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RAIFFEISENBANK (BULGARIA) EAD

CONSOLIDATED ANNUAL FINANCIAL STATEMENTS

PREPARED IN ACCORDANCE WITH INTERNATIONAL

FINANCIAL REPORTING STANDARDS, AS ADOPTED BY THE EU

WITH INDEPENDENT AUDITOR’S REPORT THEREON

For the year ended 31 December 2016


Contents General information .................................................................................................................................................................. i

1. BASIS OF PREPARATION ................................................................................................................................................. 10

2. SIGNIFICANT ACCOUNTING POLICIES......................................................................................................................... 11

3. FINANCIAL RISK MANAGEMENT ................................................................................................................................... 29

4. USE OF ESTIMATES AND JUDGEMENTS ......................................................................................................................... 62

5. CLASSIFICATION OF FINANCIAL ASSETS AND LIABILITIES .......................................................................................... 67

6. SEGMENT ANALYSIS ........................................................................................................................................................ 68

7. NET INTEREST INCOME .................................................................................................................................................... 70

8. NET FEE AND COMMISSION INCOME .......................................................................................................................... 71

9. NET TRADING RESULT ...................................................................................................................................................... 71

10. NET RESULT FROM DERIVATIVES ................................................................................................................................ 72

11. NET RESULT FROM INVESTMENTS............................................................................................................................... 72

12. ADMINISTRATIVE EXPENSES ...................................................................................................................................... 72

13. OTHER OPERATING EXPENSES .................................................................................................................................. 73

14. NET IMPAIRMENT LOSS ON LOANS AND ADVANCES ........................................................................................... 73

15. TAX................................................................................................................................................................................ 74

16. OTHER COMPREHENSIVE INCOME .......................................................................................................................... 76

17. CASH AND BALANCES WITH THE CENTRAL BANK ................................................................................................. 77

18. TRADING ASSETS ......................................................................................................................................................... 77

19. DERIVATIVES ................................................................................................................................................................ 77

20. LOANS AND ADVANCES TO BANKS ........................................................................................................................ 78

21. LOANS AND ADVANCES TO CUSTOMERS .............................................................................................................. 79

22. INVESTMENT SECURITIES ............................................................................................................................................. 80

23. PROPERTY, PLANT AND EQUIPMENT ........................................................................................................................ 81

24. INTANGIBLE ASSETS .................................................................................................................................................... 82

25. OTHER ASSETS ............................................................................................................................................................. 83

26. DEPOSITS FROM BANKS ............................................................................................................................................. 83

27. DEPOSITS FROM CUSTOMERS ................................................................................................................................... 84

28. BORROWINGS FROM BANKS .................................................................................................................................... 84

29. SUBORDINATED LIABILITIES ........................................................................................................................................ 84

30. OTHER LIABILITIES ........................................................................................................................................................ 85

31. EQUITY .......................................................................................................................................................................... 86

32. COMMITMENTS AND CONTINGENT LIABILITIES ...................................................................................................... 86

33. INVESTMENTS IN ASSOCIATES ................................................................................................................................... 87

34. CASH AND CASH EQUIVALENTS .............................................................................................................................. 87

35. GROUP MEMBERS ...................................................................................................................................................... 88

36. RELATED PARTY TRANSACTIONS .............................................................................................................................. 90

37. SUBSEQUENT EVENTS .................................................................................................................................................. 93

RAIFFEISENBANK

(BULGARIA) EAD

CONSOLIDATED MANAGEMENT REPORT FOR THE YEAR ENDED 31

DECEMBER 2016


General Information

i Translation in English of the official Consolidated Management report issued in Bulgarian.

General information

Establishment of the Bank

Raiffeisenbank (Bulgaria) EAD is the first greenfield foreign investment in the Bulgarian

banking sector made in 1994.

Main shareholder

Raiffeisenbank (Bulgaria) EAD is indirectly a 100% subsidiary of Raiffeisen Bank International

AG, Vienna. With this regard in 2016 there are no acquisition or transfer of own shares.

The capital of Raiffeisenbank (Bulgaria) EAD could be increased upon decision of the sole

shareholder through the means foreseen in the Commerce act:

Issuance of new shares;

Increasing the face value of shares already issued, or

Converting bonds into shares.

The Articles of association of Raiffeisenbank (Bulgaria) EAD do not provide for particular

rights of the Supervisory board and the Board of directors, related with the capital

increase or acquisition of own shares.

Banking License

Raiffeisenbank (Bulgaria) EAD has a full banking license for domestic and overseas

banking and financial operations.

Profile

Raiffeisenbank (Bulgaria) EAD is a universal commercial bank, providing services to large

corporate customers, small and medium-sized enterprises, retail clients, financial

institutions and institutional clients. The Bank also performs bonds and securities trading on

the local and the international money and capital markets, asset management, global

security services, etc.

The Bank’s activity does not harm ecology and environment. As a credit institution the

Bank has not established research and development and innovation activities.

The credit rating of Raiffeisenbank (Bulgaria) EAD assigned by Fitch Ratings is as follows:

• Long Term Issuer Default Rating: BBB-

• Short Term Issuer Default Rating: F3

• Outlook: stable


General information

Translation in English of the official Consolidated Management report issued in Bulgarian. ii

The Bank’s Management

Shareholders

Raiffeisen SEE Region Holding GmbH,

Austria - 100%

Supervisory Board

Chairman: Helmut Breit

SB Members:

Kurt Bruckner

Ferenc Berszan

Herbert Stepic

Management Board

Chairman: Oliver Roegl

Members of the Board: Tzenka Petkova

Ani Angelova

Martin Pytlik

Evelina Miltenova (until 30.06.2016)

Dobromir Dobrev

In 2016, the total amount of remuneration paid by the Bank to members of the Supervisory

board and the Board of directors was BGN 4,009 thousand.

The members of the Supervisory board and of the board of directors do not hold

participating interests in commercial companies as unlimited liability partners and do not

own more than 25 percent of the capital of another company. The Chairman of the

Management Board, Oliver Roegl, sits on the Supervisory Board of Raiffeisen banka a.d.

Beograd.

In the past year, board members or persons associated with them have not entered into

contracts with the Bank which are outside the scope of its ordinary activities or

substantially deviate from market conditions.

There are currently no provisions to give members of the Supervisory and Management

Board rights to acquire shares or bonds in the Bank.

Financial instruments and risk management policies used

The Bank’s activities mainly involve the creation, acquisition and disposition of financial

instruments. As a result of this, the Bank is exposed to credit, liquidity, market and capital

risk. The policies on managing those risks are disclosed in detail in Note 4 to the Bank’s

annual financial statements enclosed thereto.

Events after the date of the annual financial statements

There are no subsequent events that would require either adjustments or additional

disclosures in the annual financial statements.


CONSOLIDATED MANAGEMENT REPORT FOR THE YEAR ENDED 31 DECEMBER 2016

Translation in English of the official Consolidated Management report issued in Bulgarian. iii

Corporate governance statement

Raiffeisenbank (Bulgaria) EAD sees good corporate governance as part of current

business practice, a set of balanced relationships between the Bank’s Managing Bodies,

its sole shareholder and all other stakeholders – employees, clients, partners, regulators

and society as a whole.

In the pursuit of its activities, Raiffeisenbank (Bulgaria) EAD is guided by the principles of

corporate governance recommended to be followed by the National Corporate

Governance Commission.

Along with the aforementioned principles, which are of a recommendatory nature,

Raiffeisenbank (Bulgaria) EAD, as part of the Raiffeisen Group, follows corporate

governance requirements laid down at group level and binding upon the Bank’s

managing bodies and employees, with a Code of Conduct of the RZB Group adopted for

this purpose (information under Article 100n, (8) (1b) of the Public Offering of Securities Act

(POSA)).

Raiffeisenbank (Bulgaria) EAD and the companies of the entire Raiffeisen Group follow the

Code of Conduct, taking into account that the effective application of good corporate

governance practices contributes to reaching higher standards in the Bank’s activities,

maintaining and improving the reputation of the entire Raiffeisen Group, and establishing

transparent relationships with all stakeholders (information under Article 100n, (8) (1b) of

POSA).

Raiffeisenbank (Bulgaria) EAD hereby declares its commitment to:

1. Introduce procedures and principles to which the Bank’s Managing Bodies will adhere

in order to create the conditions necessary to enable shareholders to exercise their rights

in full.

2. Ensure the Bank’s Managing Bodies (Supervisory and Management Board) follow the

principles of transparency, independence and responsibility in accordance with the

Bank’s objectives and strategies (information under Article 100n(8)(5) of POSA) established

in the Policy on diversity in the executive, management and supervisory bodies

(information under Article 100n(8)(6) of POSA).

2.1. The Supervisory Board of Raiffeisenbank (Bulgaria) EAD consists of four (4) members

selected by the Bank’s Sole Shareholder for a fixed term of office of no longer than five (5)

years.

2.2. The Supervisory Board performs its activities in accordance with the By-laws of the

Bank and the Rules of the Supervisory Board of Raiffeisenbank (Bulgaria) EAD.

2.3. The Management Board of Raiffeisenbank (Bulgaria) EAD consists of five (5) members

selected by the Supervisory Board for a fixed term of office of no longer than five (5) years.

2.4. The Management Board performs its activities in accordance with the By-laws of the

Bank and the Rules of the Management Board of Raiffeisenbank (Bulgaria) EAD.



Translation in English of the official Consolidated Management report issued in Bulgarian. iv

2.5. In the performance of their tasks and responsibilities, the Supervisory and

Management Boards are guided by applicable law, the Bank’s By-laws, the internal rules

and procedures of the Bank and Raiffeisen Group, and the principles of integrity and

competence.

2.6. The Management Board acts independently on behalf of the Bank and makes

decisions on all matters, unless the relevant activities are within the remit of the Sole

Shareholder or Supervisory Board. In the performance of its duties, the Management

Board:

manages and represents the Bank;

manages the Bank’s ongoing activities;

sets the Bank’s objectives, adopts plans, programs and strategies for the Bank’s

activities;

adopts the Bank’s organizational and management structure.

2.7. The Management Board must obtain prior approval from the Supervisory Board in the

following cases:

determination of the common company policy, including the initiation or

discontinuation of types of business;

annual budget of the Bank and (when required) of its consolidated companies

prepared in accordance with the International Financial Reporting Standards

(including investment budget) and

annual plan for financing of the Bank from institutional investors and deviations

therefrom [Financing from institutional investors covers international and local bond

issues, including bond issues (covered and uncovered) for non-professional

investors, bilateral loans, syndicated loans, unsubordinated and subordinated

transactions, as well as deposits from banks and other institutions with a maturity of

more than one year in foreign or local currency]

the organizational structure relating to the Management Board defines the powers

of each member of the Management Board (Organizational Structure); any

functional changes in the Organizational Structure of the Management Board and

Management Board level – minus 1, as well as the creation of new portfolios and

the closure of old portfolios at the Management Board and Management Board

level – minus 1;

all matters to be presented to the Sole Shareholder for their final resolution;

acquisition, incorporation, disposition or liquidation of companies or business units of

any kind, or parts thereof, whether the investment results from normal business

activities or the restructuring of loans, and the acquisition, registration, disposition or

liquidation of holdings, and participating interest in or the creation of joint ventures

with other companies of any type, directly or indirectly through related companies

and any capital-related measures (e.g. capital increase or decrease), in respect of

the capital of any subsidiary;

acquisition, investment and disposal in any way of investment schemes (trusts, funds

or similar), provided they are not made for the purpose of sale (trading portfolio

assets) or within the remit of an existing coordinating risk management body at

group level;

Decisions relating to company restructuring (merger or division) of any subsidiary or

other related company that directly affects the Bank in respect of the disposal of its

assets or relates to the takeover of the assets or the assumption of liabilities of the



Translation in English of the official Consolidated Management report issued in Bulgarian. v

relevant subsidiary or other related company, as well as any restructuring measures

involving related companies which are credit institutions;

the conclusion or termination of consortium agreements and agreements tied to

votes with affiliates in any subsidiary or other related company or in respect of

options or similar agreements that may affect the value or interchangeability of the

participating interest of the Bank in any subsidiary or other related company, and

the conclusion of such contracts with the counterparty if it is part of the same group

of companies is not subject to approval by the Supervisory Board;

participation in or termination of profit or loss sharing agreements, group taxation

arrangements or similar arrangements by the Bank;

creation and closure of branches and offices, if not provided for in the annual

budget (but in any event, if the branch or office has been opened abroad);

acquisition and disposal of real property, as well as the creation of mortgages and

encumbrances on real property owned by the Bank or any of its subsidiaries

(including commercial real property included in the annual business plan and

exceeding the EUR 500,000 limit or having an area of more than 350 m2), and any

agreements relating to the above, as well as any additional increase in expenditure

exceeding the approved budget by at least 5% of the budgeted costs or EUR

50,000;

rental contracts or leases of immovable property to be let by the Bank for a period

longer than five years and a total contract value of more than EUR 500,000, and

any investments related to such contracts;

internal rules on the powers of the Management Board concerning decisions to

grant loans and set country credit limits (Loan Committee Rules), governing which

decisions require the approval of the Loan Committee and/or the approval of the

Supervisory Board;

approval to grant loans, including credit lines and the assumption of contingent

liabilities to one creditor (or to one of more creditors from one economic entity),

and decisions on country credit limits requiring the approval of the Supervisory

Board pursuant to the Loan Committee Rules approved in accordance with

paragraph (n) of these Rules;

internal rules on the powers of the Management Board concerning problem

exposures (Rules of Procedures of the Problem Loan Committee) laying down

which decisions require the approval of the Problem Loan Committee and/or the

approval of the Supervisory Board;

approval for the restructuring, allocation or release of provisions and the write-off of

problem exposures to a single Borrower (or to one or more borrowers from a group

of economically related parties) that requires the approval of the Supervisory

Board, in accordance with the Rules of Procedure of the Problem Loan Committee;

loan grant or increase, including internal credit lines and contingent liabilities of

members of the Bank’s Supervisory or Management Board;

approval of the loan grant or increase procedure, including internal credit lines and

contingent liabilities to Bank employees;

introduction and modification of any pension, compensation or social insurance

plan or other social insurance scheme for the benefit of a member of the

Management Board, employees or their families, or other persons having a

contractual relationship with the Bank upon or after retirement, or termination of

the appointment at or contractual relationship with the Bank, as well as the

introduction and modification of any shareholder equity plan (e.g. securities

options) or profit distribution plan that relates to a member of the Management

Board, employees or their families, or other persons having a contractual



Translation in English of the official Consolidated Management report issued in Bulgarian. vi

relationship with the Bank, and the introduction of or substantial changes in

compensation schemes (general principles, principles and structure of basic pay,

salary scales, bonus principles and structure, and incentive plans) and other benefit

schemes, but in any case, only schemes where annual expenditure exceeds 10% of

the Bank's total payroll cost, provided that approval from the Supervisory Board is

not required to do otherwise;

appointment of governing body members/managers, supervisory body members

(supervisory or advisory/oversight board) of any subsidiary or other affiliate, except

in cases where third parties or entities outside the group are entitled to appoint the

respective persons to perform their duties by virtue of their right to nominate or as a

result of other voting rights to the relevant bodies;

assumption of the duties of supervisory board members or directors in non-affiliated

companies by Management Board members or Bank employees; and

contract with a Supervisory Board member under which that Supervisory Board

member undertakes to provide services that are beyond his/her responsibilities as a

Supervisory Board member, to the Bank or any of its subsidiaries for payment of a

value higher than a purely symbolic remuneration for the service; this also applies to

contracts with undertakings in which the Supervisory Board member has a

significant economic interest. The discharge of duties at the Raiffeisen Bank

International AG Group in Vienna or the mere performance of responsibilities by a

Supervisory Board member as a management body member or manager does not

imply the treatment of the relevant undertaking as an “undertaking in which the

Supervisory Board member has a significant economic interest”, unless the

circumstances give rise to the assumption that the Supervisory Board member

derives personal benefit from that undertaking.

