe Generale Paris holding 99.74 %
that is the parent company of the Bank.
In accordance with the full license issued by BNB Societe Generale Expressbank AD functions as a
universal bank, offering to the bank market full package of bank services and products.
The name of the Bank was changed in 2005 by virtue of a decision of the shareholders from the
former SG Expressbank to Societe Generale Expressbank AD.
The registered seat and management address of the Bank are in the city of Varna, No 92 Vladislav
Varnenchik blvd.
The Bank performs its activity in Bulgaria by a Head Office, 7 regional groups and 147 offices as the
total staff as at 31.12.2014 consists of 1.627 employees.
In 2005 the Bank established the subsidiary Sogelease Bulgaria EOOD that is 100% owned by it.
Sogelease Bulgaria EOOD is a company specialized in the financial and operating lease offering its
services to all of the fields of economy and industry with the exception of the real estate field at this
stage. The Bank accounts its investment in the subsidiary by its prime cost under its financial
statement in the amount of TBGN 4.100.
In 2008 the Bank reduced its participation from 49% to 41.55 % from the capital of Insurance
Shareholder Company Sogelife Bulgaria AD. Subject of activity of the company are the following
types of insurances: Life and rent insurance; Life insurance related to an investment fund, Additional
insurance and Accident insurance.
In 2008 the Bank established the subsidiary Societe Generale Factoring EOOD that is 100% owned by
it. Subject of activity of the company is factoring of client's liabilities. The Bank accounts its
investment in the subsidiary by its prime cost under its individual financial statement in the amount of
TBGN 1.100.
In 2011 the Bank established the subsidiary Regional Urban Development Fund AD that is 52 %
owned by it. Subject of activity of the company is funding urban projects against pay, included in
integrated sustainable development plans for the towns for public-private partnership. The Bank
accounts its investment in the subsidiary by its prime cost under its individual financial statement in
the amount of TBGN 130.
In February 2014 the Bank invested in the amount of 49% of the capital of ALD Automotiv OOD
amounting to BGN 1 960 000. The subject of activity of the company is operating lease, renting out
vehicles, machines and other kind of equipment, vehicle fleet management.
The Bank has two-tier management structure - Management and Supervisory Board. Five of the
members of the Management Board are Executive Officers of the Bank.
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The International Rating Agency Fitch (FitchRatings) confirmed long-term credit rating 'ВВВ+' (IDR)
with stable perspective of the Bulgarian subsidiary of SocieteGenerale - Societe Generale Expressbank
AD. To date this is the highest rating assigned by Fitch to any financial institution in Bulgaria.
The implemented consolidation methods for the purposes of this announcement (supervisory
purposes) and these applied in the public statements of the Bank, prepared pursuant to the
International Financial Reporting Standards are as follows:
Capital participation as at 31. December 2014
Consolidation for Supervisory Purposes Method
Consolidation for Public Purposes Method
SOGELEASE BULGARIA EOOD 100% Full consolidation Full consolidation
SOCIETE GENERALE FACTORING EOOD 100% Full consolidation Full consolidation
REGIONAL URBAN DEVELOPMENT FUND 52% Full consolidation Full consolidation
ALD AUTOMOTIV OOD 49% Equity method Equity method
SOGELIFE BULGARIA AD. 41.55% Equity method Equity method
2. Consolidation base
The announcements as at 2014 complied with the rules and regulatory framework for capital adequacy
of the banks according to Regulation (EU) No 575/2013 of the European Parliament and of the EU
Council, as well as in accordance with the International Financial Reporting Standards (IRFS), issued
by the International Accounting Standards Board (IASB) and the explanations on their application
issued by the International Accounting Standards Committee (IASC) adopted by the European Council
(EU) and applicable in the Republic of Bulgaria.
The consolidated financial statement is presented in Bulgarian leva and all of the indicators are
rounded up to the closest thousand Bulgarian leva (TBGN), unless stated otherwise.
The consolidated financial statement includes the financial statements of the Bank and its subsidiaries
- Sogelease Bulgaria EOOD, Societe Generale Factoring EOOD and Regional Urban Development
Fund AD prepared annually as at 31 December. The financial statements of the subsidiaries are
prepared for the same accounting period as these of the parent company and upon the application of
one and the same accounting policies.
All intragroup balances, transactions, income and expenses, as well as profits and losses being result
of intragroup deals and recognized in assets are eliminated in full.
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II. POLICY AND RULES FOR RISK MANAGEMENT
Group Risk Management Policy is established in order to ascertain, calculate and analyze the risks
being inherent for its activities, as well as to fix the proper risk limits and to monitor their observance.
In Societe General Group the following risks fully or partially are identified and managed:
Credit Risk
Societe General Expressbank observes the directives and regulations of Societe General Group for
credit risk assessment and management. It has adopted as well the regulations of the Group with
regard to the organization of the internal control - regular monitoring of the development and quality
of the Bank's portfolio conducted by the Credit and Market Risk Committee that meets regularly once
a month. Internal Audit Unit functions as well performing control on the credit risk management
process.
Risk Management Division is responsible for the credit risk assessment. It is directly subordinated to
the Chief Executive Officer of the Bank and in this way the independence of the Division from the
commercial units of the Bank has been achieved. The Director of the Risk Management Division
reports to the Chief Executive Officer of the Bank, where they both report to Risk Management
Division in Societe Generale Paris.
According to the policy of Societe Generale Group, all credit limits shall be approved by Risk
Management Division and by the commercial units, as the Chief Executive Officer of Societe
Generale Expressbank and the Chief Risk Officer who is in charge of Risk Management Division have
personally delegated limit for approval of commercial deals that are credit risk bearers. The credit
limit provided to the Chief Executive Officer allows him to approve commercial deals credit risk
bearers with regard to which Chief Risk Officer (operating his limit) has provided positive assessment
of the respective deal. In case of negative statement on behalf of Risk Management Division, the Chief
Executive Officer may exercise his right to arbitrage (that is limited below the amount of its personal
limit) or to escalate an arbitrage procedure to a higher level - the Head office of Societe Generale
Paris. All credit files exceeding these limits shall be provided to the Head Office of Societe Generale
Paris.
For credit deals with customers - “citizens” and “freelancers” the applied limit is based on three
criteria - credit exposure, maturity and collateral.
The applied limit for credit deals with corporate clients is also based on three criteria - credit exposure,
maturity and internal rating (SG rating).
Risk Management Division exercises the control on the observance of the limits for approval of credit
deals at local level.
During the regular audit missions exercised in the branch network, Internal Audit Unit is also obliged
to perform control over the observance of the limits for approval of credit deals at branch level and at
HO level.
Operational risk
Except the credit risk resulting from the traditional activity of the Bank in our daily work we are
exposed to several other risks grouped under the general name “Operational risks”. These operational
risks may lead to loss or potential losses for the Group, therefore, they should be identified and
reported in the due time.
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A specialized internal committee - Committee on the operational risks and the continuous monitoring
was established in the Bank that meets on quarterly basis.
The identification, monitoring and analysis of the internal events related to operational risk are of
significant importance for the proper management of the exposure to operational risk of the Bank and
Societe Generale Group. Collecting of full and reliable information allows the monitoring of the price
of these operational risks related to internal or external events. The reasons for the losses are analyzed
in order the necessary corrective measures to be identified.
The Bank has defined and already monitors 25 key risk indicators of operational risk.
The employees and the units participating in the process of assessment and monitoring of the
operational risk are all branch managers, regional heads of groups, heads of units, the Head of Quality
Management and Operational Risk Unit, Operational Risk Coordinator and Corporate Secretary.
Internal Audit Unit makes regular checks on the operational risk.
The Bank keeps a register of the events with operational losses - in electronic and paper format and
this activity is regulated by internal rules, instructions and procedures for the centralization of the
operational losses in the Bank. The operational risks management was controlled and monitored by the
Committee on the operational risks and continuous monitoring. The Operational Risk Coordinator
from Quality Management and Operational Risk Unit is responsible for the keeping of the register of
the events of operational losses and the Head of Quality Management and Operational Risk Unit is
responsible for the whole management of the processes related to the centralization of information for
the operational losses.
The Bank applies the following techniques for operational risk reducing:
Keeps a centralized register for occurred operational losses for the Bank and introduction of
corrective measures for the prevention from recurrence of similar events;
Monitors the main risk indicators showing the exposure to risks of the different levels and
providing actual qualitative assessment of the risk;
Self-assessment and preventing from risks and control procedures (Risk Control Self
Assessment - RCSA);
Analyses of scenarios for ascertaining the effects from more serious operating events on the
activity of the Bank;
Keeping information and monitoring on the environment and external losses (operational
losses suffered due to financial and bank institutions external for Societe Generale Group);
Keeping a Business Continuity Plan.
Market Risk
As a part of a global bank group the strategy of Societe Generale Expressbank in relation to
undertaking market risk complies with the strategic trend adopted by Societe Generale Group with
regard to its subsidiaries and could be defined as conservative. Market risks are undertaken only
within markets corresponding to the requirements for organization, transparency and liquidity, for
example - such allowing closing positions within short terms and probably without significant losses
due to insufficient liquidity.
