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GENERAL MEETING DRAFT - Bankier.pl

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During the first quarter of 2009, com<strong>pl</strong>iant with Pillar II framework, an update on concentration risk has<br />

been performed for Single Name Concentration Limits (so called Bulk Risk Limits) and for Sectorial Limits<br />

(so called Industry Limits).<br />

With reference to restructuring and workout activities, a new specialized Committee – dedicated to the<br />

evaluation of counterparts under restructuring / workout – has been established, while the Group<br />

Transactional Credit Committee focuses on credit underwriting.<br />

With specific focus on the Retail Strategic Business Area and in light of the present economic situation,<br />

actions aiming at strengthening and optimizing processes and IT tools concerning monitoring and work<br />

out activities have been developed with emphasis on the reshaping of the credit framework and on the<br />

“friendly collection”. In order to continue to adequately ensure a support to the economy, two ad hoc<br />

initiatives have been launched for the Italian market, “SOS Impresa Italia” and “Insieme 2009”, together<br />

with the ones coordinated by the Italian Banking Association, supporting Small Business and consumers<br />

respectively.<br />

Within the framework of the “General Group Credit Policy”, special guidelines concerning “Structured<br />

Trade and Export Finance (STEF)”, aiming at guaranteeing a standard approach governing this business<br />

at Group level were developed, as well as specific instructions to be followed for “Commodity Trade<br />

Finance”, “Receivables Finance” and “Export Finance”.<br />

Monitoring and reporting activities for the Group credit risk portfolio were further developed, widening the<br />

consolidated disclosure to the other important risk categories.<br />

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2.1 Organization<br />

The new Group Risk Management framework aims at ensuring the right balance between "risk type" and<br />

"transactional specialization" by adopting a matrix approach. Group portfolios will be clustered by risk type<br />

("credit and cross-border risks", "market risks" and "operational & reputational risks") and will intersect<br />

with transactions grouped on a divisional level (CIB & PB, CEE, Retail, Treasury, Asset Management).<br />

The matrix approach will lead to the set-up of two different responsibility centres on credit risk. On the one<br />

side the "Credit and Cross Border Risks Portfolio Management” department, which oversees and<br />

manages the overall credit and cross-border risk profile of the Group defining all the relevant strategies,<br />

methodologies and limits. On the other side, the "Transactional Risk Managers" will be the responsibility<br />

centres for the credit risks originated by the Group "risk taking" functions.<br />

Besides the Group Portfolio and Transactional Risk Managers, the new Risk Management set-up<br />

comprises the “Strategic Risk Management and Control” department, responsible for, among the others,<br />

the management of Basel II activities (including measurement of internal capital according to Pillar II,<br />

definition of the risk appetite and the "ICAAP" coordination), the Group internal validation of both Pillar I<br />

systems and Pillar II models, as well as centralized risk reporting and risk policies functions for all the<br />

risks at Group level, and a specialized department ("Special Credit"), responsible for coordinating,<br />

addressing, supporting and – with reference to relevant files - managing restructuring and workout<br />

activities.<br />

2009 CONSOLIDATED REPORTS AND ACCOUNTS<br />

328

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