The Supervisory Board is entitled to decide what other matters require its approval.

2.8. Management Board members are guided in their work by the generally accepted

principles of integrity, professionalism and confidentiality, and respect the ethical rules

adopted by the Bank.

2.9. Supervisory and Management Board member follow, in their work, the principle of

avoidance and prevention of real or potential conflicts of interest, in accordance with the

Policy adopted by the Bank on the avoidance and disclosure of conflicts of interest. Any

conflict of interest should be disclosed to the other Management Board members and the

Supervisory Board. Management Board members should inform the Supervisory Board

whether, directly, indirectly or on behalf of third parties, they have a material interest in

any transactions or issues that have a direct impact on the Bank. All transactions between

the Bank and any of its affiliates and any Management Board member or person or

company closely associated with the Management Board are carried out at market

conditions. Transactions and their terms and conditions must be approved in advance by

the Supervisory Board, except for commonly executed bank transactions.

2.10. Raiffeisenbank (Bulgaria) EAD declares that it follows a diversity policy in the selection

and evaluation of the members of the Bank's executive, management and supervisory

bodies, and believes that this policy contributes to ensuring a reliable management and

oversight system based on the principles of transparency and independence.

2.11. Main criteria and principles of the diversity policy in the selection and evaluation of

members of the executive, management and supervisory bodies of Raiffeisenbank

(Bulgaria) EAD (information under Article 100n (8) (6) of POSA):



Translation in English of the official Consolidated Management report issued in Bulgarian. vii

Only legally capable individuals may be governing body members. Persons who

are over 68 years of age may not be appointed as Management Board members

and their term of office may not be renewed. Persons who have reached the age

of 75 may not be appointed as Supervisory Board members and their term of office

may not be renewed. All Management Board or Supervisory Board members should

meet the requirements of Regulation No 20 of Bulgarian National Bank (BNB) of 28

April 2009 on the issue of approvals to members of the Management Board (Board

of Directors) and the Supervisory Board of a credit institution and requirements in

relation to the performance of their duties. No other limitations on age, gender,

nationality or education shall be imposed on Management and Supervisory Board

members;

Good reputation, professional experience and managerial skills, given the

complexity and specifics of the activities conducted by the Bank;

Ability to strike a balance between experience, professionalism and knowledge of

the activities, as well as independence and objectivity in the expression of opinions

and decision-making;

Management and Supervisory Board members may be re-elected without any

restrictions.

3. Internal Control System (information under Article 100n, (8) (3) of POSA)

Raiffeisenbank (Bulgaria) EAD has implemented an Internal Control System that both helps

the Bank achieve its objectives and:

prevent losses,

ensure reliable financial accountability, and

ensure compliance with the relevant statutory and internal regulations.

The Bank’s internal control system is used to achieve its strategic objectives, increase

process efficiency and reduce risk.

The internal control system is based on the internal regulations applicable to the Raiffeisen

Group, Bulgarian law and the internal regulations of Raiffeisenbank (Bulgaria) EAD

(policies, procedures, instructions, etc.), which govern all significant and strategically

important topics.

Participants in the internal control system who carry out control activities at different levels

are the Bank’s management and structural units’ heads. They are responsible for carrying

out the Management Board’s decisions, including implementing strategies and policies,

and creating an effective Internal Control System. The management team creates more

specific internal control policies and procedures.

4. Risk Management System (information under Article 100n, (8) (3) of POSA)

4.1. As a result of its activities, Raiffeisenbank (Bulgaria) EAD is exposed to the following

risks: credit risk, market and liquidity risk, operational risk.

А. Credit risk

The Bank has incorporated and observes organizational and operational independence

of the risk control functions from business lines that it monitors and controls. The

organizational structure and risk control and management processes are coordinated by

clearly defined responsibilities, the Bank's current policies and rules, and the job

descriptions of each unit. The Bank's risk strategy is adhered to and subject to approval by

the Management Board and the Supervisory Board. A system of control processes has



Translation in English of the official Consolidated Management report issued in Bulgarian. viii

been put in place to identify measure, monitor and manage the risks documented in the

risk management policies.

The Bank follows rules and procedures approved by the Managing and Supervisory Board

on the internal control of the overall lending and credit risk management process. They

are prepared in accordance with the requirements of the Credit Institutions Act, BNB

regulations and the rules of the Raiffeisen Group.

Credit policy, specialized credit management bodies and credit risk assessment are

regulated in the lending rules. Apart from these rules, there are rules on the delegation of

approval powers to departments under the Executive Director in charge of Risk and

Finance Management by the Bank’s Credit Committee. All executives and employees

involved in the lending process are required to follow the approved credit policy and

lending process.

The Bank's credit policy is determined by its Supervisory Board, which provides

interpretations and clarifications regarding its application. It is based on the principles of

profitability, liquidity and collateral.

The Bank's credit policy is implemented by the Management Board, Executive Directors,

Credit Committee, Internal Audit, Risk Management, Corporate Banking, Corporate

Segment – Middle Market, Retail Banking and Micro & SME Client Lending at the Bank's

Head Office in Sofia.

The credit policy is implemented through the regulation and management of credit

parameters, market niches, rules and procedures, including in the form of documents

adopted by the Bank’s Management Board.

The Bank has collective management bodies for the lending and risk exposure regulation

process: Credit Committee and Problem Loan Committee.

The Credit Committee is a specialized body responsible for managing the lending process.

Its main function is to conduct the Bank’s credit policy, as determined by the

Management Board, and to make decisions on credit transactions that exceed the

powers of the departments under the Executive Director in charge of Risk and Finance

Management. The Loan Committee operates at the Bank's Head Office and is directly

subordinate to the Management Board.

Risk exposures are assessed and the amount of necessary individual impairment is

determined by a specialized collective body at the Bank: Problem Loan Committee. Its

activity is carried out in compliance with the requirements of the Credit Institutions Act and

the Bank’s internal regulations. The Problem Loan Committee prepares an assessment of

risk exposures, both on the basis of the International Financial Reporting Standards and the

internal directives of the Raiffeisen Group.

The Bank operates an Early Warning Signals System, whose role is to ensure the timely

collection of data on indicators and their correct analysis and assignment of client risk

statuses.



Translation in English of the official Consolidated Management report issued in Bulgarian. ix

B. Market and liquidity risk

The Bank has rules and procedures in place to identify the various types of market and

liquidity risk, which have been developed in accordance with the Group's directives and

the Bank’s established practice. Those include the main rules and procedures for

identifying, measuring and managing market and liquidity risk. They also define the

responsibilities of the Market and Liquidity Risk Management Department, which is

responsible for managing the Bank’s market and liquidity risk, as well as its relationship with

the RBI Group.

The Asset and Liability Management Committee is responsible for the overall

management of the Bank's balance sheet structure. In particular, it manages the Bank’s

short-term and structural liquidity, the interest rates applicable to the Bank, the internal

pricing parameters and their effect on net interest income, and the value of assets and

liabilities. A more detailed description of the competences and organizational structure of the

committee is set out in the Rules of Procedure of the Asset and Liability Management Committee

and in the relevant internal documents regulating market risk management.

The activity of the Asset and Liability Management Committee is governed by rules drawn up in

accordance with the Credit Institutions Act. Those rules set out the objectives of the Asset and

Liability Management Committee, its delegated decision-making powers and the responsibilities of

its members and the Committee as a whole.

The main objectives of the Asset and Liability Management Committee are:

manage the Bank’s balance sheet structure;

manage the Bank’s exposure to interest and exchange rate differences;

manage the Bank’s liquidity;

Facilitate the exchange of information between the Bank’s departments with a view to

optimizing risk and liquidity management.

In addition to the objectives set out above, the Asset and Liability Management

Committee:

analyses and discusses the current market development and condition of the Bank’s

competitors;

examines any legislative changes and their impact on the Bank’s balance sheet

structure and liquidity;

examines legal provisions and their impact on the Bank’s open position; Minutes of the Committee’s meetings must be provided to RBI Vienna.

C. Operational risk (OR)

Operational risk is the risk of loss resulting from inadequate or poorly functioning internal

processes, people and systems, or from external events. The definition includes legal risk

but excludes strategic and reputational risk. Legal risk is the risk of loss resulting from non-

compliance with legal provisions, established ethical standards and contractual

obligations. Model risk (the risk that the models used in the Bank’s overall risk management

process or their application are not suited to achieving the objectives set) is fully covered

in the sub-categories of OR.

Raiffeisenbank (Bulgaria) EAD and its subsidiaries, as part of RBI, consider operational risk a

separate risk category and adhere to the Group’s policies, rules, procedures and

principles, as laid down in the Sound Practices for the Management and Supervision of

Operational Risk published by the Basel Committee on Banking Supervision, because they

view those principles as fundamental to managing operational risk. They aim to implement

into the Bank a properly formulated and coherent methodology for the detection,

assessment, monitoring, control and reduction of the operational risks faced by the



Translation in English of the official Consolidated Management report issued in Bulgarian. x

Group’s companies in the course of their daily business activities.

The key steps in operational risk control taken by the Bank are risk identification, risk

assessment and monitoring, risk reporting and mitigation. The Bank manages operational

risk by registering and analyzing operational events, making risk assessments, monitoring

risk indicators and performing scenario analyses, implementing contingency plans,

optimizing processes and activities, ensuring adequate insurance coverage, outsourcing,

etc.

Operational risk assessments of the Bank and its subsidiaries are reviewed on a regular

basis. The assessments are carried out once a year, at a maximum interval (including

approval from the Operational Risk Committee of RBBG and its subsidiaries) of 15 months.

The assessments are made before the start of the scenario analysis preparation process

because the results of the assessments constitute key data about what scenarios should

be analyzed. In the event of extraordinary circumstances (e.g. new business environment,

new activities, etc.), the assessment is carried out immediately. The results of the study are

published on the internal (intranet) webpage on RBI operational risk control.

Early warning indicators have been put in place, which are metric or statistical data

providing information on the Group's risk exposure and are used to monitor specific

exposure areas associated with operational risks. The Bank uses a flexible approach where

indicators are selected from the responsible management function (top-down) and ORM

(bottom-up), which allows the control of the respective risk exposures. Early warning

indicators are coordinated with RBI.

The indicators aim to anticipate an increasing or decreasing operational risk. Each

business department/unit of the Bank and its subsidiaries determines the operational risk

indicators for its activities by monitoring changes in their values over time. They are

determined for risks rated as high (rating of 5 or higher).

The Bank operates an Operational Risk Management Committee. The Committee is a

specialised internal body, part of the management of Raiffeisenbank (Bulgaria) EAD in the

field of operational risk management and control. The Bank’s Management Board, as the

highest operational risk management body, determines the composition and members of

the Operational Risk Management Committee, and delegates duties and responsibilities.

4.2. Regulatory Compliance

The Bank has a local Compliance unit. The Compliance Department has been set up

according to the Group’s Compliance Requirements, which are organized in accordance

with the requirements of the Basel Committee on Banking Supervision titled “Guidelines on

the Control of Compliance in Banks”.

The Department monitors compliance with current laws, regulations and rules, as well as

national and international standards (Best Practice) and the group and internal rules of

the Raiffeisen Group. The Compliance Department reviews the development of internal

guidelines, procedures and organizational rules to ensure that the Bank, as well as its

governing bodies and employees are familiar with the rules, work in accordance with

them, and that the Bank will not take advantage of unlawful business practices.

The aim of the ongoing work on regulatory compliance is to advise and assist the Bank

and its employees on all measures that may be useful to prevent the violation of rules and

even criminal activity. This also includes the management of conflicts of interest between

the Bank, employees and customers. Basically, all those measures are necessary to

protect the Bank’s reputation and good name. If there is reasonable suspicion based on

facts and information that a customer or transactions have an unlawful purpose or involve

the Bank in a high risk to its reputation, the Compliance Unit clearly applies the necessary

safeguards to the Bank which, in extreme cases, may even include reporting to the



Translation in English of the official Consolidated Management report issued in Bulgarian. xi

authorities.

5. Information on the existence of takeover/merger bids in 2016 (information under

Article 100n (8) (4) of POSA – respectively under Article 10, paragraph 1, letters (c), (d), (f),

(h) and (i) of Directive 2004/25/EC of the European Parliament and of the Council of 21

April 2004 on takeover bids)

As of 31/12/2016, Raiffeisenbank (Bulgaria) EAD has not received any takeover and/or

merger bids.

5.1. Information under Article 10(1) (c) of Directive 2004/25/EC on takeover bids: significant

direct and indirect shareholdings (including indirect shareholdings through pyramid

structures and cross-shareholdings) within the meaning of Article 85 of

Directive 2001/34/EC.

The company is part of the Austrian Raiffeisen Group. The Bank's sole shareholder is

Raiffeisen SEE Region Holding GmbH, Austria. The ultimate controlling entity is Raiffeisen

Bank International, Austria.