Following the policy of the Group Societe General Expressbank is not expected to use or work with
products available in the international markets, with the exception of the cases of trading with Societe
General Paris. This concerns the centralized obtaining of products - for providing to local counter
parties or for own use. As a result of the above, the rule is that all positions being deliberately left open
and leading to market risk as general are strictly forbidden. Such positions may be permitted only with
regard to a restricted set of market instruments in case they were preliminary identified, approved and
monitored according to the respective procedure.
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The rules controlling the management of every currency or interest risk require all of risks like these to
be identified and centralized. One position must be managed only by one place and has to be a result
of flows that were not matched before that. The currency risk is controlled through setting position
limits for every separate currency (and its respective equivalence in EUR) on the daily open currency
position, as well as general limit for the general open currency position. The limits are approved and
indicated by Market Risk Division with Societe Generale Paris. The use of daily limits is daily
monitored by Market Risk Management Unit at local level. A report for currency open positions shall
be prepared and sent daily to the management and Societe Generale Paris. Upon every exceeding of
the limits explanation in writing is requested for the sources and on the manner and time of recovery
of the positions within the specific limits. The use of derivatives on foreign currency as futures
contracts is not allowed within the permitted limits. Trade only in such instruments is also strictly
forbidden. Trade at own expense in interest and derivative instruments by Financial Markets Unit on
behalf of the Bank is also strictly forbidden. The permitted use of these instruments has only hedging
and distribution to end clients purposes (the so called back-to-back deals).
Keeping governmental securities with the purpose of sale to end clients may be permitted, but only
after approval by Societe Generale Paris. Such approval usually takes the form of approved limits for
maximum nominal amount allocated in categories according to the maturity by the principle of a
“reversed pyramid”: The approved amount grows in parallel with decreasing the maturity. What shall
also be added to the above is the maximum term of holding the securities that may not be exceeded,
i.e. - 180 days after the date of purchasing. After this period of holding, the securities with fixed
income shall be sold. Additionally sub-limits shall be set for the positions in bonds according to the
currency of the issue as the permitted currencies are only BGN, EUR and USD.
Societe Generale Expressbank keeps commercial portfolio of bonds made and managed within limits
approved by Societe Generale Paris. The composition of the portfolio and the observance of the limits
shall be daily monitored by Market Risk Management Unit and this report shall be sent to the
management of the Bank and to Societe Generale Paris.
With regard to the market activities, each temporary or permanent holding of shares is forbidden.
The Credit Committee and the Assets and Liabilities Committee (ALCO) are internal committees that
aim assisting the senior management in the market risks monitoring and their use against the approved
limits.
Interest rate risk
The interest rate risk arises out of the mismatch between the balance sheet and off-balance sheet
positions as a result of the fluctuations of the interest rates in the market that subsequently leads to
change of the interest income and the economic value of the Bank. The interest risk management is of
crucial significance because one high exposure to interest risk may cause deterioration of the Bank's
results, as well as of its economic value in case of unfavorable movements of the market interest rates.
Societe Generale Expressbank calculates the interest rate level depending on the instructions of the
parent Bank as the interest rate exposures are grouped in different time intervals according to the
nearest date that is either the date of the next change of the contractual interest rate or the date of the
projected repayment of the principal.
The next date of interest rate change is either the next date on which the interest under instrument with
floating interest rate may be changed according to the terms and conditions of the agreement, or the
date of the agreed maturity, depending which of them occurs first. Residual maturity is the period from
the reporting date to the maturity of the instrument pursuant to the agreement.
The interest risk monitoring is differentiated in two aspects:
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Commercial (market) position
Structural position
The interest rate management under the commercial position is daily monitored by Risk Management
Division through a set of instruments, stress tests, sensitivity limits.
The interest rate management under the structural position of the Bank arising out of the mismatch
between the balance sheet and the off-balance sheet positions shall be monitored by Assets and
Liabilities Department to Financial Division. The structural interest rate management consists of
monitoring, calculation, reporting and execution of activities on the interest rate sensitivity
management.
The reports on the interest rate shall be prepared by Assets and Liabilities Department and discussed
quarterly by Assets and Liabilities Committee.
According to the internal rules of the Bank, the deposit base stability models and the interest rate
profile shall be approved by Societe Generale Paris in order to be used in the calculations. The last
notification by the parent bank for the deposit models is dated November 2014.
Liquidity risk
Societe Generale Expressbank manages its liquidity risk in accordance to the requirements of the
effective local legislation. The control on the liquidity executes by assets' management (providing
liquid assets for satisfying the current need of resources) and liabilities management (attracting
resources on the money market with the purpose of making up for the insufficient cash inflows).
The group established stable strategies, policies, processes and systems for identification, reporting,
management and monitoring of the liquidity risk during suitable time periods, including daily, in order
to ensure the observance of proper liquidity levels. These strategies, policies, processes and systems
are adjusted to the business trends, currencies and structures and involve proper liquidity management
mechanisms.
The Group manages the liquidity risk for match in the maturity structures of the assets and liabilities
through Assets and Liabilities Management Committee. With the purpose of effective liquidity
management the Bank management constantly takes measures for the proper allocation of the liquid
assets and the short-term liabilities, exercising daily control on the liquidity at different levels.
In August 2014 the Bank adopted general policy on liquid risk management.
The policy was established in accordance with all regulatory and group requirements and best
practices, considering the specificities of Societe Generale Expressbank with regard to the business
and economic environment.
The liquid risk management policy defines the management, the practices on the reporting and control
of the liquid risk.
In accordance with this policy early warning indicators have been developed and are observed on
weekly and monthly base with the purpose of ensuring proper and duly reaction in case of liquid crisis.
The new regulatory reports related to LCR and NSFR have been developed on the base of the assets
and liabilities maturity structure and the methodology of the Group for their reporting.
A specialized internal committee functions in Societe Generale Expressbank that is an element of the
liquid risks management structure- Assets and Liabilities Management Committee (ALCO).
ALCO consists of a Chairman - Chief Executive Officer / Deputy Chief Executive Officer and
Members - Chief Financial Officer, Chief Operating Officer, Chief Risk Officer, Head of Financial
SOCIETE GENERALE EXPRESSBANK AD Announcement under Regulation 575/2013
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Markets Department, Head of Assets and Liabilities Department (to Financial Division), Head of
Retail Banking and Commercial Network, Head of Corporate Clients and Financial Markets
Department, Head of Market Risks Department.
The meetings of the Liquidity Management Committee shall be conducted once a month.
III. EQUITY STRUCTURE AND ELEMENTS
The main aim of the Group capital management is to ensure that it maintains a stable credit rating and
proper capital ratios in order to maintain its business and to maximize the added value for the
shareholders.
In 2014 after coming into force of the requirements of Directive 2013/36/EU of the European
Parliament and of the EU Council, Ordinance No 8 of BNB on the capital adequacy of the credit
institutions was revoked and replaced by Regulation (EU) No 575/2013 of the European Parliament
and of the EU Council.
In parallel with the introducing of the new regulatory framework Basel III, BNB in its capacity of
local competent authority and based on Ordinance No. 8 of 24 April 2014 on Banks' Capital Buffers
specified the mandatory maintenance of the following two capital buffers. Capital conservation buffer
equaling 2.5 % of the total amount of the total risk exposure of the Group and systemic risk buffer
amounting to 3%.
Pursuant to the definitions of the regulatory framework Basel III, the equity includes Tier 1 capital and
Tier 2 capital after the respective deductions under art. 36, 56 and 66 of Regulation (EU) 575/2013.
The common capital adequacy of the banks shall not exceed the minimum threshold of 13.50 %. In
2014 and in 2013 the Bank observed the capital adequacy requirements set by the European
Parliament and of the EU Council.
Detailed information about equity on consolidated base of Societe Generale Expressbank AD is
provided in Appendix 1 hereunder pursuant to Commission Implementing Regulation (EU) No
1423/2013 and includes the following:
Appendix 1A - Balance sheet intended for regulatory purposes;
Appendix 1B - Matching the elements of the equity and the financial statements;
Appendix 1C - A sample on the major characteristics of the capital instruments;
Appendix 1D - Announcement of the elements of the equity during the transition period.
