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GENERAL MEETING DRAFT - Bankier.pl

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values proving inconsistent with current appraisals.<br />

325<br />

>> Consolidated Financial Statements<br />

Part E – Information on risks and related risk management policies<br />

In light of the still challenging macroeconomic environment, a sound and effective risk management has<br />

highest priority within the Group.<br />

Therefore the Group CRO has im<strong>pl</strong>emented in 2009 a new risk governance model emphasizing this<br />

guiding princi<strong>pl</strong>e and aimed to:<br />

� strengthen the capacity of steering, coordination and control activities of some aggregated risks<br />

(so called “Portfolio Risks”), through dedicated responsibility centres (“Portfolio Risk Managers”)<br />

totally focused and specialized on such risks, from a Group and cross – divisional perspective;<br />

� enhance coherence with the Group business model, ensuring clear specialization and focus –<br />

from a purely transactional perspective - of specific centres of responsibility on risks originated by<br />

the Group “risk taking” functions, at the same time keeping these “centres of responsibility”<br />

(“Transactional Risk Managers”) totally independent from the “risk taking” functions (i.e. Business<br />

units, Treasury, Asset Management, CEE countries).<br />

Consistently with the Risk Management architecture redesign, the set-up, role and rules of the Group<br />

Committees responsible for risk topics have been revised. In order to strengthen the capacity of<br />

independent steering, coordination and control of Group risks, to improve the efficiency and the flexibility<br />

on the risk decision process and to address the interaction between the relevant risk stakeholders three<br />

distinct levels of Risk Committees have been set-up:<br />

� the "Group Risk Committee" being responsible for the Group strategic risk decisions;<br />

� the "Group Portfolio Risks Committees", tasked with addressing, controlling and managing the<br />

portfolio risks;<br />

� the "Group Transactional Committees" that will be in charge of evaluating the single counterparts<br />

/ transactions impacting the overall portfolio risk profile.<br />

In accordance with the roll-out <strong>pl</strong>an for the Advanced Internal Rating Based (A-IRB) criteria,<br />

communicated to Bank of Italy in September 2008, the Group has either im<strong>pl</strong>emented or is in the process<br />

to extend the A-IRB approach to further Subsidiaries of the Group that are yet to adopt this approach.<br />

Regarding the com<strong>pl</strong>iance with the Pillar II of the New Capital Accord (Basel II), a specific capital<br />

adequacy valuation process was developed in 2009, based on existing approaches. It envisages a<br />

general framework as well as a set of specific guidelines aimed at setting out a common approach at<br />

Group level in the areas of capital <strong>pl</strong>anning, the definition of risk appetite and the measurement,<br />

management, control and governance of risks. In addition, synthesis elements concerning risks<br />

measurement were introduced to better support processes such as capital <strong>pl</strong>anning and capital<br />

adequacy. The Group’s risk profile is represented by internal capital that is calculated by aggregating<br />

risks, net of diversification benefits, <strong>pl</strong>us a “cushion” which incorporates model risk and the variability of<br />

the economic cycle. Capital adequacy is evaluated either on the basis of Pillar I metrics or using best<br />

practices, by comparing internal capital to available financial resources (AFR) through their ratio, named<br />

risk-taking capacity. The achievement of capital adequacy also im<strong>pl</strong>ies proper risk management based on<br />

the involvement of senior management by identifying the appropriate decision-making Bodies, properly<br />

assigning duties and responsibilities and reviewing the overall process.

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