Raiffeisenbank (Bulgaria) EAD is the sole shareholder of the following companies:

- RAIFFEISEN ASSET MANAGEMENT (BULGARIA) EAD;

- RAIFFEISEN SERVICE EOOD;

- RAIFFEISEN INSURANCE BROKER EOOD;

- RAIFFEISEN LEASING BULGARIA EOOD;

The Bank holds shares amounting to 20% of the capital of Cash Service Company AD.

5.2. Information under Article 10(1) (d) of Directive 2004/25/EC on takeover bids: holders

of any securities with special control rights and a description of those rights.

The capital of Raiffeisenbank (Bulgaria) EAD is divided into 603,447,952 (six hundred and

three million four hundred and forty seven thousand nine hundred and fifty two) shares

with a par value of BGN 1 (one) each. The shares of the Company are registered,

dematerialized and indivisible, and there are no separate classes of shares.

Each share gives the right to one vote in the General Meeting of Shareholders, the right to

a dividend and a proportional liquidation dividend of the Bank's assets.

The Bank’s shares may only be dematerialized.

5.3. Information under Article 10(1) (f) of Directive 2004/25/EC on takeover bids: any

restrictions on voting rights, such as limitations of the voting rights of holders of a given

percentage or number of votes, deadlines for exercising voting rights, or systems whereby,

with the company’s cooperation, the financial rights attaching to securities are separated

from the holding of securities.

The Bank’s current By-laws does not provide for such restrictions.

5.4. Information under Article 10(1) (h) of Directive 2004/25/EC on takeover bids: rules

governing the appointment and replacement of board members and the amendment of

the articles of association.

Raiffeisenbank (Bulgaria) EAD has a two-tier management system, including a Supervisory

Board and a Management Board.

The Rules of Procedure of the Supervisory Board are laid down in the By-laws of

Raiffeisenbank (Bulgaria) EAD and the Rules of the Supervisory Board of Raiffeisenbank

(Bulgaria) EAD.



Translation in English of the official Consolidated Management report issued in Bulgarian. xii

The Rules of Procedure of the Management Board are laid down in the By-laws of

Raiffeisenbank (Bulgaria) EAD and the Rules of the Management Board of Raiffeisenbank

(Bulgaria) EAD.

The Bank’s Supervisory Board and Management Board are governed by current law, the

Bank’s statutes and procedures, and the standards of integrity and competence in the

performance of its duties and responsibilities.

According to Article 5(7) of the By-laws of Raiffeisenbank (Bulgaria) EAD, the sole

shareholder has exclusive competence to make decisions on the following matters:

Amendments to the By-laws;

Capital increase and decrease;

Bond issue authorizations;

Selection and dismissal of Supervisory Board members;

Approval of annual financial statements and profit distribution, as well as

acceptance of the Supervisory Board and Management Board report;

Remuneration of Supervisory Board members;

Selection of a specialized auditing company to verify and certify the annual

financial statements;

Company transformation and/or dissolution;

Selection and dismissal of the Specialized Internal Audit Service manager.

The functions and powers of the Supervisory Board are set out in Article 6 of the Bank’s By-

laws and in the Rules of the Supervisory Board of Raiffeisenbank (Bulgaria) EAD and the

Rules of the Management Board of Raiffeisenbank (Bulgaria) EAD. In addition to the other

competencies mentioned in Article 6 of the Charter of the Bank, the Supervisory Board:

Selects and dismisses Management Board members;

Adopts rules of procedure of the Bank’s Supervisory and Management Board;

Approves predetermined actions and deals of the Management Board;

Detailed information on the rules governing the appointment or replacement of

Supervisory or Management Board members is given in item 2 of this Statement and,

respectively, in the By-laws of Raiffeisenbank (Bulgaria) EAD and the Rules of Procedure of

the Supervisory Board and the Management Board of Raiffeisenbank (Bulgaria) EAD.

5.5. Information under Article 10(1) (i) of Directive 2004/25/EC on takeover bids: powers of

board members and in particular the power to issue or buy back shares.

The capital of Raiffeisenbank (Bulgaria) EAD may be increased by decision of the Sole

Shareholder by the methods provided in the Commerce Act:

Issue of new shares;

Increase of the par value of shares already issued, or

Conversion of bonds into shares.

The By-laws of Raiffeisenbank (Bulgaria) EAD does not provide for special powers of the

Supervisory or Management Board to increase the Bank's capital or buy back shares.

6. Stakeholders

6.1. Raiffeisenbank (Bulgaria) EAD believes that effective interaction with stakeholders has

a direct impact on corporate governance. With this in mind, the Bank identifies who are

the stakeholders involved in the conduct of the Bank's business on the basis of their



Translation in English of the official Consolidated Management report issued in Bulgarian. xiii

degree and spheres of influence, role and attitude towards its sustainable development,

direct impacts which in turn can affect its activities, including sole owner/shareholders,

regulatory and other authorities of state and local government, clients, employees, public

groups and others.

6.2. Raiffeisenbank (Bulgaria) EAD, recognizing the public significance of its activities,

adheres to the principle of publicity of the information on its activities and strives to build

and maintain sustainable, constructive relations with regulatory and other authorities of

state and local government. The Bank conducts its activities in strict compliance with the

laws and other legal acts of the Republic of Bulgaria and the European Union. The Bank's

relations with state and local government authorities are based on the principles of

responsibility, good faith, professionalism, partnership, mutual trust, as well as respect and

fulfilment of its obligations.

Raiffeisenbank (Bulgaria) EAD publishes the RZB Group Code of Conduct and the this

Corporate Governance Statement on the Bank's website (https://www.rbb.bg/bg) in

compliance with Article 100n, paragraph 7 and 8 of the Public Offering of Securities Act, in

conjunction with Article 40, paragraph 1 and 2 of the Accountancy Act. This Statement is

also enclosed with the Annual Report of Raiffeisenbank (Bulgaria) EAD.

This Corporate Governance Statement forms an integral part of the 2016 Annual Financial

Statements of Raiffeisenbank (Bulgaria) EAD.

Group companies

This consolidated report covers the activities of the Bank and its subsidiaries and associates

(hereinafter referred to as the Group) in 2016. As of 31 December 2016, the Bank holds the

following investments in subsidiaries and associates:

- Subsidiaries

Subsidiaries are companies controlled by the Bank. Control is the power to manage an entity's financial and operating policies so as to derive benefits as a result of its activities.

The income and expenses of the subsidiary are included in the consolidated financial statements from the date of acquisition to the date on which the Bank ceases to control the subsidiary.

Intra-group balances, transactions, income and expenses arising from transactions between the Group's companies are fully eliminated in the preparation of consolidated financial statements. Gains and losses arising from intragroup transactions that are recognized in the assets, such as loans and receivables, are eliminated altogether.

The subsidiaries controlled by the Bank as of 31 December 2016 are as follows:

Raiffeisen Leasing Bulgaria EOOD – 100% participating interest

Raiffeisen Leasing Bulgaria OOD was founded in 2004, with Raiffeisenbank (Bulgaria) EAD

(24.5%) and Raiffeisen Leasing International GmbH (75.5%) as partners. In 2016, the Bank

acquired full ownership of Raiffeisen Leasing OOD by buying all shares of Raiffeisen

Leasing International GmbH. After the share purchase, the legal status of the company

changed to Raiffeisen Leasing Bulgaria EOOD.



Translation in English of the official Consolidated Management report issued in Bulgarian. xiv

Raiffeisen Leasing Bulgaria EOOD has an active presence on the Bulgarian leasing market.

The main products offered to its clients are leasing of new and used vehicles, construction

and agricultural machinery, light and heavy goods vehicle, trailers and forklifts, machinery

and equipment, as well as real property leasing.

As of 31 December 2016, Raiffeisen Leasing Bulgaria OOD reached a market share of

9.02% on a leasing portfolio basis (Bulgarian National Bank statistics). The total volume of

the leasing market as of 31 December 2016 amounted to BGN 3,314 million and the assets

of Raiffeisen Leasing Bulgaria OOD reached BGN 313 million. The registered capital of the

company amounted to BGN 5,900 thousand.

Raiffeisen Service EOOD – 100% participating interest

Raiffeisen Service EOOD is registered in the Commercial Register with a capital of BGN

4,220 thousand. The company’s scope of activity includes real property management,

financial and accounting consultancy, legal advice and accounting services, valuation of

movable and immovable property, financial assets and enterprises, electronic data

processing and information analysis, information services, rental of safes, leasing. As of 31

December 2016, the net assets of the company amounted to BGN 5,112 thousand.

Raiffeisen Asset Management (Bulgaria) EAD – 100% participating interest

Raiffeisen Asset Management (Bulgaria) EAD was licensed in 2005 by the Financial

Supervision Commission to conduct activities under Article 202, paragraph 1, items 1, 2

and 3 of the Public Offering of Securities Act (POSA), namely management of the

activities of collective investment schemes (CIS) and of closed-end investment

companies, as well as activities under Article 202 paragraph 2 of POSА namely

management of individual portfolios, at its own discretion, without special orders of the

client, and provision of advice on investing in securities. As of 31 December 2016, the

registered capital of the company amounts to BGN 250 thousand and its net assets

amount to BGN 863 thousand.

Raiffeisen Insurance Broker EOOD – 100% participating interest

Raiffeisen Insurance Broker EOOD is a company founded in 2006, 100% owned by

Raiffeisenbank (Bulgaria) EAD. The Company was registered in the Register of Insurance

Brokers on 30 March 2006 by Decision No 250-3B of the Financial Supervision Commission.

The activity of the company is mediation in the conclusion of insurance contracts

between the Broker's clients and insurance companies.

Raiffeisen Insurance Broker EOOD analyses and studies the insurance market, offers

insurance products tailored to the clients' individual needs, administers the insurance

contracts and provides assistance upon the occurrence of insurance events.

The clients of Raiffeisen Insurance Broker EOOD are the borrowers of Raiffeisenbank

(Bulgaria) EAD, the lessees of Raiffeisen Leasing Bulgaria OOD, as well as clients outside

the Raiffeisen Group. As of 31 December 2016, the registered capital of the company

amounts to BGN 5 thousand and its net assets amount to BGN 5,927 thousand.



Translation in English of the official Consolidated Management report issued in Bulgarian. xv

Raiffeisen Real estate EOOD – 100% participating interest

In 2016, the Bank decided to discontinue the company's operations through liquidation and Raiffeisen Real estate EOOD was stricken from the Commercial Register.

- Associates

An associate is an enterprise in which the Bank exercises significant influence but does not control its financial and operating policies. Investments in associates are accounted for in the Bank’s consolidated financial statements using the equity method. According to the equity method, the investment is initially recorded at cost price and the carrying amount is increased or decreased to recognize the Bank's share of the entity's profits or losses after the acquisition date. The Bank's share of the associate's profit or loss is recognized in profit or loss of the Group. Income received through allocation from the associate reduces the carrying amount of the investment. A recalculation of the carrying amount may also be required following a change in the percentage of the Bank in the associate due to changes in the equity of the entity that have not been reflected in its profits or losses. Such changes may also occur as a result of the revaluation of property, plant and equipment, exchange rate differences from foreign exchange transactions. The Group's share in these changes is directly reflected in its equity.

Cash Service Company AD – 20% participating interest

In 2009, the Bank acquired shares worth BGN 2,500 thousand in the Cash Service

Company, which constitutes 20% of the Company's registered capital. In 2016, indications

of impairment of the investment were identified and the Bank recognized a loss of BGN

1,200 thousand.

Correspondent Relations

Raiffeisenbank (Bulgaria) EAD has established correspondent banking relations with over

1100 banks world-wide and maintains accounts in major currencies with first-class foreign

banks.

Branch network

As at the end of 2016 the network of Raiffeisenbank (Bulgaria) EAD totaled 136 branches.

Bulgarian Economy in 2016

Economic Growth

In 2016, real GDP grew by 3.4% YoY, a pace 0.2pp below the 2015 figure (3.6% YoY). On

the demand side, the economic growth in 2016 was once again a result of strong external

and feeble domestic demand. External demand was driven by the weak euro and the

favorable conjunction in the international markets for the export of Bulgarian products

and services. Thus, in 2016, the substantial upswing in export of goods was combined with

a record-breaking growth of the demand for tourism services in Bulgaria. Against this

backdrop, the low prices of oil, which represents a substantial part of Bulgarian import, led

to a relatively slower expansion of total import. As a consequence, net export contributed

more significantly to the GDP growth during the year. On the other hand, domestic



Translation in English of the official Consolidated Management report issued in Bulgarian. xvi

demand, primarily household consumption, was stimulated by low interest rates on

deposits and loans in addition to increasing wages. However, the stagnant investment

activity in the economy retained domestic demand. In particular, shrinking public and

sluggish foreign direct investment along with the initial phase of the new program period

for EU funds absorption drove investments to a lower level compared to 2015. The

elections-related political uncertainty in the country in H2 2016 was yet another contributor

to the restrained sentiment of businesses for private investments in the economy.

In regard to production, industry increased output by 2.7% in 2016 after an upturn of 2.9%

in the year before. The upturn recorded in 2016 was brought about primarily by the

manufacturing industry, which expanded production by 5.0% compared to the previous

year. The mining industry also raised output by 2.6% YoY, while the production of

electricity, heat and gas recorded a drop of 2.0% YoY. For the entire year, construction

shrank by 10.1% in comparison to 2015, when a growth of 2.4% was observed. The decline

in 2016 resulted from a contraction in both civil and buildings construction.

Labor Market

The unemployment rate followed descending trend in 2016, settling at 6.7% at the end of

the year (annual average of 7.6%). This was 1.2pp below the unemployment rate at the

end of year 2015. Nevertheless, the employment rate also marked a downturn of 0.5pp

amounting to 49.2%. The positive fact of slumping unemployment corresponded to the

real GDP growth. On this background, the average monthly wage during the year rose by

BGN 68 to BGN 950. Although the average monthly wage in the public sector remained

higher (BGN 979) compared to the private sector (BGN 941), the average wage in the

latter stepped up at a faster pace by BGN 72 YoY, while the increase in the public sector

was of BGN 56 YoY.

Inflation

After 2014 and 2015, year 2016 was yet again marked by deflation. In 2016, the average

annual deflation increased all the more to 0.8% (0.1% for 2015), while on a December-to-

December basis modest inflation of 0.1% (-0.4% for 2015) was registered. Contributors to

this slight inflation were the higher prices of food products and beverages, alcohol and

tobacco, restaurants and hotels. The lower prices of communications, clothing and

footwear, furnishings and equipment held, however, inflation on its nearly flat level.