The Bank applies two types of buffers:
- Capital conservation buffer amounting to 2.5% of the risk-weighted assets;
- Systemic risk buffer amounting to 3% of the risk-weighted assets;
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2014 2013
Basel III Basel II
Equity 484.360 459.709
Tier one capital 456.040 421.935
Basic Equity Tier one capital 456.040 -
Tier two capital 28.320 37.774
Risk weighted assets
Risk weighted assets for credit risk 3,208,282 3,135,063
Risk weighted assets for market risk 42.550 20.488
Risk weighted assets for operational risk 318.349 303.878
Total risk weighted assets 3,569,181 3,459,429
Basic Equity Tier one capital ratio 12.78% -
Tier one capital ratio 12.78% 12.21%
Capital adequacy ratio 13.57% 13.31%
Minimum capital requirements for the basic equity tier one capital ratio (4.5%) 160.613 -
Minimum capital requirements for tier one capital (6.0% for 2014, 10.0% for 2013) 214.151 345.943
Minimum general capital requirements (8.0% for 2014, 12.0% for 2013) 285.534 415.131
Additional capital requirements for capital conservation buffer (2.5%) 89.230 - Additional capital requirements for systemic risk buffer (3.0%) 107.075 -
Adjusted minimum capital requirements for the basic tier one capital after buffers
(10%) 295.427 -
Adjusted minimum capital requirements for the tier one capital, including buffers
(11.5%) 241.889 75.992
Adjusted minimum capital requirements after buffers (13.5%) 198.826 44.578
Free capital after buffers 2.521 44.578
IV. CAPITAL REQUIREMENTS
1. Internal analysis of the capital
The Group performs regular internal analysis of the amount, type and allocation of the needed capital
that is sufficient for covering all of the risks on which the Group is or may be exposed, using reliable
and efficient strategies. The responsible authority is the effective Assets and Liabilities Committee.
Every year Group Management approves a plan for capital increase. The estimation of the needed
capital is calculated on the basis of a preliminary prepared business schedule, considering all of the
risks on which the Group is locally exposed.
The main sources for capital increase are the following:
• capitalization of profit;
• subordinated short-term debt;
• share capital increase.
2. Capital requirements for credit risk by classes of exposures
The Group uses standardized approach upon the calculation of capital requirements for credit and
market risk and for defining the capital requirements for operational risk the approach of the basic
indicator has been used.
For the needs of the regulatory reporting under Regulation (EU) No 575/2013 the Bank applies a
simplified approach for reducing the credit risk in the use of financial collaterals.
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The capital requirements for credit, market and operational risk are provided in Appendix 2
to this document.
V. EXPOSURES TO COUNTERPARTY CREDIT RISK
The Group allocates capital for counterparty credit risk arising out of the transactions in derivative
instruments, by use of the method of market valuation. The requirements of art. 271 of Regulation
575/2013 are observed and upon calculating the current exchange value and the potential future credit
exposure, the methodology set in art. 274 and the respective percents from Table No 1 of the same
article are applied.
As at 31.12.2014 the Bank calculated exposures by classes, as follows:
Classes of exposures
/Derivatives and long settlement transactions/
Value of the
balance sheet
exposure
Value of the off-
balance sheet
exposure
Institutions 799 799
Enterprises 33.305 33.305
Total 34.104 34.104
VI. EXPOSURES TO CREDIT RISK AND DISPERSION RISK
The Group evaluates and classifies its risk exposures in case there is objective evidence for
impairment (when it is likely the Group could not manage to collect, or there are no reasonable
arguments that it could collect all of its receivables pursuant to the contractual terms and conditions of
the Loan Agreement).
Provisions for impairment losses
The major criterion on defining the credit impairment loss is the presence of overdue payments of the
due amounts under principals and interests and deterioration of the financial condition of the client.
By observing the above criterion, the Group classifies the risk exposures in 10 major groups
depending on the level of the existing risk as in case there is objective evidence for need of
impairment, such is performed.
The amount of the impairment is calculated as the difference between the book value and the
recoverable amount of the exposure and the amount of the acceptable collateral according to the
internal rules of the Bank for management of the accepted collaterals.
The Group defines impairment separately for individually significant exposures on portfolio base as
well.
Impairment of individually significant exposures
The Group assesses individually each exposure of the Borrower as upon the calculation of the
impairment analysis of the solvency of the Borrower is performed, of its current financial condition,
its operating capacity during the occurred financial crisis, its possibility to provide backup finance in
order to cover its financial liabilities in case of difficulties. The Group uses the effective interest rate
for discounting the expected cash flows. Impairment is calculated and accounted as at the end of every
accounting period.
The Group identifies as "sensitive" corporate clients the financial status of which requires special
monitoring due to possibility for deterioration of the quality of servicing of their credit exposures.
These clients are considered performing and the provisions allocated for them are calculated and
accounted on portfolio base.
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Collective base impairment
Collective base impairment shall be made for loans that are not individually significant (portfolios of
individuals and small business). The Bank allocates the loans by internal classification risk groups
depending on the extent of the overdue payments. The expected cash flows are defined on historical
base in accordance to the rate of return from preceding accounting periods. Upon discounting the
Group uses the average effective interest rate for the respective type of credit product. Impairment is
calculated as at the end of each accounting period as the calculated impairment shall be approved at
Group level.
The total amount of the exposures after provisions and adjustments to the value before accounting the
effect of reducing the credit risk and adjusting the off-balance sheet position on conversion ratios as at
31 December 2014 was the following:
TBGN
Class of exposures Value of the
balance sheet
exposure
Value of the off-
balance sheet
exposure
Central governments or central banks; 964.527 0
Regional governments or local authorities; 12.360 8.254
Institutions 181.539 28.208
Enterprises 1.737.701 818.727
Retail exposures; 1.045.097 50.006
Exposures secured by real estate 480.002 13.616
Exposures at default 102.111 27.864
Exposures in capital instruments 1.960 0
Other positions. 173.369 0
Total 4.698.666 946.675
The allocation of the exposures by fields differentiated by classes of exposures before and after
impairment as at 31.12.2014 was as follows:
SOCIETE GENERALE EXPRESSBANK AD Announcement under Regulation 575/2013
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2014
Industry 966.761
Construction 76.463
Agriculture and Forestry 92.485
Transport and Communications 55.580
Trade and Services 573.033
Other fields 387.439
Corporate clients - total amount 2,151,761
Collective base impairment (36,144)
Individual base impairment (83,990)
Corporate clients - net amount 2,031,627
Consumer loans 751.180
Mortgage loans 374.435
Citizens and households - total amount 1,125,615
Collective base impairment - consumer loans (69,385)
Collective base impairment - mortgage loans (3,621)
Citizens and households - net amount 1,052,609
Provided loans to clients - net amount 3,084,236
The concentration of the credit portfolio calculated as a ratio of the ten largest exposures of clients to
the gross amount of the loans provided to clients as at 31.12.2014 was 16,80 %.
VII. INFORMATION FOR THE USED RECOGNIZED CREDIT RATING AGENCIES UPON
IMPLEMENTATION OF STANDARDIZED APPROACH TO THE CREDIT RISK
In implementation of art. 135 of Regulation 575/2013 for ascertaining the risk weights of the
exposures under the standardized approach for credit risk the Group uses the credit assessments of the
rating agencies Standard&Poor’s, Moody’s and Fitch. If for a rating position
there are two credit assessments awarded by recognized agencies and if they correspond to different
risk weights, the highest risk weight is applied.
The classes of exposures for which the Bank uses assessments of external agencies are:
Exposures to central governments or central banks;
Exposures to institutions;
Exposures to enterprises;
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The awarded credit assessments shall be equalized to the approved grades of credit quality upon
defining the risk weights of the respective exposures.
VIII. INTERNAL MARKET RISK MODELS
The Group does not apply internal market risk models.
ІХ. CAPITAL REQUIREMENTS FOR CURRENCY AND POSITION RISK
Currency risk is the risk in which the value of the financial instruments is influenced by the change in
the foreign currency exchange rates. As a result of the Currency Board effective in Bulgaria, Bulgarian
lev is fixed to the Euro with ratio BGN 1.95583 to 1 EUR, therefore the positions in this currency do
not lead to currency risk. As the currency in which the Group presents its financial statements is
Bulgarian lev, the financial statements are influenced by the movement of the currency exchange rates
between the currencies out of the Eurozone and the Bulgarian lev. These changes are monitored and
analyzed daily by the Group specialists by using different hedging techniques for maintaining the risk
within the normal range.
The currency risk is controlled through setting position limits for every separate currency (and its
respective equivalence in EUR) on the daily open currency position, as well as general limit for the
general open currency position. The limits are approved and indicated by Market Risk Division with
Societe Generale Paris. The use of daily limits is daily monitored by Market Risk Management Unit at
local level.
The table below shows the sensitivity of the profit before tax and of the equity for the significant
positions by the types of foreign currencies of the Group as at 31.12.2014. The study of the sensitivity
of the significant positions in foreign currency has no influence on the equity because the Group
accounts the currency revaluation in the Income statement in accordance with International
Accounting Standard 21.
Change of the currency
exchange rate in % 2014
Effect on the profit before
tax 2014
Effect on the equity 2014
USD
9%
(26)
-
-8% 23 -
8% (2) - GBP -4% 1 -
As at 31 December 2014 the Group did not account capital requirements for currency risk.
The position risk is the risk of change in the prices of the debt and capital instruments in the
commercial portfolio.
Societe Generale Expressbank AD maintains commercial portfolio of bonds that was made and
managed within limits approved by Societe Generale Paris. The composition of the portfolio and the
observance of the limits shall be daily monitored by Market Risk Management Unit and this report
shall be sent to the management of the Bank and to Societe Generale Paris.
