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Annual Report 2010 - ProCredit Bank

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Risk Management 25<br />

In <strong>2010</strong> the bank introduced the group-wide New<br />

Risk Approval (NRA) process, which is applied to<br />

all materially new or changed products, services<br />

or business processes. Only after the elimination<br />

of any obstacles or deficiencies revealed by<br />

the NRA process does management give its approval<br />

for the innovation to go ahead.<br />

The bank’s Business Continuity Policy ensures<br />

that the bank can maintain or restore its operations<br />

in a timely manner in the event of a serious<br />

disruption. As well as defining the steps to be<br />

taken to restore normal operations, the bank’s<br />

Business Continuity Plan specifies the procedure<br />

for moving critical operations to temporary locations,<br />

the resources that need to be mobilised<br />

in each type of case and the expected cost of<br />

disruptions in specific areas. It also offers guidance<br />

on avoiding disruption in the first place.<br />

<strong>ProCredit</strong> <strong>Bank</strong> Serbia has a rigorous three-part<br />

Business Continuity Plan that addresses general<br />

emergency situations, power failures and IT system<br />

integrity.<br />

Fraud has been recognised as the most significant<br />

source of operational risk, especially<br />

in the context of lending operations. To offset<br />

this risk, the bank has established clearly defined<br />

procedures and control mechanisms for<br />

loan approval, disbursement and monitoring.<br />

In addition, a dedicated fraud prevention team<br />

has been set up to address all fraud cases and<br />

propose countermeasures. The bank has since<br />

introduced a system for anonymous reporting of<br />

incidents and training courses aimed at raising<br />

fraud awareness.<br />

Anti-Money Laundering<br />

<strong>ProCredit</strong> <strong>Bank</strong> Serbia fully endorses the fight<br />

against money laundering and terrorist financing,<br />

and has implemented the Group Anti-Money<br />

Laundering Policy, which meets the requirements<br />

of Serbian, German and EU legislation. No<br />

customer is accepted and no transaction is executed<br />

unless the bank understands and agrees<br />

to the underlying purpose of the business relationship.<br />

The Group Anti-Money Laundering Department<br />

(Group AML) conducts an annual survey<br />

of all <strong>ProCredit</strong> banks and updates the policy<br />

accordingly. In addition, all <strong>ProCredit</strong> banks submit<br />

quarterly reports on their AML activities to<br />

Group AML.<br />

At <strong>ProCredit</strong> <strong>Bank</strong> Serbia, responsibility for AML<br />

activities is exercised by the Compliance and<br />

AML Unit, employing one compliance officer, two<br />

AML specialists and a unit supervisor. The Unit<br />

prepares daily reports on all cash transactions<br />

exceeding EUR 15,000. In addition, any attempt<br />

to execute a transaction that arouses suspicion<br />

of money laundering, terrorist financing or some<br />

other criminal activity must be reported, regardless<br />

of the amount. Front-office staff receive intensive<br />

training in how to recognise suspicious<br />

transactions. In cases of doubt, Group AML<br />

takes the final decision on how to handle the<br />

suspicious transactions and suspicious customers<br />

reported by the bank. In the near future, the<br />

bank plans to automate its AML screening process:<br />

the AML, Embargo and PEP modules of the<br />

specialist software package Siron are scheduled<br />

to be installed in the first quarter of 2011.<br />

Capital Adequacy<br />

The bank’s capital adequacy is calculated on<br />

a monthly basis and reported both to the management<br />

and to the Group Risk Management<br />

Committee, together with rolling forecasts to<br />

ensure future compliance with capital adequacy<br />

requirements. Strong support from our shareholders<br />

once again enabled the bank to maintain<br />

a comfortable capital cushion. At year-end<br />

<strong>2010</strong> the capital adequacy ratio (tier 1 and tier 2<br />

capital / risk-weighted assets) stood at 14.4%,<br />

well above the group-wide target of 12%. Capital<br />

adequacy according to local regulations was<br />

17.45%, which is also significantly above the locally<br />

required minimum of 12%.<br />

<strong>ProCredit</strong> <strong>Bank</strong>’s ratings, issued by FitchRatings,<br />

remained unchanged in <strong>2010</strong>. For foreign<br />

currency credit, its long-term Issuer Default Rating<br />

(IDR) was BB- and its short-term IDR was B;<br />

for local currency, its long-term and short-term<br />

ratings were BB and B, respectively.

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