Fiscal Sector

The gross budget accumulated revenues of close to BGN 40.0 bn in 2016, reaching a level

BGN 1.7 bn higher compared to 2015. Meanwhile, total spending, including the installment

made by Bulgaria to the EU budget, went down to BGN 32.5 bn or BGN 2.2 bn below their

level in the year before. As a result of this dynamics, a surplus of nearly BGN 1.5 bn (1.6% of

GDP) was recorded in 2016 against a deficit of BGN 2.5 bn at the end of the previous year.



Translation in English of the official Consolidated Management report issued in Bulgarian. xvii

The total value of tax revenues amounted to BGN 26.9 bn in 2016, which presented an

increase of BGN 2.0 bn compared to 2015. The revenues from grants (mainly through EU

programs) recorded, however, a decline of BGN 739.1 mn. On the expenditures side,

social expenses registered the most significant rise of BGN 558.9 mn YoY, while capital

expenses recorded the most substantial contraction of BGN 3.0 bn, which complied with

the sluggish dynamics of investment within the GDP in 2016.

Public Debt

At the end of 2016, public debt reached BGN 26.9 bn which stood for 29.4% of GDP,

marking an increase of BGN 2.1 bn compared to the previous year. Nevertheless, public

debt remained among the lowest levels in the EU. The increase in sovereign indebtedness

was due to the issued government debt of EUR 2.0 bn in the international markets in

March 2016. The EUR 2.0 bn represented the second transaction after the issuance of EUR

3.1 bn in 2015 within the mid-term debt program for EUR 8 bn adopted by the Parliament

in 2015.

Balance of Payments

In 2016, the current account remained on positive territory comprising a total of EUR 1.8

bn, substantially above the total accumulated at the end of 2015 (EUR 172.4 mn). In terms

of its components, the trade balance was expectedly negative at EUR -1.8 bn, but

compensated by the positive services balance of EUR 3.4 bn. Primary income totaled BGN

-1.3 bn, being offset by secondary income, which amounted to BGN 1.6 bn. During the

year, both the capital account and the financial account registered positive balances of

EUR 1.1 bn and EUR 3.1 bn, respectively.

Foreign Direct Investment

In 2016, net foreign direct investment in the country registered a considerable decline of

EUR 1.0 bn YoY to only EUR 0.7 bn at the year-end. A leading investor for 2016 was

Luxembourg with net direct investment of EUR 135.6 mn, followed by the Netherlands with

EUR 128.1mn and the UK with EUR 118.1 mn. The slowdown of the foreign direct investment

flow in 2016 was caused by the uncertain political situation in the region, as well as the

continuing postponement of actual structural reforms, including the judicial and

administrative systems, education, and the energy sector. The electoral political situation

during H2 also resulted in uncertainty on the foreign investors’ side, despite low direct

taxes, membership in the EU, stable finical sector and sovereign ratings, as well as the

pegged to the euro BGN.



Translation in English of the official Consolidated Management report issued in Bulgarian. xviii

Selected

macroeconomic

indicators 2013 2014 2015 2016

Change

2016/2015

Nominal GDP (EUR bn) 42.0 42.8 45.3 47.3 4.6%

Real GDP growth (%) 0.9% 1.3% 3.6% 3.4% (0.2) bp

GDP per capita (EUR) 5784.3 5937.3 6330.3 6620.8 3.9%

Unemployment rate

(annual average, %) 12.9% 11.4% 9.2% 7.6% (1.6) bp

Inflation (end-of-year, %) (1.6%) (0.9%) (0.4%) 0.1% 0.5 bp

Inflation (annual average,

%) 0.9% (1.4%) (0.1%) (0.8%) (0.7) bp

Current account (% of

GDP) 1.3% 0.1% 0.4% 3.8% 3.5 bp

Trade balance (EUR bn) (2.9) (2.7) (1.9) (1.8) (5.3%)

Foreign direct investment

(net, EUR bn) 1.4 1.2 1.7 0.7 (58.8)%

FDI/Current account

balance (%) 258.3% 3306.2% 981.9% 37.7% (944.2) bp

FX reserves (EUR bn) 14.4 16.5 20.3 23.9 17.7%

Source: NSI, BNB,

RBI/Raiffeisen RESEARCH

The Bulgarian banking sector in 2016

Overview

During 2016, the Bulgarian banking sector showed sound overall results, confirmed by the

Asset Quality Review (AQR) carried out in the past year. It was part from the 18-month Plan

on reforms of BNB, which apart from the AQR and stress tests also included the

implementation of strict regulations and reforms of the Regulator, which contributed to the

stability of the banking sector. The Bank system recorded slightly increasing credit activity

despite banks’ cautious lending policy while at the same time the share of non-performing

loans’ in gross loans was subdued. The sustainable deposit growth, mainly from residents,

contributed to the good capitalization and high liquidity of the sector.

Bulgarian banks continued to carry out daily activities making an effort to enhance the

banking sector efficiency in an environment of decreasing interest margins, market

volatility and internal and external political uncertainty.

As of end 2016 the total number of banks decreased to 27 (22 licensed banks and 5

branches of foreign banks) with the finalization of deal for the acquisition of Alpha Bank

Bulgarian Branch by Eurobank Bulgaria EFG. In end-2016 local credit institutions’ share was

to 23.5 per cent, compared to 23.6 per cent in end-2015. More than 96 per cent of the

sector’s total assets were controlled by private entities, while 76.5 per cent of the system

was owned by foreign financial institutions, mainly European banking groups.

The banking systems’ total assets grew given the sustainable growth of the funds attracted

from households, thus as of end 2016 the balance sheet assets reached BGN 92.1 billion,

increasing by 5.2 per cent year-on-year (2015: BGN 87.5 billion).



Translation in English of the official Consolidated Management report issued in Bulgarian. xix

For the year 2016, the banks’ loan portfolio grew by 0.64 per cent to BGN 54.5 billion,

representing approximately 60 per cent of total assets. The sustainable economic activity

supported the growth of lending to the non-government sector which was able to

overcome the negative tendency from 2015. Thus resulted in a 0.23 per cent year-on-year

growth (BGN 83.01 mn) of the banks’ corporate loan portfolio to nearly BGN 36 bn. Retail

loans rose by 1.44 per cent YoY to BGN 18.6 bn due to the improving purchasing power of

the population.

Households’ high propensity to save remained a decisive factor for the deposit base

growth, moving up by 7.9 per cent year-on-year to BGN 74.1 billion as of end 2016. Positive

tendency was observed both in the retail segment (plus 6.3 per cent YoY, up to BGN 47.2

billion) and in corporate segment (plus 8.3 per cent YoY, up to BGN 26.9 billion).

Financial indicators in the banking sector improved significantly, as the overall profit for

2016 recovered near to the highest levels prior to the global crisis. Profitability recorded a

40.5 per cent increase compared to the previous year, reaching BGN 1.3 billion mainly

due to decreased provision expenses and some one-off effects. However the net profit of

the sector was negatively affected by lower income from interest.

Over the year 2016 the share of non-performing exposure in the banks’ loan portfolios

recorded a decrease. Thus, as of end-2016 their gross amount reached BGN 9.96 billion

with is by BGN 1.1 billion less than in end-2015. The improvement reflected the significant

balance sheet clean-up efforts of banks and reforms and institutional development of the

regulator.

The liquidity ratio, showing the ability of banks to repay their debts, further improved to

38.24 per cent from 36.71 per cent in 2015. Meanwhile, the sustainable growth of deposits

from households affected positively the banks’ financing structure and their liquidity. In

end of 2016 profitability indicators – Return on Assets (ROA: 1.41 per cent) and Return on

Equity (ROE: 9.05 per cent) - remained relatively unchanged on a yearly basis (2015 - ROA:

1.05%; ROE: 8.11%) due to the banking sector significantly higher financial result and the

rise in total assets.

During 2016 the impetus to market consolidation in the sector was preserved and will

remain as one of the challenges which the banking sector should overcome in 2017 as

well as the implementation of the measures prescribed by the BNB after the AQR. Another

point which would require commitment will be the preparation for the implementation of

IFRS9, which is expected to be introduced in the beginning of 2018. In 2018 an additional

buffer, applicable to the total risk exposure amount for other systemically important

institutions.

1. Raiffeisenbank (Bulgaria) EAD 2016 key figures for 2016

“Total assets”

In BGN ‘000 2016 2015 2014 2013 2012

Total assets 6,323,964 6,459,550 5,981,352 5,959,680 6,171,818 Source: Audited separate financial statements of Raiffeisenbank (Bulgaria) EAD

The decrease of total assets in 2016 is mainly due to repayment of loans received from

foreign financial institutions.



Translation in English of the official Consolidated Management report issued in Bulgarian. xx

“Loans and advances to customers”

In BGN ‘000 2016 2015 2014 2013 2012

Loans and advances

to customers 4,030,438 3,834,128 3,912,631 4,650,190 4,998,604

Source: Audited separate financial statements of Raiffeisenbank (Bulgaria) EAD

The increase in gross loans and advances to customers is driven by higher new volumes in

all customer segments.

In 2015 the Bank has written off from its balance sheet against loan loss provisions

exposures classified as “loss” in the amount of BGN 50 mn.

“Deposits from customers”

In BGN ‘000 2016 2015 2014 2013 2012

Deposits from

customers 4,748,602 4,759,901 4,235,399 4,174,110 4,367,639


In 2016 the customer deposit base remains stable on the back of decreasing funds in non-

retail segment, compensated by increase in retail deposits.

“Equity”

In BGN ‘000 2016 2015 2014 2013 2012

Equity 910,497 910,327 909,630 863,053 908,985 Source: Audited separate financial statements of Raiffeisenbank (Bulgaria) EAD

The equity includes also the net profit for the year. In 2016, the Bank paid out dividend to

the sole shareholder in the amount of BGN 123 mn.

“Net profit”

In BGN ‘000 2016 2015 2014 2013 2012

Net profit 132,641 61,615 46,553 (43,814) 4,667 Source: Audited separate financial statements of Raiffeisenbank (Bulgaria) EAD

The increase in net profit compared to 2015 is driven by the significantly lower impairment

loss on loans and advances.

“Return on assets before tax”

In % 2016 2015 2014 2013 2012

Return on assets before

tax 2.3% 1.1% 0.8% -0.8% 0.1% Source: Audited separate financial statements of Raiffeisenbank (Bulgaria) EAD

“Return on equity before tax”

In % 2016 2015 2014 2013 2012

Return on equity before tax 17.4% 7.9% 5.9% -5.7% 0.5%




Translation in English of the official Consolidated Management report issued in Bulgarian. xxi

2. Human resources

As of the end of 2016 the staff of Raiffeisenbank (Bulgaria) EAD totaled 2736 employees,

50% of which were employed in the branch network. 82% of the employees are university

graduates while the average age is 38 years.

In 2016 the main focus in human resources management was the improvement of

employee engagement, performance and leadership development. Further automation

of core HR processes was provided which leads to more efficient process management,

paper-less and faster communication with stakeholders, ability to produce variety of

reports and will allow monitoring of key HR KPIs.

In 2016 one of the main HR priorities was the Employer branding project. The aim of the

project is to strengthen our image as an employer of choice and be able to attract more

and better candidates, and also promote the bank as good employer internally.

Another very important and successful HR project was Branch Management Academy –

structured leadership and professional skills development program for Branch managers

and Microcenter Leaders.

New internal and external professional and soft skills trainings were offered to the whole

staff – not only in Sofia, but also in the other big cities in Bulgaria.

The results of the second Engagement survey conducted in 2016 showed significant

improvement in all areas especially in dimensions as: Confidence in Senior Management,

Respect & Recognition, Training; Authority and Empowerment. Significant increase was

measured also in Employee Engagement and Enablement indexes. The results were

discussed with the managers and an action plan for further improvement was approved.

Further efforts were invested in new HR approaches as Onboarding process and

mentorship programs, coaching workshops and consultations, 360-degree feedback for

managers, structured career paths for different positions, Intranet communication. Further

investments in work-life balance programs, sport and teambuilding events were made in

2016. RBBG participated in various HR international programs as International young

potential program, etc.

Internal Customer Satisfaction Survey was performed for the third year in a row where a

significant improvement of the Internal Satisfaction Index was measured. Judging by the

employees' feedback the survey was perceived very well and significant improvement of

the communication and cooperation within the entire organization is now visible.

3. Operations

The implemented Lean and BPMS methodology in the processing of local and foreign

currency payments continues to positively impact the efficiency and automation level,

cost optimization, as well as the establishment of better cooperation with internal

customers.

Customer payments in foreign currency marked an increase of 11% in incoming payments

and 3% in outgoing and interbank payments. The share of electronic payments reached

85% during 2016.

Customers’ local currency payments (outgoing and interbank) increased by 9%

compared to previous year. The share of electronic local currency payments also

increased and reached 86%. The Bank increased to 9% its share in payments processed

through the local payments system BISERA.



Translation in English of the official Consolidated Management report issued in Bulgarian. xxii

The Bank constantly improves the possibilities offered to customers for ordering local

currency outgoing and interbank payments without and with EUR/BGN FX conversion,

aiming at 24/7 payments service. The Bank already offers electronic foreign currency

payments in XML format.

During 2016 the Bank continued offering trade finance consultancy to corporate

customers, which contributed to establishing long-term customer relationship and high

confidence level. Number of trade finance transactions remained stable with a 57%

increase in issued documentary letters of credit, leading to a 5% increase in total

documentary transactions processed in 2016 compared to 2015.

4. Information technology

With regard to information technology, in 2016 the Bank continued to focus with priority on

the IT transformation program, aiming at covering the business requirement towards

information systems and optimizing the entire IT architecture. Within the program a

detailed roadmap was developed for implementing the IT solution on integrated

customer, product and pricing information and providing customers with enhanced

access to the Bank’s products and services. A provider was elected for the two main IT

solutions related to automation of the work at the front office. In cooperation with the

lead provider elected for the IT transformation program, the Bank already started analysis

and design of the solution for providing product and pricing information. Within the scope

of the transformation program was completed the implementation of the Customer

information file.

As part of the IT transformation program is also the unification and optimization of the

Bank’s reporting systems, one of which is already in production and will be the basis for

future IFRS 9 compliance. An upgrade was completed of the Data warehouse, which is

the main data source for the Bank’s reporting. During the past year the Bank continued to

work on automation of Risk reporting, as well as on the project for managing the data

architecture.

Several business and regulatory projects were finalized in 2016, like implementation of

SEPA credit transfer in XML format according to EU regulations.