SOCIETE GENERALE EXPRESSBANK AD Announcement under Regulation 575/2013
consolidated base
15
The Group examines total position risk that is the risk of change in the price of a financial instrument
as a result of a change in the interest rates level in case of a traded debt instrument or derivative.
The derivative financial instruments include forward, swap deals, etc. and are recognized first at the
moment in which the Group becomes a party under the agreement by the price of acquisition (incl.
acquisition costs) and subsequently are revaluated to their fair value. The fair value is defined on the
grounds of quoted market prices or in case of lack of such it is calculated by other techniques for
reliable defining of the fair value.
Upon calculating the position risk, the Group applies maturity approach for total risk pursuant to art.
339 of Regulation 575/2013.
Х. EXPOSURE TO OPERATIONAL RISK
As at 31.12.2014 the Group used the approach of the basic indicator upon calculating the capital
requirements for operational risk - by multiplying the average annual gross income of the bank by
ratio 0.15.
The average gross income is the sum total of the net interest income and the net non-interest income,
in average for the last three calendar years, based on the audited financial statements for the respective
years.
The annual gross income is calculated before the discounting of the provisions for covering
impairment losses and after the excluding of:
The profit from sale of financial assets intended for disposal.
Other income from the activity
As at 31 December 2014 the Group reported capital requirements for market and operational risk, as
follows:
TOTAL AMOUNT OF RISK EXPOSURES FOR:
TBGN
MARKET RISK 42,550
OPERATIONAL RISK 318,349
XІ. CAPITAL INSTRUMENTS IN THE BANK PORTFOLIO
These assets may be sold as a reply to changes in the market risks or the requirements to liquidity and
include shares and partnerships in local and foreign commercial enterprises, shares in other financial
institutions and governmental securities.
The subsequent assessment is by fair value, with the exception of the cases when the fair
value could not be reliably assessed.
The Group revaluates its capital investments classified as financial assets disposable for sale in case
there is significant or continuous drop of their fair value below their book value or in case there is
objective evidence for revaluation. Defining whether the drop to be significant or continuous requires
evaluation of all of the significant factors as the sensitivity of the prices of capital investments, etc.
SOCIETE GENERALE EXPRESSBANK AD Announcement under Regulation 575/2013
consolidated base
16
The non-realized profits and losses due to a change in the fair value of these financial assets shall be
posted under the equity item.
The book value of the capital instruments as of 31. December 2014 was TBGN 639.
The complete amount of the investments in shares was accounted by 100% risk under class of
exposure “Other positions”.
XIІ. INTEREST RISK IN THE BANK PORTFOLIO
The match or the controlled mismatch of the assets and liabilities interest rates is of key significance
for the Group profit management. In order to ascertain the vulnerability of the Group to interest risk
shall be tracked the imbalance of all of the interest rate exposures, including the derivatives. The
interest rate exposures are grouped in different time intervals according to the nearest date that is
either the date of the next change of the contractual interest rate or the date of the projected repayment
of the principal.
The next date of interest rate change is either the next date on which the interest rate under an
instrument with floating interest rate may be changed according to the terms and conditions of the
agreement, or the date of the agreed maturity, depending on which of them occurs first. Residual
maturity is the period starting from the date of accounting until the final agreed maturity of the
instrument.
To avoid the negative results in case of interest rates change, the interest rates of the attracted funds
and the provided loans shall be discussed on a meeting of the Assets and Liabilities Committee, in
case the change is needed due to the market conditions.
The loans with floating interest rates are formed by a floating basic interest rate and a margin fixed
under the agreement. The basic interest rate shall be defined by the Group Management as a reply to
the changes in the market conditions of the country.
The enclosed table shows the sensitivity of the net interest income and the equity as at 31 December
2014 upon reasonable possible change of the interest rates, where all the other indicators in the Income
statement remain unchanged.
Increase in
basic point
Sensitivity of the
net interest
income in TBGN
Equity Sensitivity
From 0
to 6
months.
From 6
months
to 1 year
From 1
year to 5
years
More
than 5
years Total
BGN +100 5.288 (17) (259) (494) (490) (1,260)
EUR +100 10.503 - (611) (53) - (664)
USD +100 481 (658) - - (102) (760)
Other +100 134 - - - - -
Decrease in
basic point
Sensitivity of the
net interest
income in TBGN
Equity Sensitivity
From 0
to 6
months.
From 6
months
to 1 year
From 1
year to 5
years
More
than 5
years Total
BGN -100 (5,288) 17 259 494 490 1.260
EUR -100 (10,503) - 611 53 - 664
USD -100 (481) 658 - - 102 760
Other -100 (134) - - - - -
SOCIETE GENERALE EXPRESSBANK AD Announcement under Regulation 575/2013
consolidated base
17
The sensitivity in the Income Statement was calculated based on the net currency effect (result) from
the revaluation of the net currency position upon increase/decrease of the major currencies exchange
rates. The effect of a change in the foreign currency exchange rate is valid upon the assumption that all
of the other parameters remain unchanged. The analysis of the sensitivity in the equity reflects the
change of the fair values of the financial assets disposable for sale upon the above conditions.
XIІI. SECURITIZATION
The Group does not apply securitization.
SOCIETE GENERALE EXPRESSBANK AD Announcement under Regulation 575/2013
consolidated base
18
XІV. ANNOUNCEMENT OF THE ENCUMBERED ASSETS
A-assets form
TBGN
Book value of
encumbered
assets
Fair value of
encumbered assets
Book value of
unencumbered
assets
Fair value of
unencumbered
assets
010 040 060 090
010 Assets of the
reporting
institution
53.887 4,833,363
030 Capital Instruments 639
040 Equities 26.190 430.390
120 Other assets 27.697 4,402,334
Form B - Received collateral
Fair value of a
received
encumbered
collateral or issued
own equities
Fair value of a
received collateral
or issued own
equities, accessible
for encumbering.
010 040
130 Received compensation from the reporting institution 51.716
150 Capital Instruments
160 Equities 51.716
230 Other received collaterals
240 Issued own equities different than own covered bonds or
securities secured by assets.
SOCIETE GENERALE EXPRESSBANK AD Announcement under Regulation 575/2013
consolidated base
19
Form B - Encumbered assets/received collaterals and liabilities related to them
Corresponding liabilities,
conditional liabilities or
borrowed securities.
Assets, received
collaterals and issued
own equities different
than own covered bonds
or securities secured by
assets.
010 030
010 Book value of selected financial
liabilities 38.016 53.887
D - Information on the significance of the encumbering
1. The data provided in forms A-C are on consolidated base as at 31.12.2014.
2. Form A: Row 040, column 010 accounts blocked securities as collateral for achieved deposits
from budget enterprises.
3. Form A: Row 120 column 010 reports loans provided to clients of Societe Generale
Expressbank under programmes of Bulgarian Bank for Development with established on them
pledge in favour of Bulgarian Bank for Development.
4. Form B: Row 160, column 040 accounts received securities under reversed repo deals. Until the
date of the maturity the securities can be used as collaterals for other deals or sold.
5. Form C: Row 010 column 010 reports the attracted deposits from budgetary enterprises and the
received funds under programmes of Bulgarian Bank for Development.
6. Form C: Row 010 column 030 reports the blocked securities as collateral for the attracted deposits
from budgetary enterprises and the loans with established pledge in favour of the Bulgarian Bank
for Development as a collateral for the received funds under programmes of the Bulgarian Bank for
Development.
7. There are no sources of encumbering at consolidation level.
8. According to the signed agreements with the Bulgarian Bank for Development Societe Generale
Expressbank AD establishes pledges in favour of Bulgarian Bank for Development on the loans
provided with funds under programmes of the Bulgarian Bank for Development. Societe Generale
Expressbank blocks securities as collateral of the funds under accounts of the budgetary enterprises
pursuant to the State Budget of the Republic of Bulgaria Act and the Government Debt Act.
9. Changes in the levels of encumbered assets may be due mainly to dynamics in the volume of the
repo deals. The accounting value of the assets with established pledge in favour of Bulgarian Bank
for Development decreases before their repayment. The level of collateralization of attracted
deposits from budgetary enterprises remains stable.
10. Societe Generale Expressbank does not consider that some part of the assets included in row 120,
column 60 would be encumbered in the process of the normal activity of the Bank.
SOCIETE GENERALE EXPRESSBANK AD Announcement under Regulation 575/2013
consolidated base
20
XV. CREDIT RISK MINIMIZATION TECHNIQUES
The Group requests from the Borrowers to provide collaterals eligible with regard to its type, value
and liquidity and corresponds to the risk profile of the Client and the type of the credit deal.
Collaterals can serve as a tool for credit risk minimization and reducing the needed regulatory capital.
The agreements for securing credit deals shall be concluded in the form envisaged by the law for
validity of the collaterals and in case such is not envisaged - in writing.