In 2016 some changes in the organizational structure of the Bank’s IT division were

undertaken, aiming at improving the services and the cooperation quality with internal

and external customers, as well as achieving business goals and realization of projects

from the Bank’s project portfolio.

The IT architecture roadmap was updated and the main version of the data architecture

was enhanced.

Main focus in 2016 was the improvement of the systems’ productivity, security and stability.

Upgrades of main systems were completed, including the documents storing system Omni,

the business process automation system IBM BPM, the server platform of the Bank’s core

banking system, etc. As a result a significant increase was achieved in the IT systems’

processing time, stability and accessibility, which enabled the increase in customer

servicing time during working and non-working days.

In 2016 were also improved and renewed some of the main internal IT services, like the

corporate telephony. A new version of Cisco call manager was implemented with

enhanced functionalities, as well as a new numeration plan was introduced.

The Bank’s electronic channels were improved during the past year and the security level

was significantly increased through implementing a fraud prevention system and a system

for combat attacks against the accessibility of the Bank’s electronic channels.



Translation in English of the official Consolidated Management report issued in Bulgarian. xxiii

5. Corporate banking

In 2016 Raiffeisenbank (Bulgaria) EAD was focused on the continuous support to its

corporate clients, adding 2.8 per cent more new companies to its large customer base.

The bank has a well-diversified customer portfolio comprising leading representatives from

all growing and export oriented sectors of the economy: agro business, manufacturing,

pharmacy, IT, Telecommunications, etc. Raiffeisenbank (Bulgaria) EAD is a reliable partner

for many multinational companies and participates in several syndicated loans.

As a universal bank, Raiffeisenbank (Bulgaria) EAD offers and constantly improves its range

of banking products including lending, import and export factoring, cash management,

documentary operations, deposits, foreign exchange, derivatives, etc. to small, medium

and large companies. The Bank further develops its image of supplier of innovative

services, offering large scope of digital solutions via its Online and Mobile banking, FX

Exchange Web based platform and innovative online applications for bank guarantees

and letters of credit.

Raiffeisenbank (Bulgaria) EAD is one of the major partners of national and supranational

financial institutions, including the National Guarantee Fund and the European Investment

Fund (with which is currently working under three guarantee line programs – COSME,

InnovFin and SME Initiative), thus being a sustainable mediator between the EU programs

and the Bulgarian entrepreneurs and procuring the improvement of the competitiveness

of the Bulgarian economy.

Raiffeisenbank (Bulgaria) EAD invests significantly in modernization of the IT infrastructure

and systems in order to become fully compatible with the new trends in the customer’s

expectations and behavior. In addition, the Bank has introduced LEAN internal processes,

leading to additional efficiency.

The Voice of the Customer survey enables the Bank to receive regular feedback from its

customers. It is conducted regularly with both lending and non-lending clients in order for

the Bank to be on the pulse of their requirements and to constantly keep improving.

As of 31 December 2016, Raiffeisenbank (Bulgaria) EAD was the fifth largest lender to legal

entities with a market share of 6.82 per cent. The Bank is ranked third in terms of attracted

funds from legal entities with a market share of 7.53 per cent.

6. Micro Business

In 2016, Raiffeisenbank (Bulgaria) EAD further strengthened its leading position in the Micro

segment, servicing a growing base of more than 65 800 customers. The Bank added new

attractive services to its broad lending and non-lending product portfolios for micro

companies and business owners, and further improved its specialized personal customer

approach.

8 new Micro Business Centers were established in 2016, increasing their total number in the

country to 20. Within each one of them, clients can benefit from full financial consulting,

clear and flexible products and services.

The focus of activities in 2016 was on:

- increasing customer satisfaction by providing extensive and competent service,

constant improvement of service quality, development of customer-tailored products;



Translation in English of the official Consolidated Management report issued in Bulgarian. xxiv

- providing micro companies with access to local and EU guarantee programs and

credit lines by maintaining strong partnership with European Investment Fund and National

Guarantee Fund. In 2016, 4 new guarantee agreements were signed – COSME, SME

Initiative and InnovFin agreements were signed with EIF, and PRSR 2 agreement was

signed with NGF;

- further expanding the Bank’s presence in the agricultural sector through actively

financing the needs of agricultural producers;

- providing modern and innovative banking services, upgrading online banking and

mobile banking platform, ensuring a quick and convenient 24/7 access. Raiffeisenbank

was the first bank in Bulgaria to introduce a public Viber chat for its customers;

- conducting attractive CRM and promotional campaigns, focused on clients in the

segment and improved presence in alternative channels;

- facilitating the direct interaction and exchange of information with micro customers. By

holding 6 regional business forums and more than 60 business breakfasts throughout the

country, the bank shared information on the topic of new programming period, as well as

the latest opportunities for financing micro business development.

The strong emphasis on personnel development continued to contribute for the more

efficient performance of the segment.

7. Retail Banking

In 2016 Raiffeisenbank (Bulgaria) EAD continued its strategy for sustainable growth aiming

to deliver excellent customer journey and further enhancement of digital banking

channels. The Bank focuses on strengthening the primary relationship with customers in

daily banking, developing modern transactional and lending products.

Raiffeisenbank’s customer base of individual clients is more than 567,000. By the end of

2016, the retail assets reached BGN 1,592 bn representing a market share of 9.12%. The

total attracted funds from private individuals reached BGN 2,721 bn with 5.77% market

share. The number of primary customers exceeded 247,600 and their penetration reached

44% from active customer base.

The Bank is ranked in Top 5 banks in consumer lending for new volume with market share

of 9.7%. New unsecured product with fixed interest rate up to 7 years was introduced on

the market together with online application in the website to facilitate the customer

during the loan consultancy process.

In terms of Housing lending the Bank strengthened its positions and grew by 55% YoY in

new volume. The Bank offers tailor-made approach to satisfy customer needs as well as

expert mortgage consultancy service in the newly established mortgage zones. The Bank

offers transparent and flexible mortgage products with option for floating and fixed

interest rate for 5 years as well as special conditions for refinancing.

In line with the growing digital habits of the customers, the Bank continue to enlarge the

range of innovative communication channels and introduce Viber public chat being the

first bank in Bulgaria to offer such service and free of charge stickers. BOT Chat was

introduced as an unique way of communication between the bank and the customers.



Translation in English of the official Consolidated Management report issued in Bulgarian. xxv

The users of Rаiffeisenbank’s on-line banking continued to grow and as of year-end

exceed 358,000. The share of electronic payments is steadily increasing and reached 87%

at the end of 2016. 50% growth has been registered in the electronic payments via mobile

banking. The downloads of the mobile application have increased by 52% compared to

2015 due to the new improved interface of the application. New functionalities were

enhanced - online payments processing in real time for transactions in local currency.

The number of both domestic and international sale transactions performed by cards

increases by 12% YoY on the back of various initiatives to stimulate the activity of

cardholders. POS network consists of more than 9,300 and the ATM over 600. As of the

end of 2016 the total number of debit and credit cards issued by Raiffeisenbank (Bulgaria)

EAD exceed 480,000. The Bank enhanced its infrastructure for card payments, marking an

increase of over 30% of card transactions on POS of the Bank. Meanwhile, continue to

execute the migration of cards and terminals to new card processing platform in order to

provide to customers innovative functionalities and modern services such as contactless

payments, attractive loyalty programme, 3D secure, etc.

During 2016 Raiffeisenbank (Bulgaria) EAD continued to offer the highest service level for

affluent customers, via Premium and Top Premium Banking service. Enhanced

functionalities of Premium Direct service for remote chat with customers were

implemented in order to provide more convenient consultations for daily banking.

Bancassurance business marked a growth of over 29% in 2016 impacted by the increasing

consumer awareness as well as attractive and innovative insurance coverage.

Endowment and Daily allowance stand-alone insurances were preferred by a number of

customers due to the unique features and coverage as well as the fast and simple

procedure and the possible tax preferences. New insurance package was introduced for

mortgage loans with improved coverage and monthly installments.

8. Sales and Distribution Channels

Raiffeisenbank (Bulgaria) EAD has a nationwide branch distribution network with 136

branches as of the end of 2016, located in more than 60 cities in the country. The Bank

continues to invest in the footprint in order to be more flexible and convenient for its

customers. In 2016, aiming to further improve the network coverage, the Bank opened

and relocated several newly established branches and also renovated many of the

branches to ensure flexible servicing and excellent customer experience. In the last years

the Bank imposed a new model of comprehensive service by its multiskilling staff – in all

branches the customers can be consulted and serviced for cash and non-cash

transactions from one specialist and in 45 branches categorized as Flexi offices can be

furthermore serviced and consulted by the same specialist for lending products. Especially

for the micro and small business companies (annual turnover up to 2 million BGN),

Raiffeisenbank continues to invest in specialized Business centers and currently in 20

Business centers the small businesses companies and freelancers get access to all-round

financial consultancy, clear and business-tailored products and services, financing to

continue business development, as well as individual solutions for their personal finance.

For the private individuals in 2016 Raiffeisenbank (Bulgaria) EAD established eight

specialized Mortgage zones located in biggest cities – Sofia, Plovdiv, Varna and Bourgas.

In the specialized Business centers and Mortgage zones responsible for the service and

consulting are teams of highly qualified specialists, who are engaged with the customer

and provide financial solutions. As the meeting customer expectations for quality, service,

and convenience is of greatest importance, 19 branches work with extended working

time during the weekdays, with selected ones operating during the weekends as well.



Translation in English of the official Consolidated Management report issued in Bulgarian. xxvi

Raiffeisenbank (Bulgaria) EAD continues to develop its Agent network with direct sales

agents and external partners. For more than 12 years direct sales agents in 5 big cities, also

known as Mobile bankers, visit the customers and consult them absolutely free of charge

about the main retail products for private individuals, e.g. consumer loans, debit and

credit bank cards, packages. Mobile bankers save customers’ time and efforts by visiting

them at time and place convenient to them, and help them to prepare the necessary

documents in order to apply for the needed bank service. The external partners’ network

with some 450 partners in more than 45 cities as of the end of 2016 is also important

alternative channel and great contributor to business volumes in retail banking segments.

Raiffeisenbank (Bulgaria) has its own Call Center “Raiffeisen Direct” which is an alternative

channel for 24/7 client servicing, facilitating both existing and potential customers in their

day-to-day communication with the Bank. The Call Center handles a wide variety of

customer enquiries and consults customers about bank products through various remote

communication channels – Phone, E-mail, Voicemail, Chat, and Skype. The professional

Call Center agents actively conduct outbound x-sell, loyalty and customer satisfaction

programs and initiatives to existing and prospect customers. Premium Direct provides

personal remote advisory and transactional services for the Premium clients of the Bank.

Reflecting the trends for digitization Raiffeisenbank (Bulgaria) enhances its electronic

channels for transactional services and further develops its web site, internet and mobile

banking as sales channels. During the year lead generation for lending products have

been launched, enabling existing and potential customers to get professional consultation

via the phone for an appropriate loan product.

Raiffeisenbank (Bulgaria) EAD is recognized as a Bank with clear customer focus and

customer experience policy. Raiffeisenbank strives not only to provide excellent service

quality according to internal corporate standards but to exceed customer’s expectations.

In order to do so, the Bank closely monitors customer’s experience with the Bank from

“end to end”, gathering feedback from all “touch points” with its customers – corporate

web page, blog, Facebook fan page, social media, media, Call Center, e-channels,

blogs, regular telephone interviews, tablets in offices, etc. The Bank invests in activities and

initiatives to continuously improve the customer experience in all channels and touch

points.

9. Capital Markets

In 2016 Raiffeisenbank (Bulgaria) EAD reaffirmed its leading position on the local foreign

exchange and debt capital markets.

Throughout 2016 the institution strengthened further the quality cooperation with its

customers and counterparties with focus on enhancing the offered service and overall

customer experience. In response to market demand, the Bank successfully added a new

derivative product for currency risk protection to its product mix, allowing customers to

attain at one and the same time enhanced flexibility and cost optimization.

The increased customer penetration and the improved service have led to an

improvement in financial results, generated by traditionally strong product areas, and

complemented by more complex products for market risk management.

Raiffeisenbank (Bulgaria) EAD is a respected and preferred primary dealer and supports

the Ministry of Finance by bidding regularly on the government debt auctions, and by

proactive participations in discussions and working groups, organized by the Ministry or the

Bulgarian National Bank. At the end of 2016 the Bank was once again appointed a

primary dealer for the next calendar year.

https://www.rbb.bg/en/individual-clients/loans/consumer-loans/

https://www.rbb.bg/en/individual-clients/bank-cards/

https://www.rbb.bg/en/individual-clients/bank-cards/



Translation in English of the official Consolidated Management report issued in Bulgarian. xxvii

Being an integral part of an international banking group, Raiffeisenbank (Bulgaria) EAD

successfully employs the experience of its sister network banks and proposes alternative

solutions based on а wide range of products, thus providing comprehensive services and

treasury products to its demanding retail, corporate and institutional clients.

10. Group Securities Services

Raiffeisenbank (Bulgaria) specializes in providing a wide range of custodial and depository

services to banks and non-bank financial institutions in Central and Eastern Europe,

including Bulgaria, as well as local corporate customers.

In recognition of our customers' satisfaction with the high quality custodial and depository

services, Raiffeisen Group, including Raiffeisenbank (Bulgaria), continues to receive

excellent results and awards in the surveys of leading specialized publications on the

trends in management and administration of client assets. In March 2016 Raiffeisen Group

was awarded by Global Custodian with the award for Best Sub-Custodian Bank in

Emerging Europe, and in June 2016 won the prestigious award "Best Sub-custodian CEE" by

Global Investor. The awards once again highlight the serious commitment and

responsibility of Raiffeisenbank in the field of custodial and depository services. These

represent the latest recognition for our innovative approach in the search for the best and

most effective solution for our customers in the CEE markets. In 2016, a remarkable growth

of 25% YoY in client assets under custody in Raiffesenbank (Bulgaria) was recorded, which

further strengthened our position among the leading financial institutions in Bulgaria in

custodial services.

11. Financial Institutions and Sovereigns

Relationship with Banks, Non – Bank Financial Institutions and Sovereigns

Raiffeisenbank (Bulgaria) EAD develops its relations with first-class international and local

financial institutions as well as with International Organisations and Central Government

Organisations. As of the end of 2016, the Bank has established correspondent relations

with more than 1,100 banks while the number of accounts in different currencies

maintained by the bank was 22. The Bank offers a full range of services to approximately

200 non–bank financial institutions and 150 Central Government Organizations and

International Organisations.