The Group has adopted rules for evaluating the type of the collateral and its liquidity.
The Group accepts the following types of collaterals:
Mortgage on real property;
Pledge of movable assets and receivables (the pledge may be real and special);
Cash receivables;
Guarantorship and guarantees (corporate, bank or government);
Other collaterals defined by the law.
The Group defines standard criteria for eligibility of the collaterals. Pursuant to these criteria the
collaterals shall be subject to monitoring in the process of credit approval, their legal relatedness shall
be tracked and they shall be subject to regular review and revaluation.
Various rules shall be observed as provision of all of the necessary documents identifying the
collaterals; the amount of the collateral to be sufficient in order to cover the liabilities of the debtor
during the whole term of the loan and last but not least - the collateral should be capable of fast
realization, to be clearly defined, correctly established and accounted as it has direct impact on
minimization of the credit risk for the bank, calculating the concentration in case of risk of the
guarantors.
Highly-liquid collaterals in accordance with the internal rules for managing the credit activity of the
Group are received bank guarantees from foreign banks and received deposits.
In case of collateral in the form of a recognized guarantee, this part of the exposure that is fully
covered by it shall be weighed by the risk weight of the protection guarantor.
All of the loans of corporate clients are 100% secured by guarantees, mortgages or pledges of
equipment or receivables. The collaterals are agreed individually by each corporate client depending
on the financed activity.
Collaterals
The amount and the types of the requested collaterals depend on the assessment of the solvency and
their credit risk profile of the Borrowers. The Group has adopted rules for evaluating the type of the
collateral and its liquidity. The main types of the collaterals are as follows:
Under repo deals - securities or cash funds;
Upon crediting corporate clients - cash funds, securities, mortgage on lands and/or buildings,
special pledge of inventories and/or commercial receivables;
Upon consumer lending - cash funds, mortgage on real property and guarantorship.
If necessary, the Group receives as well guarantees from the parent companies as collateral upon
providing loans to their subsidiaries.
SOCIETE GENERALE EXPRESSBANK AD Announcement under Regulation 575/2013
consolidated base
21
The total amount of the exposures after provisions and adjustments to the value before accounting the
effect of reducing the credit risk and adjusting the off-balance sheet position under conversion ratios as
at 31 December 2014 was the following:
TBGN
Class of exposures
Value of the
balance sheet
exposure
Value of the off-
balance sheet
exposure
Central governments or central banks; 1,016,205
Regional governments or local authorities; 12.360 2.125
Institutions 131.578 13.623
Enterprises 1,720,734 191.118
Retail exposures; 1,037,249 2.109
Exposures secured by real property 479.690 0
Exposures at default 102.111 5.370
Exposures in capital instruments 1.960
Other positions. 178.688
Total 4,680,575 214.345
XVI. REMUNERATIONS POLICY AND PRACTICE
1. Bank's remuneration policy
The remuneration policy in Societe Generale Expressbank AD Group was developed in accordance
with the obligatory requirements and takes into consideration the best practices in this field. The
policy and all of its amendments and updates are proposed and adopted by the Management Board of
the Bank and approved by the Supervisory Board.
The Remuneration Committee of Societe Generale Expressbank AD is an authority supporting the
functions of the Supervisory Board related to assessment and independent review of the remuneration
policy of the Bank in accordance with the regulatory requirements, the recommendations of the
European Commission and the international good practices in the field of the corporate management
and the remuneration policies in the financial field. The membership of the committee is presented by
members of the Supervisory Board and independent members having relevant professional expertise
and functional independence from Societe Generale Expressbank AD who are capable of providing an
independent assessment of the remuneration policy, incl. on its impact on the risk management.
The remuneration policy has been developed in three steps:
remunerations of the employees - fair and motivating remuneration against the assigned
responsibilities and in accordance with the grade of fulfillment of the undertaken obligations;
remuneration to these members of the staff who due to their work obligations can influence on
the risk profile of the Bank and its subsidiaries - risk takers;
remuneration to the members of the Management Board and the other authorities representing
the Bank and its subsidiaries - decision makers.
The remuneration policy has been developed in accordance with the following main principles:
the business strategy of the group Societe Generale Expressbank; prudent risk policy, aims,
values and long-term interests of the Group;
transparency within the organization and suitable way of disclosing the policy beyond it;
combined base between the personal contribution of the employee and the general result of the
company;
SOCIETE GENERALE EXPRESSBANK AD Announcement under Regulation 575/2013
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22
equality - upon structuring the package of incentives no kind of discrimination should be
allowed based on gender, age, race, religion, etc.
According to the system of remunerations they can have constant or variable nature. The wage is a
constant remuneration defined individually for each of the employees considering:
the responsibilities characteristic for the specific position of the employee;
The complexity of the labour functions and qualification in accordance with the knowledge
and skills of the employee and the requirements to his/her position;
The level of pay in the field;
The individual efficiency - the capacity of the employee to fulfill the assigned to him/her
obligations duly and properly, to actively contribute to the continuous improvement of the
work quality;
The elements of the monthly remuneration are:
Basic salary - remuneration for the fulfillment of the assigned functions and responsibilities
inherent to the work position in accordance with the standards for quantity, quality and
duration of the work time. Usually the labour remuneration forms a material part of the whole
package of material incentives;
Extra pay - related to the length of service; night work or overtime or Sunday work or work
during holidays and in other cases stipulated by the legislation. These additional labour
remunerations have actually compensation nature and should not be considered an important
motivating factor.
The bonus forms the floating part of the remuneration. The bonus shall be defined based on the result
of the Group, individual contribution and behaviour. The bonuses are defined on the grounds of two
factors:
- Result of the company:
The result of the company is a combination of the financial result, market shares, reputation
and risk level. The results of SG Group, IBSF and Societe Generale Expressbank Group are
considered;
- Individual contribution:
The individual contribution is related to the achievements. For measuring the individual
contribution specific quality indicators have been introduced as: Achieving the individual
targets for products' realization, observing terms and schedules, characteristic both of the
projects' implementation and fulfillment of the daily functions.
The monthly remuneration shall be paid in cash. With regard to the bonuses, the regulators
recommend that they include a deferred component - financial instruments of the company, tools of
keeping with the system of bonus-malus (a system in which the bonus may be retroactively reduced in
the cases of losses during the following years), etc. Bonuses that are direct expression of the individual
financial result, if any - they should be provided under the condition of providing possibility that they
be refunded, in case it is ascertained that they were deserved as a result of fraudulent activity or were
achieved upon violation of the applicable rules.
A special focus shall be set on the remunerations of the people observing controlling functions or risk
management functions: Current control - credit risk, financial risk, operational risks, etc; regular
control and constant control. The remuneration for these positions is proper and corresponding to the
levels in this sector in order to allow Societe Generale Expressbank AD to attract highly-qualified,
well-experienced professionals and to ensure their independence and loyalty.
SOCIETE GENERALE EXPRESSBANK AD Announcement under Regulation 575/2013
consolidated base
23
The remuneration reflects the personal contribution of the employee and the efficiency of these
functions, as well as the level of achievement of the purposes related to the risk management and
control. The remuneration is related to the complete result of the company and is not directly related to
the results of the business units being subject to control.
In implementation of the requirements of Ordinance No 4 related to the variable part of the
remuneration, as well as the principles of Societe Generale Group Remuneration Policy, specific
categories of employees have been identified, to whom the specific requirements to the variable
remuneration to be applied. For the last year there were no employees, the variable remuneration of
whom to exceed the threshold accepted in Societe Generale Group and applicable as well in Societe
Generale Expressbank AD.
2. Summarized quantitative information for 2014 on the remunerations of the persons according
to art. 450 of Regulation (EU) No 575/2013 and Ordinance No 4 of BNB of 2010 on the
requirements to the remunerations in the banks.
- Paid remunerations for 2014 (in TBGN) by activities:
Types of activities Remuneration
paid in 2014
Investment banking 924
Credit activity 17904
Corporate functions 7732
Independent controlling functions 1444
Other 3834
- The amount of the annual remunerations, differentiated in constant and variable remunerations
and the number of their recipients are:
Constant annual remunerations - TBGN 30,692 1632 employees
Variable annual remunerations - TBGN 2,856 1130 employees
- The amount of the annual remunerations of the persons under art. 2 of Ordinance 4 of BNB
totals TBGN 1,711.
- The amount and the type of the variable remunerations is TBGN 2,856 - cash funds;
- There are no unpaid deferred remunerations;
- There are no deferred remunerations, allocated during the accounting year, being paid and
reduced through adjustments based on the achieved results;
- There are no remunerations upon job appointment;
- The amount of the compensations upon dismissal is TBGN 102, as the highest amount of such
compensation allocated to one specific person was TBGN 12.
- We have no employee to receive remuneration amounting to EUR 1 million or more for one
financial year.
XVІІ. LEVERAGE
Societe Generale Expressbank AD calculates the ratio of leverage upon observing the requirements of
Regulation (EU) No 575/2013; It is expressed in percent and is formed by the value of Tier one capital
correlated to the sum total of the amounts of the exposures under all assets and off-balance sheet
positions that have not been deducted upon defining the value of the Tier one capital.