Based on the excellent quality of tailor-made services provided to Financial Institutions

and the confidence of the international financial community in Raiffeisenbank (Bulgaria)

EAD, almost 40 foreign banks – mainly from Europe, North America – and more than 20

international non -banking financial institutions and international organizations maintain

accounts with the Bank in local and foreign currencies.

The Bank continues to be among the preferred partners with increasing number of

serviced local Insurance companies, Pension insurance companies, Fund management

companies, Investment intermediarie etc. Raiffeisenbank (Bulgaria) is among the local

leaders in servicing Central Government Authorities, Sovereigns, Non-Commercial

Undertakings – Sovereigns and International Organizations by providing a complex bank

service and full range of bank products.



Translation in English of the official Consolidated Management report issued in Bulgarian. xxviii

Relationship with International Financial Institutions

Raiffeisenbank (Bulgaria) is one of the leaders on the Bulgarian market in attracting mid-

term and long-term funding from International Financial Institutions. For the last 14 years,

the total amount of agreements negotiated under Credit Line and Risk Sharing Facilities

(signed with institutions such as the European Bank for Reconstruction and Development,

the European Investment Bank, the European Investment Fund, KfW, the European Fund

for Southeast Europe, the Council of Europe Development Bank, the National Gurantee

Fund etc.) is more than EUR 800 mn.

Raiffeisenbank (Bulgaria) continued successful cooperation with IFIs and the National

Guarantee Fund. In 2016, the Bank has signed three risk sharing facilities with the European

Investment Fund and two with the National Gurantee Fund. The total amount of

agreements signed with the EIF was EUR EUR 205 mn out of which EUR 35 mn under the

InnovFin SME Guarantee Facility, EUR 70 mn under the SME Initiative and EUR 100 mn under

the COSME Loan Guarantee.

12. Raiffeisen Insurance Broker

Raiffeisen Insurance Broker EOOD, a company founded in 2006, is 100 per cent owned by

Raiffeisenbank (Bulgaria) EAD. On 30 March 2006 the Financial Supervision Commission

listed Raiffeisen Insurance Broker EOOD in the Register of the insurance brokers under

Registration No 250-3B, thus marking up the launch of its activities of insurance

intermediation.

In fulfillment of the highest customer service standards, Raiffeisen Insurance Broker

performs various activities, some of which are related to studying and analyzing the

insurance market trends, preparation of detailed analysis, modeling of specific insurance

products, administrating insurance contracts and last but not least - assistance in cases of

insurance events. Raiffeisen Insurance Broker provides high-quality insurance

intermediation services to individuals and legal entities. The company‘s clients are

borrowers of Raiffeisenbank (Bulgaria) EAD, lease holders of Raiffeisen Leasing Bulgaria

OOD and other customers outside the Raiffeisen Group.

For the Retail customers the Broker offers tailor made product „ Property Certificate”

which are issued on the spot.

The product is flexible, it optimized the work process and increased the customer

satisfaction.

The Broker uses additional sales channel through Insurance zones to offer wide range of

insurance products.

Insurance experts are able to provide specific insurance expertise to Bank customers since

December 2015.

The financial data as of 31 December 2016 shows that for the past one-year period

Raiffeisen Insurance Broker has realized BGN 24 million premium income.

13. Raiffeisen Asset Management (Bulgaria) EAD

Market Share/Assets under management

The dynamic global market environment influenced financial markets in 2016. Record

declines in financial markets at the beginning of the year, leaving the UK from the

European Union, presidential elections in the US and Bulgaria influenced the performance

of the Raiffeisen Asset Management’ funds. The launch of the new fund in euros Raiffeisen

Bulgaria Global Mix contributes to increase the amount of assets under management.



Translation in English of the official Consolidated Management report issued in Bulgarian. xxix

However, redemptions from institutional and corporate clients lead to a decrease in

market share of Raiffeisen Asset Management from 16,8% by the end of 2015 to 14,2% by

the end of 2016. During the period the Company was able to increase the number of

retail clients. By increasing the relative share of the investments of the retail clients for the

account of big institutional and corporate clients, the company is aiming to limit the

concentration risk, which will lead to stability and predictability of its cash flows.

Market share of RAM

Date %

30.06.2015 26,3%

31.12.2015 16,8%

30.06.2016 15,4%

31.12.2016 14,2%

Assets under Management

Date AUM

30.06.2015 BGN 235,9 mln

31.12.2015 BGN 141,9 mln

30.06.2016 BGN 141,4 mln.

31.12.2016 BGN 152,9 mln.

By the end of 2016 RAM manages and distributes four local funds, covering conservative

and high-risk spectrum. As of 31 December 2016, the assets managed by the company in

the four local funds are amounting to BGN 153 mln., which represents 14,2 % market share.

One of the main activities of „Sales & Marketing” Department of RAM is connected with the

training of the staff in the branch network of the Bank, which is offering the products of the

company. The regular visits in the branches of RBBG are aiming to constantly increase the

investment culture and the knowledge of the employees in the field of mutual funds, which is

resulting in higher recognition of these products throughout the clients of the bank.

New products and initiatives/Clients base

In January 2016 RAM has received an approval from the Financial Supervision Commission

(FSC) for the transformation of its biggest fund – MF Raiffeisen (Bulgaria) Liquidity Fund in

MF Raiffeisen Conservative Fund Bulgaria, as in line with its new investment policy the fund

may invest up to 100 per cent of its assets in Bulgarian Government debt. The broad

knowledge, experience and over ten years presence of the company on the local

market, combined with the expertise of Raiffeisen Group, provide very good opportunities

for the performance of the fund, as well as, bring value added to the investors.

In April 2016 RAM has started the offering of new mutual fund - MF Raiffeisen (Bulgaria)

Global Mix, representing feeder collective investment scheme, investing at all time 85 per

cent or more of its assets in units of master fund MF Raiffeisen Raiffeisenfonds-Sicherheit,

managed by Raiffeisen Capital Management, Vienna. As of 31st December 2016, the

assets accumulated in the fund are amounting to BGN 7,2 mln.

These initiatives aimed to enrich and renew the offered by the company product mix,

adjusting it to the current market environment and the newest tendencies in the asset

management, to optimize the performance of the funds and и to attract new clients and

assets.

10.10%

12.36%

15.86% 15.39% 16.85%

15.95%

0.00%

2.00%

4.00%

6.00%

8.00%

10.00%

12.00%

14.00%

16.00%

18.00%

31.3.2006 30.6.2006 31/09/2006 30.10.2006 30.11.2006 31.12.2006

Пазарен дял на РАМ



Translation in English of the official Consolidated Management report issued in Bulgarian. xxx

At the end of 2016 the company offers to its clients four local mutual funds, there of them

being with low to moderate risk profile and one fund - MF Raiffeisen (Bulgaria) Global

Growth – with moderate to high level of risk.

In addition to the core product range, RAM offers to its clients two additional products,

suitable for long term saving of funds – Deposit Mix and Individual Investment Plan.

In 2016 the main focus of the company was entirely oriented to the sales of low risk profile

mutual funds with an accent in the Retail segment.

At the end of 2016 the number of company’s clients has reached 5,720, which represents

an increase of more than 18% compared to 2015. The share of the investments held by

institutional and corporate clients in the funds managed by RAM is approximately 20 %,

compared to 25 % as of December 2015, which has resulted respectively in an increase of

the share of retail customers from 75 % to 80 % for the same period.

Total assets under management in local funds as of 31.12.2016 are amounting to BGN 153

mln. which represents an increase of 7.8 % compared to the end of 2015.

RCM Funds

As of 31st December 2016 the clients’ assets in RCM funds, Vienna, distributed by RAM are

amounting to BGN 18 mln.

Investment approach and achieved return

Raiffeisen Asset Management (Bulgaria) EAD applied analytical and professional expertise

working in close collaboration with Raiffeisen Group in making investment decisions,

construction and management of the local funds’ portfolios.

The divergence in the monetary policies of the FED and ECB was one of factors

influencing the financial markets indexes. For 2016 the European STOXX 600 registered an

increase of 2,1 per cent while the STOXX 50 is up by 4,4 per cent. In the U.S. the S&P 500

has gained 11,8 per cent.

The Bulgarian SOFIX ended the year with an increase of 30.1 per cent. The activity of

investors on the BSE rose after the release of the first exchange-traded fund that tracks the

index SOFIX.

In January 2016 RAM has transformed its biggest fund – Raiffeisen (Bulgaria) Liquidity Fund

and changed its name and investment strategy. The name of the new fund is Raiffeisen

Conservative Fund Bulgaria and may invest up to 100 per cent of its assets in Bulgarian

sovereign debt.

In April 2016 RAM has launched new fund -- Raiffeisen (Bulgaria) Global Mix, a

master/feeder investment scheme, investing constantly 85 per cent or more of its assets in

units of master fund Raiffeisenfonds-Sicherheit, managed by Raiffeisen Capital

Management, Vienna. As of 31st December 2016, the assets accumulated in the fund are

amounting to BGN 7.2 mln.

Assets under management in the mutual funds managed by RAM as of the end of 2016

are as follows:

MF Raiffeisen Conservative Fund Bulgaria is the biggest mutual fund in Bulgaria with

assets amounting to BGN 87.6 mln;

MF Raiffeisen (Bulgaria) Active Protection is managing BGN 48.5 mln;

MF Raiffeisen (Bulgaria) Global Growth is managing BGN 9,5 mln;

MF Raiffeisen (Bulgaria) Global Mix is managing BGN 7,3 mln.



Translation in English of the official Consolidated Management report issued in Bulgarian. xxxi

Absolute return of the locally managed mutual funds for 2016 is as follows:

MF Raiffeisen Conservative Fund Bulgaria: 0,73% p.a.;

MF Raiffeisen (Bulgaria) Active Protection: 2,32% p.a.;

MF Raiffeisen (Bulgaria) Global Growth Fund: 2.46% p.a.;

MF Raiffeisen (Bulgaria) Global Mix: 0,74% p.a.

14. Raiffeisen Leasing Bulgaria ЕOOD

Raiffeisen Leasing Bulgaria OOD was established in 2004 with shareholders Raiffeisenbank

(Bulgaria) EAD, holding 24.5 per cent of its shares, and Raiffeisen Leasing International

GmbH, holding 75.5 per cent.

In July 2016 the extraordinary General Meeting of the shareholders of Raiffeisen Leasing

Bulgaria OOD approved Raiffeisen Leasing International GmbH's request for relief from

partnership in Raiffeisen Leasing Bulgaria OOD. All the shares of Raiffeisen Leasing

International GmbH were taken by the other shareholder - Raiffeisenbank (Bulgaria) EAD.

After the shares' transfer, the legal form of the company changes to Raiffeisen Leasing

Bulgaria EOOD.

Raiffeisen Leasing Bulgaria ЕOOD has already been an active player on the leasing

market for 12 years. The main leased assets offered to the customers are new and used

vehicles, construction and agricultural machinery, light and heavy trucks, trailers and

forklifts, machines and equipment as well as real estate leasing.

The market share of Raiffeisen Leasing Bulgaria ЕOOD as of 31 December 2016 was 9.02

per cent, based on the leasing portfolio (BNB statistics). The total volume of the leasing

market as of 31 December 2016 amounted to BGN 3,314 mln which was a increase of

BGN 226 mln compared to 31 December 2015.

As of 31 December 2016 the total assets of Raiffeisen Leasing Bulgaria OOD amounted to

BGN 313 mln.

At the end of 2016 the net lease receivables of Raiffeisen Leasing Bulgaria OOD

amounted to BGN 292 mln. The leased assets were distributed as follows: vehicles – 80.7

per cent, equipment – 7.3 per cent and real estate – 12.0 per cent.

The customers of Raiffeisen Leasing Bulgaria ЕOOD are Corporates representing 78.4 per

cent of the total portfolio, followed by small and medium enterprises – 13.9 per cent and

private individuals – 7.7 per cent.

In 2016, the attracted and utilized medium and long-term financing reached to BGN 292

mln, out of which BGN 28 mln from international financial institutions.

Raiffeisen Leasing Bulgaria ЕOOD have registered 9 branches in the regional cities

throughout the country.



Translation in English of the official Consolidated Management report issued in Bulgarian. xxxii

Translation in English of the official Auditor’s report issued in Bulgarian.

2 Translation in English of the official Auditor’s report issued in Bulgarian.


Consolidated financial statements as at 31 December 2016

5 Translation in English of the official Consolidated Financial Statements issued in Bulgarian.




1. BASIS OF PREPARATION

(a) Reporting entity

Raiffeisenbank (Bulgaria) EAD (the Bank) with identification number 831558431, registered under N 14195/ 1994 in the Commercial registry, is indirectly 100% owned by Raiffeisen Bank International, Austria. The ultimate owner is Raiffeisen Zentralbank AG, Austria.

The Bank has a general banking license issued by the Bulgarian National Bank (BNB) according to which it is allowed to conduct all banking transactions permitted by the Bulgarian legislation in the country and abroad, as well as to conduct all deals and services in its capacity of investment intermediary according to the Public offering of securities Act and the the regulations related to it.

The Bank is a joint-stock company with two-tier management system. The management and representation is performed by the Board of directors under the control of the Supervisory board.

The consolidated financial statements of the Bank for 2016 represent the financial statements of the Bank and its subsidiaries and associated companies as described in note 35, referred to as the Group.

(b) Basis of accounting

These consolidated financial statements have been prepared in accordance with the International Financial Reporting Standards (IFRS), as adopted by the European Union. The reporting framework “IFRS adopted by EU” in its essence is the adopted national accounting base IAS, as accepted by the EU, regulated by the Bulgarian Accountancy act and defined under p. 8 of the additional provisions thereof.

(c) Basis of measurement

These financial statements have been prepared on the historical cost basis except for the following:

financial assets and liabilities at fair value through profit or loss, which are measured at fair value;

available-for-sale financial instruments, which are measured at fair value;

defined benefit retirement obligations to employees, which are accounted at their net present value, adjusted for any actuarial gains/losses.

(d) Presentation of the financial statements

These consolidated financial statements are presented in Bulgarian leva (BGN) rounded to the nearest thousand, which is the Group’s functional currency.

The Group presents the statement of financial position based on liquidity ranking. A maturity analysis up to 12 months and more than 12 months from reporting date is presented in the accompanying notes.

The Group’s assets and liabilities are presented gross in the statement of financial position, except for items, for which there is legal or contractual right to be netted.




(e) Comparable information

Financial statements include comparative information from previous reporting period. The information related to the previous financial year may be corrected if this correction is necessary in terms of comparison to the information presented for the current financial year.

2. SIGNIFICANT ACCOUNTING POLICIES

These consolidated financial statements are prepared by applying one and the same accounting policy by the Group and its subsidiaries.

a) Basis of consolidation

These consolidated financial statements are prepared in accordance with IFRS 10 “Consolidated Financial Statements” and IAS 28 “Investments in associates and joint ventures”, whereby participations with more than 50% of the voting rights are fully consolidated and all participations with more than 20% of the voting rights are consolidated using the equity method.

Transactions between entities under common control

As part of Raiffeisen Group restructuring, in 2016 Raiffeisenbank (Bulgaria) EAD acquired 75.5% from the share capital of Raiffeisen Leasing Bulgaria EOOD and became 100% owner of the entity. The following accounting policy is applied with regard to this deal under common control:

In the absence of IFRS that is directly applicable to transactions between entities under common control, the Bank applied the requirements of IAS 8 - Accounting Policies, Changes in Accounting Estimates and Errors, using also current information sources (as far as they are not contradicting the general framework or a concrete IFRS or interpretation thereof) in defining own accounting policy for accounting of such transactions. In establishing own accounting policy the Bank considers the substance of the transactions, as well as the needs of key users of the financial statements. Business combinations between entities under common control are excluded from the scope of IFRS 3 – Business combinations, hence the standard does not prescribe their accounting treatment and an entity may elect either to use the acquisition method or the method of consolidating participations when reporting the transaction. In the presented below financial statements the Bank has applied the method of consolidating participations, which consist of the following:

- The assets and liabilities of the acquired entity are considered at their book values that have been presented in the separate financial statements of the acquired entity by the time of the transaction

- No corrections are undertaken with regard to fair values or recognition of new assets or liabilities at the date of acquisition, which would otherwise be required when applying the acquisition method. Corrections are made only in order to unify the accounting policies applied by the entities under common control.




- The difference between paid/transferred consideration and the “acquired” net assets at the effective date of the transfer is presented under as “Change in consolidation group” in equity.

- The statement of comprehensive income includes the activity of the acquired entity after the date of acquisition. For accounting purposes the effective date of acquisition is 01 January 2016, therefore the statement of comprehensive income includes the activity of Raiffeisen Leasing Bulgaria EOOD for the period from the acquisition to 31 December 2016. This effective date is adopted based on management judgment that the full control of Raiffeisen Leasing EOOD commences from the announcement of the Group restructuring.

Comparative financial information is not restated, because according to IFRS 10 Consolidated financial statements the acquired entity is not included in the financial statements of the acquiring entity before the date at which control was taken over.

b) Income and expense recognition

Income is recognized to the extent, that the Group assumes economic benefits will be realized and income could be measured reliably.

Interest income and expense

Interest income and expense are recognized in profit or loss for all interest bearing instruments on an accrual basis using the effective interest rate.

Interest income and expense presented in profit or loss include:

interest on financial assets and liabilities at amortized cost; interest on investment securities designated as at fair value through profit or loss, which excludes trading assets; interest income from trading assets is disclosed in net trading result; interest on available for sale securities carried at fair value through other comprehensive income;

Interest income and expense on all trading assets and liabilities are considered to be incidental to the Group’s trading operations and are presented together with all other changes in the fair value of trading assets and liabilities in net trading income.

In the current environment of negative market interest rates, the Group realizes interest expense on financial assets, as for example deposits with other banks or maintaining minimum reserves with the Central Bank that are above the required minimum. These expenses are disclosed under “interest expense” as explained in note 7.

Fair value changes

Fair value changes on derivatives are presented in net result from derivatives in profit or loss. Fair value changes in trading assets are included in net trading income Fair value changes of investments securities carried at fair value through profit or loss, are presented in net income from investments in profit or loss, which also includes gains and losses on the realization of available-for-sale financial assets, and impairment losses on available-for-sale financial assets and investments in associates.




Fees and commission

Fees and commission are generally recognized on an accrual basis when the service has been provided.

Fees and commission income and expenses that are integral to the effective interest on a financial asset or liability are included in the measurement of the effective interest income/expense. Loan commitment fees for credit lines that are likely to be drawn down, are deferred and are recognized as an adjustment to the effective interest income on the loan. Loan syndication fees are recognized as revenue when the syndication has been completed and the Group has recognized in its statement of financial position the respective part of the syndication. Commission and fees arising from negotiating, or participating in the negotiation of, a transaction for a third party – such as the arrangement of the acquisition of shares or other securities or the purchase or sale of businesses – are recognized upon completion of the underlying transaction. Portfolio and other management advisory and service fees are recognized based on the applicable service contracts, usually on a time-apportionate basis.

Other fees and commission income, including account servicing fees, sales commission, payments transfer fees, cash transaction fees, card payment commissions are recognized as the related services are performed.

Other fees and commission expense, which is not part of the effective interest expense, represents mainly transaction and service fees, which are expensed as the services are received.

Dividends

Dividend income is recognized in profit or loss when the Group’s right to receive payment is established.

Net trading income

Net trading income comprises gains less losses related to trading assets and liabilities, and includes all realized and unrealized fair value changes, interest, dividends and foreign exchange differences.

c) Leasing

Determining whether a credit agreement contains leasing

At origination of a credit agreement, the Group determines whether it is or contains leasing. At origination or at a subsequent measurement of a credit agreement that contains leasing, the Group divides payments and other considerations related to this agreement into leasing and other elements based on the percentage of their fair values.

When the Group concludes that payments could not be divided reliably, asset and liability are recognized to the amount of the fair value of the base asset; subsequently the liability is decreased by the payments and an expense is recognized using the Group’s differential interest rate.




- The Group as lessor

Finance lease

When the Group is lessor under finance lease agreements a receivable is recognized to the amount of the net investment in finance lease, which includes all minimum lease payments due under the leasing agreement and the unguaranteed residual value discounted with the respective effective interest rate.

A leasing agreement is classified as finance lease if the lessor transfers to the lessee all significant risks and rewards arising from the ownership of the leased assets.

The main indicators considered by the Group when determining whether all significant risks and rewards are transferred include among other: comparison between the net present value of the minimum lease payments and the fair value of the leased asset at the beginning of the lease agreement; comparison between the duration of the lease agreement and the useful life of the leased assets; the right of the lessee to acquire the assets at the end of the finance lease agreement. Lease agreements that do not transfer all significant risks and rewards arising from the ownership of the asset are classified as operational lease.

Minimum lease payments

Minimum lease payments are defined as the payments that the lessee will make or is obliged to make during the period of the lease agreement. From the Group’s perspective minimum lease payments include also the asset’s residual value guaranteed by third party in case there is an arm’s length guarantee agreement.

Commencement of the lease agreement and commencement of the term of the lease agreement

It should be differentiated between the commencement of the lease agreement and the commencement of the term of the lease agreement. The lease agreement commences on the earlier of both dates - the date of the lease agreement and the date when the parties engage with the main conditions of the lease agreement. By that date:

- the lease agreement is classified as finance or operational lease; and

- in case of finance lease are determined the amounts that should be recognized at the commencement of the term of the lease agreement

Commencement of the term of the lease agreement is the date when the lessee is entitled to exercise he right to use the leased asset. This is also the date when the Group initially recognizes the lease receivable.

Initial and subsequent measurement

At the date the lease agreement commences the Group recognizes finance lease receivable to the amount of the net lease investment. The initial direct costs related to the lease agreement are considered when determining the lease receivable. During the term of the lease agreement the Group recognizes interest income from finance lease. The net investment in finance lease is disclosed under “Loans and receivables from customers” net of impairment, which is calculated according to the Group’s Policy for impairment of financial assets at amortized cost.

Operational lease

Assets rendered under operational lease are classified as “means of transport”. The lessor retains all significant risks and rewards from the ownership of the leased assets. The assets




continue to be part of the lessor’s inventory and their depreciation for the term of the lease agreement is included in the operating expenses of the lessor. The income from the operational lease is recognized in profit or loss for the year on a linear basis over the term of the respective lease agreement. The initial direct costs related with the conclusion of the operational lease agreement are included in the book value of the leased asset and are recognized on a linear basis over the term of the operational lease agreement.

- The Group as lessee

Assets held by the Group under leases that transfer to the Group substantially all of the risks and rewards of ownership are classified as finance leases. The leased asset is initially measured at an amount equal to the lower of its fair value and the present value of the minimum lease payments. Subsequent to initial recognition, the asset is accounted for in accordance with the accounting policy applicable to that asset.

Assets held under leases where substantially all the risk and rewards of ownership are not transferred, are not recognized in the Group’s statement of financial position.

Minimum lease payments made under finance leases are apportioned between the finance expense and the reduction of the outstanding liability. The finance expense is allocated to each period during the lease term so as to produce a constant periodic rate of interest on the remaining balance of the liability.

Payments made under operating leases are recognized in profit or loss on a straight-line basis over the term of the lease.

d) Foreign currency transactions

All transactions in foreign currencies are translated to the functional currency of the Group at exchange rates fixed by the Bulgarian Central Bank at the date of the transaction. Monetary assets and liabilities denominated in foreign currencies at the reporting date are retranslated to the functional currency at the exchange rate fixed by the Bulgarian Central Bank at that date and the revaluation result is recognized in comprehensive income.

e) Financial assets and financial liabilities The Group classifies its financial instruments in the following categories: financial assets at fair value through profit or loss including trading assets and liabilities and derivatives; loans and receivables; held-to-maturity investments; available-for-sale financial assets and other financial liabilities. The Group determines the classification of financial assets and liabilities at their initial recognition. The Group initially recognizes loans and advances, deposits, debt securities, borrowings and subordinated liabilities on the date they are originated. All other financial instruments (including regular-way purchases and sales of financial assets) are recognized on the trade date on which the Bank becomes a party to the contractual provisions of the instrument. i. Financial assets at fair value through profit or loss - recognition and measurement The Group designates financial assets and liabilities at fair value through profit or loss when: the financial assets or liabilities are managed, evaluated and reported on a fair value basis;




the designation eliminates or significantly reduces an accounting mismatch which would otherwise arise; or the financial asset or liability contains an embedded derivative that significantly modifies the cash flows that would otherwise be required under the contract. Financial assets and liabilities at fair value through profit or loss are initially recognized in the Group’s statement of financial position at fair value and are subsequently measured at fair value. Transaction costs are directly recognized in profit or loss.

ii. Trading assets and liabilities – recognition and measurement

Trading assets and liabilities are those assets and liabilities that the Group acquires or incurs principally for the purpose of selling or repurchasing in the near term, or holds as part of a portfolio that is managed together for short-term profit or position taking. Trading assets and liabilities are initially recognized and subsequently measured at fair value in the statement of financial position with transaction costs taken directly to profit or loss. All changes in fair value are recognized as part of net trading income in profit or loss. Trading assets and liabilities are not reclassified subsequent to their initial recognition.

iii. Derivatives – recognition and measurement

Derivatives are initially recognized at fair value on the date on which a derivative contract is entered into and are subsequently re-measured accordingly to the quoted market prices obtained from active financial markets. If no information on the market price is available, valuation techniques such as discounted cash flow models are used as appropriate. All derivatives are carried as assets when fair value is positive and as liabilities when fair value is negative.

iv. Loans and receivables – recognition and measurement

Loans and receivables are non-derivative financial assets with fixed or determinable payments that are not quoted in an active market and that the Group does not intend to sell immediately or in the near term. Loans and advances to banks are classified as loans and receivables. Loans and receivables are initially measured at fair value plus incremental direct transaction costs, and subsequently measured at their amortised cost using the effective interest method less any impairment losses.

v. Held-to-maturity – recognition and measurement

Held-to-maturity investments are non-derivative assets with fixed or determinable payments and fixed maturity that the Group has the positive intent and ability to hold to maturity. Held-to-maturity investments are initially measured at fair value plus incremental direct transaction costs and subsequently measured at amortised cost using the effective interest method. A sale or reclassification of a more than insignificant amount of held-to-maturity investments would result in the reclassification of all held-to-maturity investments as available-for-sale. However, sales and reclassifications in any of the following circumstances would not trigger a reclassification: - sales or reclassifications that are so close to maturity that changes in the market rate of interest would not have a significant effect on the financial asset’s fair value; - sales or reclassifications after the Group has collected substantially all of the asset’s original principal; and - sales or reclassifications that are attributable to non-recurring isolated events beyond




the Group’s control that could not have been reasonably anticipated.

vi. Available-for-sale – recognition and measurement

Available-for-sale investments are those intended to be held for an indefinite period of time, which may be sold in response to needs for liquidity or changes in interest rates, exchange rates or equity prices and which are not classified as at fair value through profit or loss or held to maturity. Available-for-sale financial assets are initially recognized at fair value plus any directly attributable transaction costs. Subsequent to initial recognition, they are measured at fair value and changes therein, other than impairment losses and foreign currency differences on debt instruments, are recognized in other comprehensive income and accumulated in the fair value reserve. When these assets are derecognized, the gain or loss accumulated in equity is reclassified to profit or loss. Interest income is recognized in profit or loss using the effective interest method.

vii. Other financial liabilities – recognition and measurement

Other non-derivative financial liabilities are initially measured at fair value less any directly attributable transaction costs. Subsequent to initial recognition, these liabilities are measured at amortized cost using the effective interest method.

Deposits, borrowings from banks, debt securities issued and subordinated liabilities are the Group’s main funding sources and are classified as other financial liabilities, carried at amortized cost.

viii. Fair values of financial assets and liabilities

“Fair value” is the price that would be received to sell an asset or paid to transfer a liability in an orderly transaction between market participants at the measurement date in the principal or, in its absence, the most advantageous market to which the Group has access at that date. The fair value of a liability reflects its non-performance risk.

When available, the Group measures the fair value of an instrument using the quoted price in an active market for that instrument. A market is regarded as active if transactions for the asset or liability take place with sufficient frequency and volume to provide pricing information on an ongoing basis.

If there is no quoted price in an active market, then the Group uses valuation techniques that maximise the use of relevant observable inputs and minimise the use of unobservable inputs. The chosen valuation technique incorporates all of the factors that market participants would take into account in pricing a transaction.