The leverage ratio shall be calculated as arithmetic mean of the monthly values of the leverage ratio
for a quarter.
SOCIETE GENERALE EXPRESSBANK AD Announcement under Regulation 575/2013
consolidated base
24
As at 31.12.2014 the value of the leverage ratio upon the use of completely adopted definition of one-
tier capital is 6.27%.
The Bank manages the risk of excessive leverage through current monitoring of the leverage ratio,
performing a constant monitoring in order to prevent mismatch between the assets and liabilities and
applying preventive measures against its possible growth due to reducing the tier one capital in case of
possible losses.
SOCIETE GENERALE EXPRESSBANK AD Announcement under Regulation 575/2013
consolidated base
25
APPENDIX 1A
BALANCE SHEET INTENDED FOR REGULATORY PURPOSES
as at 31.12.2014
ASSETS TBGN
Cash and cash balances in central banks and other sight deposits
843,162
Financial tradable assets 178,797
Financial assets disposable for sale. 301,732
Loans and receivables 3,446,809
Investments in subsidiaries, joint ventures and partnerships
6,002
Tangible assets 76,666
Intangible assets 9,787
Deferred tax assets 3,033
Other assets
19,928
Non-current assets and groups of assets for disposing classified as held for sale
1,334
TOTAL ASSETS: 4,887,250
LIABILITIES
Financial liabilities kept for trading 23,977
Financial liabilities assessed by their depreciable value 4,236,893
Provisions 7,195
Tax Liabilities 4,665
Other Liabilities 52,674
TOTAL LIABILITIES: 4,325,404
EQUITY
Capital 33,674
Premium reserves 45,070
Accumulated other comprehensive income 31,984
Undistributed profit 15,213
Other reserves 376,803
Profit or loss concerning the owners of the partner company 58,777
Small participations (non-controlling participations) 324
TOTAL EQUITY 561,846
TOTAL EQUITY and TOTAL LIABILITIES 4,887,250
SOCIETE GENERALE EXPRESSBANK AD Announcement under Regulation 575/2013
consolidated base
26
APPENDIX 1B
Methodology for balance sheet matching Announcing pursuant to art. 2 of the Commission Implementing Regulation (EU) No 1423/2013 of
20.12.2013 as at 31.12.2014
TBGN
Balance sheet elements participating in the calculation of the regulatory capital
Amount in the accounting
statements
Companies not falling within the scope of the
regulatory consolidation
Value for the regulatory
purposes
EQUITY
Subscribed capital 33,674 33,674
Premium reserve 45,070 45,070
Other reserves (incl. undistributed profit from previous years)
449,207 1,568 392,341
Revaluation reserve / Accumulated other comprehensive income
33,420 -1,111 31,984
Total equity 561,371 503069
Position: Amount
Equity due to the Balance sheet of the Group 503069
Intangible assets -9787
Investments in subsidiaries, joint ventures and partnerships -4042
Other transitional adjustments of the basic equity and one tier capital -31783
including:
Unrealized gains and losses (art. 468 and 467) and deductions (art. 469-472 and art. 478 of Regulations 575/2013/ -20880
Additional filters and deductions under art. 36 , 469, 472 and 472 of Regulation 575/2013. -10903
Basic Equity Tier one capital 457457
Tier two capital 457457
Tier two capital 28320
Total capital base 485777
SOCIETE GENERALE EXPRESSBANK AD Announcement under Regulation 575/2013
consolidated base
27
Appendix 1C
Capital instruments’ main features template
Disclosure according to Article 3 in Commission implementing regulation (EU) No 1423/2013
Capital instruments’ main features template (1)
1 Issuer
Societe Generale Expressbank AD
Societe Generale Expressbank AD
2
Unique identifier (eg CUSIP, ISIN or Bloomberg identifier for private
placement ISIN BG1100101051
3 Governing law(s) of the instrument Bulgarian legislation Bulgarian legislation
Regulatory treatment
4 Transitional CRR rules
Common Equity Tier 1 capital T i e r 2
5 Post-transitional CRR rules
Common Equity Tier 1 capital T i e r 2
6 Eligible at solo/(sub-)consolidated/solo
& (sub-)consolidated Solo &consolidated
7 Instrument type (types to be specified by each jurisdiction)
share Tier 2, according to art. 63/Reglement
575/2013
8
Amount recognised in regulatory capital (currency in million, as of
most recent reporting date)
33674
765
9 Nominal amount of instrument 1 BGN 27382
9a Issue price N/A N/A
9b Redemption price
N/A 100% of the instrument's
nominal value
10 Accounting classification Share capital Liabilities -
amortisated value
11 Original date of issuance 13.Jun.93 20.Feb.08
12 Perpeptual or dated Perpeptual dated
13 Original maturity date N/A 7 years
14 Issuer call subjet to prior
supervisory approval N/A N/A
15 Optional call date, contingent call dates, and redemption amount
N/A N/A
16
Subsequent call dates, if applicable
N/A N/A
Coupons / dividends
17 Fixed or floating dividend/coupon Floating dividend Floating
18
Coupon rate and any related index
N/A 3M EURIBOR + 1.2 %
19 Existence of a dividend stopper N/A
20a
Fully discretionary, partially discretionary or mandatory (in
terms of timing
N/A
20b
Fully discretionary, partially discretionary or mandatory (in
terms of amount)
N/A
SOCIETE GENERALE EXPRESSBANK AD Announcement under Regulation 575/2013
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28
21
Existence of step up or other incentive to redeem
N/A
22 Noncumulative or cumulative N/A N/A
23 Convertible or non-convertible N/A N/A
24 If convertible, conversion trigger
(s) N/A N/A
25 If convertible, fully or partially N/A N/A
26 If convertible, conversion rate N/A N/A
27 If convertible, mandatory or
optional conversion N/A N/A
28 If convertible, specifiy instrument
type convertible into N/A N/A
29 If convertible, specifiy issuer of
instrument it converts into N/A N/A
30 Write-down features No No
31 If write-down, write-down trigger
(s)
N/A N/A
32 If write-down, full or partial N/A N/A
33
If write-down, permanent or temporary N/A N/A
34
If temporary write-down,
description of write-up mechanism
N/A N/A
35
Position in subordination hierachy in liquidation (specify instrument
type immediately senior to instrument)
Senior loan Senior loan
36 Non-compliant transitioned
features Не
37 If yes, specifiy non-compliant
features
N/A N/A
(1) 'N/A' inserted if the question
is not applicable
SOCIETE GENERALE EXPRESSBANK AD Announcement under Regulation 575/2013
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29
Appendix 1D
Transitional own funds disclosure template
Disclosure according to Article 5 in Commission implementing regulation (EU) No 1423/2013 31.12.2014
Common Equity Tier 1 capital: instruments and reserves (1)
KBGN
(B) REGULATION (EU)
No 575/2013
ARTICLE REFERENCE
(C)
AMOUNTS SUBJECT TO
PRE-REGULATION (EU) No 575/2013
TREATMENT
OR PRESCRIBED
RESIDUAL AMOUNT OF REGULATIO
N (EU) 575/2013
1 Capital instruments and the related share premium accounts 78 744
26 (1), 27, 28, 29, EBA list 26 (3) N/A
of which: Instrument type 1 N/A EBA list 26 (3) N/A
of which: Instrument type 2 N/A EBA list 26 (3) N/A
of which: Instrument type 3 N/A EBA list 26 (3) N/A
2 Retained earnings 15 213 26 (1) (c) N/A
3
Accumulated other comprehensive
income (and any other reserves) 408 787 26 (1) N/A
3a Funds for general banking risk 0 26 (1) (f) N/A
4
Amount of qualifying items referred to in Article 484 (3) and
the related share premium accounts subject to phase out from CET1 0 486 (2) N/A
Public sector capital injections grandfathered until 1 january 2018 0 483 (2) N/A
5
Minority interests (amount allowed
in consolidated CET1) 325 84, 479, 480 N/A
5a
Independently reviewed interim profits net of any foreseeable
charge or dividend 26 (2) N/A
6
Common Equity Tier 1 (CET1) capital before regulatory adjustments 503 069 N/A
SOCIETE GENERALE EXPRESSBANK AD Announcement under Regulation 575/2013
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30
Common Equity Tier 1 (CET1) capital: regulatory adjustments
7 Additional value adjustments (negative amount) 0 34, 105 N/A
8 Intangible assets (net of related tax liability) (negative amount) -9 787
36 (1) (b), 37, 472 (4) N/A
9 Empty set in the EU 0 N/A
10
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) 0 36 (1) (c), 38, 472 (5) N/A
11
Fair value reserves related to gains or losses on cash flow hedges 0 33 (a) N/A
12
Negative amounts resulting from
the calculation of expected loss amounts 0
36 (1) (d), 40, 159, 472 (6) N/A
13
Any increase in equity that results from securitised assets (negative amount) 0 32 (1) N/A
14
Gains or losses on liabilities valued at fair value resulting from changes in own credit standing 0 33 (1) (b) (c) N/A
15 Defined-benefit pension fund assets (negative amount) 0
36 (1) (e), 41, 472 (7) N/A
16
Direct and indirect holdings by an institution of own CET1 instruments (negative amount) 0 36 (1) (f), 42, 472 (8) N/A
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 (negatvie amount) 0
36 (1) (g), 44, 472 (9) N/A
SOCIETE GENERALE EXPRESSBANK AD Announcement under Regulation 575/2013
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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 10% threshold and net of eligible short positions) (negative amount) 0
36 (1) (h), 43, 45, 46, 49 (2) (3), 79, 472 (10) N/A
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 10% threshold and net of eligible short positions) (negative amount) -4 042
36 (1) (i), 43, 45, 47, 48 (1) (b), 49 (1) to (3), 79, 470, 472 (11) N/A
20 Empty set in the EU 0 N/A
20a
Exposure amount of the following
items which qualify for a RW of 1250%, where the institution opts for the deduction alternative 0 36 (1) (k) N/A
20b
of which: qualifying holdings outside the financial sector
(negative amount) 0 36 (1) (k) (i), 89 to 91 N/A
20c
of which: securitisation positions
(negative amount) 0
36 (1) (k) (ii) 243 (1) (b) 244 (1) (b)
258 N/A
20d
of which: free deliveries (negative
amount) 0
36 (1) (k) (iii), 379
(3) N/A
SOCIETE GENERALE EXPRESSBANK AD Announcement under Regulation 575/2013
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21
Deferred tax assets arising from
temporary difference (amount above 10 % threshold , net of related tax liability where the conditions in Article 38 (3) are met) (negative amount) 0
36 (1) (c), 38, 48 (1) (a), 470, 472 (5) N/A
22 Amount exceeding the 15% threshold (negative amount) 0 48 (1) N/A
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 0
36 (1) (i), 48 (1) (b),
470, 472 (11) N/A
24 Empty set in the EU 0 N/A
25 of which: deferred tax assets arising from temporary difference 0
36 (1) (c), 38, 48 (1) (a), 470, 472 (5) N/A
25a Losses for the current financial year (negative amount) 0 36 (1) (a), 472 (3) N/A
25b Foreseeable tax charges relating to CET1 items (negative amount) 0 36 (1) (l) N/A
26
Regulatory adjustments applied to
Common Equity Tier 1 in respect of amounts subject to pre-CRR treatment 0 N/A
26a
Regulatory adjustments relating to unrealised gains and losses pursuant to Articles 467 and 468 -20880 N/A
26b
Amount to be deducted from or
added to Common Equity Tier 1
capital with regard to additional filters and deductions required pre CRR 0 481 N/A
SOCIETE GENERALE EXPRESSBANK AD Announcement under Regulation 575/2013
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27
Qualifying AT1 deductions that exceeds the AT1 capital of the institution (negative amount) -10 903 36 (1) (j) N/A
28 Total regulatory adjustments to Common Equity Tier 1 (CET1) -45 612 N/A
29 Common Equity Tier 1 (CET1) capital 457 457 N/A
Additional Tier 1 (AT1) capital: instruments
30 Capital instruments and the related share premium accounts 0 51, 52 N/A
31
of which: classified as equity under applicable accounting standards 0 N/A
32
of which: classified as liabilities under applicable accounting standards 0 N/A
33
Amount of qualifying items referred to in Article 484 (4) and the related share premium accounts subject to phase out from AT1 0 486 (3) N/A
Public sector capital injections grandfathered until 1 january 2018 0 483 (3) N/A
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 0 85, 86, 480 N/A
35 of which: instruments issued by subsidiaries subject to phase-out 0 486 (3) N/A
36 Additional Tier 1 (AT1) capital before regulatory adjustments 0 N/A
Additional Tier 1 (AT1) capital: regulatory adjustments
37
Direct and indirect holdings by an
institution of own AT1 instruments (negative amount) 0
52 (1) (b), 56 (a), 57, 475 (2) N/A
SOCIETE GENERALE EXPRESSBANK AD Announcement under Regulation 575/2013
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38
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 (negative amount) 0 56 (b), 58, 475 (3) N/A
39
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) (negative amount) 0
56 (c), 59, 60, 79, 475 (4) N/A
40
Direct, indirect and synthetic holdings of the AT1 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) (negative amount) 0
56 (d), 59, 79, 475 (4) N/A
41
Regulatory adjustments applied to Additional Tier 1 capital in respect of amounts subject to pre-CRR treatment and transitional
treatments subject to phase-out as prescribed in Regulation (EU) No 585/2013 (ie. CRR residual amounts) 10903 N/A
41a
Residual amounts deducted from Additional Tier 1 capital with regard to deduction from Common Equity Tier 1 capital during the transitional period pursuant to article 472 of Regulation (EU) No 575/2013 -7830
472, 473(3)(a), 472 (4), 472 (6), 472 (8) (a), 472 (9), 472 (10) (a), 472 (11) (a) N/A
41b
Residual amounts deducted from Additional Tier 1 capital with regard to deduction from Tier 2 capital during the transitional period pursuant to article 475 of
Regulation (EU) No 575/2013 N/A
477, 477 (3), 477 (4)
(a) N/A
SOCIETE GENERALE EXPRESSBANK AD Announcement under Regulation 575/2013
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41c
Amounts to be deducted from added to Additional Tier 1 capital with regard to additional filters and deductions required pre- CRR -3073 467, 468, 481 N/A
42
Qualifying T2 deductions that exceed the T2 capital of the institution (negative amount) 0 56 (e) N/A
43
Total regulatory adjustments to Additional Tier 1 (AT1) capital 0 N/A
44 Additional Tier 1 (AT1) capital 0 N/A
45 Tier 1 capital (T1 = CET1 + AT1) 457 457 N/A
Tier 2 (T2) capital: instruments and provisions
46 Capital instruments and the related share premium accounts 765 62, 63 N/A
47
Amount of qualifying items referred to in Article 484 (5) and the related share premium accounts subject to phase out from
T2 0 486 (4) N/A
Public sector capital injections grandfathered until 1 january 2018 0 483 (4) N/A
48
Qualifying own funds instruments included in
consolidated T2 capital (including minority interest and AT1 instruments not included in rows 5 or 34) issued by subsidiaries and held by third party 0 87, 88, 480 N/A
49 of which: instruments issued by subsidiaries subject to phase-out 0 486 (4) N/A
50 Credit risk adjustments 0 62 (c) & (d) N/A
51
Tier 2 (T2) capital before regulatory
adjustment 765 N/A
SOCIETE GENERALE EXPRESSBANK AD Announcement under Regulation 575/2013
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Tier 2 (T2) capital: regulatory adjustments
52
Direct and indirect holdings by an
institution of own T2 instruments and subordinated loans (negative amount) 0
63 (b) (i), 66 (a), 67, 477 (2) N/A
53
Holdings of the T2 instruments and subordinated loans of financial sector entities where those entities have reciprocal cross holdings with the
institutions designed to inflate artificially the own funds of the institution (negative amount) 0 66 (b), 68, 477 (3) N/A
54
Direct, indirect and synthetic 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) (negative amount) 0 66 (c), 69, 70, 79, 477 (4) N/A
54a
Of which new holdings not subject to
transitional arrangements 0 N/A
54b
Of which holdings existing befor 1 January 2013 and subject to transitional arrangements 0 N/A
55
Direct, indirect and synthetic holdings 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) (negative amounts) 0 66 (d), 69, 79, 477 (4) N/A
56
Regulatory adjustments applied to tier 2
in respect of amounts subject to pre-CRR treatment and transitional treatments subject to phase out as prescribed in Regulation (EU) No 575/2013 (i.e. CRR residual amounts) N/A N/A
56a
Residual amounts deducted from Tier 2 capital with regard to deduction from Common Equity Tier 1 capital during the
transitional period pursuant to article 472 of Regulation (EU) No 575/2013 0
472, 472(3)(a), 472 (4),
472 (6), 472 (8), 472 (9), 472 (10) (a), 472 (11) (a) N/A
56b
Residual amounts deducted from Tier 2 capital with regard to deduction from Additional Tier 1 capital during the transitional period pursuant to article 475 of Regulation (EU) No 575/2013 0
475, 475 (2) (a), 475 (3), 475 (4) (a) N/A
56c
Amounts to be deducted from or added to Tier 2 capital with regard to additional
filters and deductions required pre- CRR 27555 467, 468, 481 N/A
57
Total regulatory adjustments to Tier 2
(T2) capital 27 555 N/A
58 Tier 2 (T2) capital 28 320 N/A
59 Total capital (TC = T1 + T2) 485 777 N/A
SOCIETE GENERALE EXPRESSBANK AD Announcement under Regulation 575/2013
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59a
Risk weighted assets in respect of amounts subject to pre-CRR treatment and transitional
treatments subject to phase out as prescribed in Regulation (EU) No 575/2013 (i.e. CRR residual amount) N/A N/A
Of which:… items not deducted from CET1 (Regulation (EU) No 575/2013 residual amounts) (items to be
detailed line by line, e.g. Deferred tax assets that rely on future profitability net of related tax
liability, indirect holdings of own CET1, etc) N/A
472, 472 (5), 472 (8)
(b), 472 (10) (b), 472 (11) (b) N/A
Of which:…items not deducted from AT1 items (Regulation (EU) No 575/2013 residual amounts) (items to be detailed line by line, e.g.
Reciprocal cross holdings in T2 instruments, direct holdings of non-significant investments in the capital of other financial sector entities, etc.) N/A
475, 475 (2) (b), 475 (2) ©, 475 (4) (b) N/A
Items not deducted from T2 items (Regulation (EU) No 575/2013 residual amounts) (items to be
detailed line by line, e.g. Indirect holdings of own T2 instruments, indirect holdings of non-significant investments in the capital of other financial sector entities, indirect holdings of significant investments in the capital of other financial
sector entities etc) N/A
477, 477 (2) (b), 477
(2) (c), 477 (4) (b) N/A
60 Total risk-weighted assets 3 565 119 N/A
Capital ratios and buffers
61
Common Equity Tier 1 (as a percentage of total risk exposure amount 12.83% 92 (2) (a), 465 N/A
62 Tier 1 (as a percentage of total risk exposure amount 12.83% 92 (2) (b), 465 N/A
63
Total capital (as a percentage of
total risk exposure amount 13.63% 92 (2) (c) N/A
64
Institution specific buffer requirement (CET1 requirement in accordance with article 92 (1) (a) plus capital conservation
and countercyclical buffer requirements plus a systemic risk buffer, plus systemically important institution buffer expressed as a percentage of total risk exposure amount)
not yet implemented CRD 128, 129, 140 N/A
65
of which: capital conservation
buffer requirement 2.50% N/A
66
of which: countercyclical buffer
requirement
not yet
implemented N/A
67 of which: systemic risk buffer requirement 3% N/A
SOCIETE GENERALE EXPRESSBANK AD Announcement under Regulation 575/2013
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67a
of which: Global Systemically Important Institution (G-SII) or Other Systemically Important Institution (O-SII) buffer
not yet implemented CRD 131 N/A
68
Common Equity Tier 1 available to meet buffers (as a
percentage of risk exposure amount)
not yet implemented CRD 128 N/A
69 [non-relevant in EU regulation] N/A N/A
70 [non-relevant in EU regulation] N/A N/A
71 [non-relevant in EU regulation] N/A N/A
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
36 (1) (h), 45, 46, 472 (10) 56 (c), 59, 60, 475 (4), 66 (c), 69, 70, 477 (4) N/A
73
Direct and indirect holdings 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
36 (1) (i), 45, 48, 470, 472 (11) N/A
74 Empty set in the EU N/A N/A
75
Deferred tax assets arising from temporary difference (amount below 10 % threshold , net of related tax liability where the conditions in Article 38 (3) are met)
36 (1) (c), 38, 48, 470, 472 (5) N/A
Applicable caps on the inclusion of provisions in Tier 2
76
Credit risk adjustments included in T2 in respect of
exposures subject to standardised approach (prior
to the application of the cap) N/A 62 N/A
77
Cap on inclusion of credit risk adjustments in T2 under standardised approach N/A 62 N/A
78
Credit risk adjustments included in T2 in respect of
exposures subject to internal rating-based approach (prior to the application of the cap) 62 N/A
79
Cap for inclusion of credit risk adjustments in T2 under
internal ratings-based
approach 62 N/A
Capital instruments subject to phase-out arrangements (only applicable between 1 Jan 2014 and 1 Jan 2022)
SOCIETE GENERALE EXPRESSBANK AD Announcement under Regulation 575/2013
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80
- Current cap on CET1 instruments subject to phase-out arrangements 484 (3), 486 (2) & (5) N/A
81
- Amount excluded from CET1 due to cap (excess over cap after redemptions and
maturities) 484 (3), 486 (2) & (5) N/A
82
- Current cap on AT1 instruments subject to phase-out arrangements 484 (4), 486 (3) & (5) N/A
83
- Amount excluded from AT1 due to cap (excess over cap after redemptions and maturities) 484 (4), 486 (3) & (5) N/A
84
- Current cap on T2 instruments subject to
phase-out arrangements 484 (5), 486 (4) & (5) N/A
85
- Amount excluded from T2 due to cap (excess over cap after redemptions and maturities) 484 (5), 486 (4) & (5) N/A
(1) 'N/A' inserted if the question is not applicable
SOCIETE GENERALE EXPRESSBANK AD Announcement under Regulation 575/2013
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Appendix 1D
Capital instruments’ main features template
Disclosure according to Article 3 in Commission implementing regulation (EU) No 1423/2013
Capital instruments’ main features template (1)
1 Issuer
Societe Generale Expressbank AD
Societe Generale Expressbank AD
2
Unique identifier (eg CUSIP, ISIN or Bloomberg identifier for private
placement ISIN BG1100101051
3 Governing law(s) of the instrument Bulgarian legislation Bulgarian legislation
Regulatory treatment
4 Transitional CRR rules
Common Equity Tier 1 capital T i e r 2
5 Post-transitional CRR rules
Common Equity Tier 1 capital T i e r 2
6 Eligible at solo/(sub-)consolidated/solo
& (sub-)consolidated Solo &consolidated
7 Instrument type (types to be specified by each jurisdiction)
share Tier 2, according to art. 63/Reglement
575/2013
8
Amount recognised in regulatory capital (currency in million, as of
most recent reporting date)
33674
765
9 Nominal amount of instrument 1 BGN 27382
9a Issue price N/A N/A
9b Redemption price
N/A 100% of the instrument's
nominal value
10 Accounting classification Share capital Liabilities -
amortisated value
11 Original date of issuance 13.Jun.93 20.Feb.08
12 Perpeptual or dated Perpeptual dated
13 Original maturity date N/A 7 years
14
Issuer call subjet to prior supervisory approval
N/A N/A
15 Optional call date, contingent call dates, and redemption amount
N/A N/A
16 Subsequent call dates, if
applicable N/A N/A
Coupons / dividends
17 Fixed or floating dividend/coupon Floating dividend Floating
18
Coupon rate and any related index
N/A 3M EURIBOR + 1.2 %
19 Existence of a dividend stopper N/A
20a
Fully discretionary, partially discretionary or mandatory (in
terms of timing
N/A
20b
Fully discretionary, partially discretionary or mandatory (in
terms of amount)
N/A
SOCIETE GENERALE EXPRESSBANK AD Announcement under Regulation 575/2013
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21
Existence of step up or other incentive to redeem
N/A
22 Noncumulative or cumulative N/A N/A
23 Convertible or non-convertible N/A N/A
24 If convertible, conversion trigger
(s) N/A N/A
25 If convertible, fully or partially N/A N/A
26 If convertible, conversion rate N/A N/A
27 If convertible, mandatory or
optional conversion N/A N/A
28 If convertible, specifiy instrument
type convertible into N/A N/A
29 If convertible, specifiy issuer of
instrument it converts into N/A N/A
30 Write-down features No No
31 If write-down, write-down trigger
(s)
N/A N/A
32 If write-down, full or partial N/A N/A
33
If write-down, permanent or temporary N/A N/A
34
If temporary write-down,
description of write-up mechanism
N/A N/A
35
Position in subordination hierachy in liquidation (specify instrument
type immediately senior to instrument)
Senior loan Senior loan
36 Non-compliant transitioned
features Не
37 If yes, specifiy non-compliant
features
N/A N/A
(1) 'N/A' inserted if the question
is not applicable
SOCIETE GENERALE EXPRESSBANK AD Announcement under Regulation 575/2013
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Appendix No 2
TBGN
Capital requirements - Risk exposures Amount
TOTAL AMOUNT OF RISK EXPOSURES: 3,565,119
AMOUNT OF THE RISK-WEIGHTED EXPOSURES FOR CREDIT RISK, CREDIT RISK FROM THE COUNTER PARTY.
3,204,219
Standardized approach 3,204,219
Central government or central banks; 75,856
Regional governments or local authorities; 8,585
Institutions 38,867
Enterprises 1,876,198
Retail 779,518
Exposures collateralized by mortgages on real properties; 216,942
Exposures at default 108,984
Capital Instruments 1,960
Other positions. 97,310
TOTAL AMOUNT OF THE EXPOSURES AGAINST POSITION, CURRENCY AND COMMODITY RISK
42,550
Amount of the exposures against position, currency and commodity risk in case of standardized approaches.
42,550
Tradable debt instruments 42,550
Capital Instruments 0
Currency 0
Goods 0
TOTAL AMOUNT OF RISK EXPOSURES FOR OPERATIONAL RISK: 318,349
Approach of the basic indicator for operational risk 318,349