The best evidence of the fair value of a financial instrument at initial recognition is normally the transaction price – i.e. the fair value of the consideration given or received. If the Group determines that the fair value at initial recognition differs from the transaction price and the fair value is evidenced neither by a quoted price in an active market for an identical asset or liability nor based on a valuation technique that uses only data from observable markets, then the financial instrument is initially measured at fair value, adjusted to defer the difference between the fair value at initial recognition and the transaction price. Subsequently, that difference is recognized in profit or loss on an appropriate basis over the life of the instrument but no later than when the valuation is wholly supported by observable market data or the transaction is closed out.

If an asset or a liability measured at fair value has a bid price and a ask price, then the Group measures assets and long positions at a bid price and liabilities and short positions at an ask price.




The fair value of a demand deposit is not less than the amount payable on demand, discounted from the first date on which the amount could be required to be paid.

The Group recognizes transfers between levels of the fair value hierarchy as of the end of the reporting period during which the change has occurred.

ix. Derecognition

The Group derecognizes a financial asset when the contractual rights to the cash flows from the asset expire, or it transfers the rights to receive the contractual cash flows on the financial asset in a transaction in which substantially all the risks and rewards of ownership of the financial asset are transferred. Any interest in transferred financial assets that is created or retained by the Group is recognized as a separate asset or liability.

The Group derecognizes a financial liability when its contractual obligations are discharged or cancelled, or expire.

The Group enters into transactions whereby it transfers assets recognized on its statement of financial position, but retains either all risks and rewards of the transferred assets or a portion of them. If all or substantially all risks and rewards are retained, then the transferred assets are not derecognized from the statement of financial position. Transfers of assets with retention of all or substantially all risks and rewards include, for example, securities lending and repurchase transactions. Upon transfer of a financial asset on which the Group retains control, the asset continues to be recognized in the statement of financial position, the Group assesses the extent to which it is exposed to changes in the fair value of the asset.

In certain transactions the Group retains rights to service a transferred financial asset for a fee. The transferred asset is derecognized in its entirety if it meets the derecognition criteria. An asset or liability is recognized for the servicing rights, depending on whether the servicing fee is more than adequate to cover servicing expenses (asset) or is less than adequate for performing the servicing (liability).

f) Cash and cash equivalents

Cash and cash equivalents comprise cash balances on hand and in current accounts in other banks, unrestricted cash deposited with the Central bank and placements with banks with original maturity of less than 3 months.

Cash at banks is classified as loans and receivables and is carried at amortized cost in the statement of financial position.

g) Deals with securities

Securities borrowing and lending and repurchase agreements

(i) Securities borrowing and lending

Investments lent under securities lending arrangements are recognized in the statement of financial position and are measured in accordance with the accounting policy for financial assets designated at fair value through profit or loss, available for sale or held to maturity. Cash collaterals received in respect of securities lent are recognized as liabilities to either banks or customers. Investments borrowed under securities borrowing agreements are not recognized as assets of the Group. Cash collateral placements in respect of securities borrowed are recognized under loans and advances to either banks or customers. Income and expenses arising from the securities borrowing and lending business are recognized on an accrual basis over the period of the transactions and are included in interest income or expense.




(ii) Repurchase agreements

The Group enters into purchases (sales) of investments under agreements to resell (repurchase) substantially identical investments at a certain date in the future at a fixed price. Investments purchased subject to commitments to resell them at future dates are not recognized.

The amounts paid are recognized as receivables under repurchase agreements. The receivables are shown as collateralized by the underlying security. Investments sold under repurchase agreements continue to be recognized in the statement of financial position and are measured in accordance with the accounting policy for either assets held for trading or at fair value through profit or loss as appropriate. The proceeds from the sale of the investments are reported in the statement of financial position as liabilities on repurchase agreements.

The difference between the sale and repurchase considerations is recognized on an accrual basis over the period of the transaction and is included in interest income or expense.

h) Offsetting

Financial assets and financial liabilities are offset and the net amount is reported in the statement of financial position when the Group has a legally enforceable right to set off the recognized amounts and the transactions are intended to be settled on a net basis.

Income and expenses are presented on a net basis only if permitted under IFRS, as adopted by the EU, or for gains and losses arising from group of similar transactions such as in the Group’s trading activities.

i) Impairment

Impairment of financial assets

At each reporting date the Group assesses whether there is objective evidence that financial assets not carried at fair value through profit or loss are impaired. In case such evidence exists, recoverable amount of the assets is defined.

Financial assets are impaired when objective evidence demonstrates that a loss event has occurred after the initial recognition of the asset, and that the loss event has an impact on the future cash flows on the asset that can be estimated reliably. Objective evidence that financial assets (including equity securities) are impaired can include default or delinquency by a borrower, restructuring of a loan or advance by the Group on terms that the Group would not otherwise consider, indications that a borrower or issuer will enter bankruptcy, the disappearance of an active market for a security, or other observable data relating to a group of assets such as adverse changes in the payment status of borrowers or issuers in the group, or economic conditions that correlate with defaults in the group. Loans and advances are measured and classified based on their credit risk grade, delinquency, financial difficulty of the borrower and his cash flow generating ability. If the Group has more than one credit exposure against a group of borrowers with common risk characteristics, all exposures are classified according to the grade of the borrower bearing the highest credit risk.

The Group considers evidence of impairment at both an individual and collective level. Exposures which are past due more than 90 days or for which some or all of the default indicators mention above have been identified, are assessed for individual impairment. All significant assets found not to be individually impaired are then collectively assessed for any




impairment that has been incurred but not yet identified. Assets that are not individually significant are then collectively assessed for impairment by grouping together financial assets (carried at amortized cost) with similar risk characteristics.

In assessing collective impairment the Group uses statistical modelling of historical trends of the default rates, timing of recoveries and the amount of loss incurred, adjusted for management’s judgments as to whether current economic and credit conditions are such that the actual losses are likely to be greater or less than suggested by historical modelling. Default rates, loss rates and the expected timing of future recoveries are regularly benchmarked against actual outcomes to ensure that they remain appropriate.

Individual impairment losses on individually identified assets are measured as the difference between the carrying amount of the financial assets and the present value of estimated cash flows, considering the risk grade of the borrower, discounted at the assets’ original effective interest rate. Short-term balances are not discounted.

When a loan (or part of a loan) is uncollectible, it is written off against the related allowance for loan impairment. Such loans are written off after all the necessary procedures have been completed and the amount of the loss has been determined.

When a subsequent event causes the amount of impairment loss to decrease and that decrease can be objectively related to an event after the impairment recognition, the impairment loss is reversed through profit or loss.

Loans and advances are presented net of impairment losses. The increase of the impairment losses is recognized in profit or loss. The Group reintegrates in its current year income impairment losses, which are released as a result of a partial or the total collection of the provisioned exposure, as well as in case of reclassifying the exposure into a lower credit risk group.

Allowances for impairment losses on a collective basis are allocated against exposures to cover existing losses, which could not be identified for each individual loan according to the Group’s provisioning policy. The Group’s policy for allocation of portfolio based allowances for impairment losses determines the principles for reducing the statement of financial position amount of a portfolio of loans with similar credit risk characteristics to their recoverable amount as at the reporting date.

In case indication for impairment is identified for assets available for sale, the cumulative loss recognized in other comprehensive income is reclassified to profit or loss. The cumulative loss represents the difference between the purchase price and the current fair value of the financial asset, decreased by losses that are already recognized in profit or loss.

Impairment on non-financial assets

At each reporting date, the Group reviews the carrying amounts of its non-financial assets to determine whether there is any indication of impairment. If any such indication exists, then the asset’s recoverable amount is estimated.

For impairment testing, assets are grouped together into the smallest group of assets that generates cash inflows from continuing use that is largely independent of the cash inflows of other assets or CGUs.

The ‘recoverable amount’ of an asset or CGU is the greater of its value in use and its fair value less costs to sell. ‘Value in use’ is based on the estimated future cash flows, discounted to their present value using a pre-tax discount rate that reflects current market assessments of the time value of money and the risks specific to the asset or CGU.

An impairment loss is recognised if the carrying amount of an asset or CGU exceeds its recoverable amount.




Impairment losses are recognised in profit or loss. They are allocated first to reduce the carrying amount of any goodwill allocated to the CGU, and then to reduce the carrying amounts of the other assets in the CGU on a pro rata basis.

An impairment loss in respect of goodwill is not reversed. For other assets, an impairment loss is reversed only to the extent that the asset’s carrying amount does not exceed the carrying amount that would have been determined, net of depreciation or amortisation, if no impairment loss had been recognised.

j) Investments in associates

The Group accounts for its investments in associates at cost. Dividends from associates are

recognized in profit or loss when the Group's right to receive the dividend is established.

The Group assesses at the end of each reporting period whether there is any indication

that an investment in associate may be impaired. If any such indication exists, the Group

estimates the recoverable amount of the investment based on the ability of the entity to

continue to generate income and to pay out dividends to the Group.

k) Property, plant and equipment

Recognition and measurement

Items of property, plant and equipment are measured at cost less accumulated depreciation. Cost includes expenditures that are directly attributable to the acquisition of the asset. Purchased software that is integral to the functionality of the related equipment is capitalized as part of that equipment.

When parts of an item of property or equipment have significant part in the total cost of the asset, or have different useful lives, then they are accounted and depreciated as separate items (major components) of property and equipment.

Subsequent costs

The cost of replacing part of an item of property, plant or equipment is recognized in the carrying amount of the item if it is probable that the future economic benefits embodied within the part will flow to the Bank and its cost can be measured reliably.

Depreciation

Property, plant and equipment are depreciated on a straight-line basis over the estimated useful lives. Leased assets are depreciated over the shorter of the lease term and their useful lives. Land is not depreciated.

The estimated depreciation rates are as follows:

Assets % Buildings 4 Equipment 15-50 Fixtures and fittings and reconstructions 15 Vehicles 20-25

Assets are not depreciated until they are brought into use and transferred from assets in the course of construction into the relevant asset category.




l) Intangible assets

Recognition and measurement

Intangible assets, which are acquired by the Group, are stated at cost less accumulated amortization and any impairment losses.

Subsequent costs

Subsequent expenditure on intangible assets is capitalized only when it increases the future economic benefits embodied in the specific asset to which it relates. All other expenditure is expensed when incurred.

Amortization

Amortization is calculated on a straight-line basis over the expected useful life of the asset. The annual rates of amortization are as follows:

Assets %

Licenses 15-33

Computer software 20-50

m) Repossessed assets

Repossessed assets are measured at the lower of carrying amount and the net realizable value. Carrying amount includes acquisition expenses, state fees for court executors, etc.

Net realizable value is the estimated selling price reduced by approximately evaluated costs for sale realization.

n) Provisions for liabilities and charges

A provision is recognized in the statement of financial position when the Group has a legal or constructive obligation as a result of a past event, and it is probable that an outflow of economic benefits will be required to settle the obligation. Provisions are determined by discounting the expected future cash flows at a pre-tax rate that reflects current market assessments of the time value of money and, where appropriate, the risks specific to the liability. Short-term provisions are usually not discounted.

o) Employee benefits

(i) Short-term employee benefits

Short-term employee benefits include salaries, bonuses and benefits in kind and are expensed as the related service is provided. A liability is recognized for the amount expected to be paid if the Group has a present legal or constructive obligation to pay this amount as a result of past service provided by the employee and the obligation can be estimated reliably.

(ii) Defined contribution plans

Obligations for contributions to defined contribution plans comprise contributions to state-owned institutions and to obligatory pension funds managed by privately-owned management companies, in accordance with legal requirements or individual choice. Obligations for contributions to defined contribution plans are expensed as the related service is provided.




(iii) Defined benefits

The Group’s obligation in respect of defined benefits is calculated separately for each plan and the amount of future benefits that employees have earned in the current and prior periods is estimated and that amount is discounted at an appropriate discount rate.

The calculation is performed annually by a qualified actuary using the projected unit credit method. The Group determines the net interest expense on the net defined benefit liability for the period by applying the discount rate used to measure the defined benefit obligation at the beginning of the annual period to the net defined benefit liability.

Remeasurements of net defined benefit liability which comprise actuarial gains and losses and are recognized in other comprehensive income. Net interest expense and other expenses related to defined benefits, including costs for past service, are recognized in profit or loss.

p) Financial guarantees and loan commitments

“Financial guarantees” are contracts that require the Group to make specified payments to reimburse the holder for a loss that it incurs because a specified debtor fails to make payment when it is due in accordance with the terms of a debt instrument. “Loan commitments” are firm commitments to provide credit under pre-specified terms and conditions.

q) Income tax

Income tax expense comprises current and deferred tax. It is recognized in profit or loss except to the extent that it relates to a business combination, or items recognized directly in equity or in OCI.

(i) Current tax

Current tax is the expected tax payable or receivable on the taxable income or loss for the year, using tax rates enacted or substantively enacted at the reporting date, and any adjustment to tax payable or receivable in respect of previous years. Current tax also includes any tax arising from dividends.

(ii) Deferred tax

Deferred tax is recognized in respect of temporary differences between the carrying amounts of assets and liabilities for financial reporting purposes and the amounts used for taxation purposes. Deferred tax is not recognized for:

• temporary differences on the initial recognition of assets or liabilities in a transaction that is not a business combination and that affects neither accounting nor taxable profit or loss;

• temporary differences related to investments in subsidiaries and jointly controlled entities to the extent that it is probable that they will not reverse in the foreseeable future; and

• taxable temporary differences arising on the initial recognition of goodwill.

Deferred tax is measured at the tax rates that are expected to be applied to temporary differences when they reverse, based on the laws that have been enacted or substantively enacted by the reporting date.




Deferred tax assets and liabilities are offset if there is a legally enforceable right to offset current tax liabilities and assets, and they relate to income taxes levied by the same tax authority.

A deferred tax asset is recognized for unused tax losses, tax credits and deductible temporary differences, to the extent that it is probable that future taxable profits will be available against which they can be utilized. Deferred tax assets are reviewed at each reporting date and are reduced to the extent that it is no longer probable that the related tax benefit will be realized.

In determining the amount of current and deferred tax the Group takes into account the impact of uncertain tax positions and whether additional taxes and interest may be due. This assessment relies on estimates and assumptions and may involve a series of judgments about future events. New information may become available that causes the Group to change its judgment regarding the adequacy of existing tax liabilities; such changes to tax liabilities will impact tax expense in the period that such a determination is made.

r) Segment reporting

The Group applies IFRS 8 “Operating segments” which requires the Bank to present operating segments based on the information that is internally provided to the Management.

s) Transactions with securities

The Bank performs for customers the following transactions with securities:

- Services related to investments in securities

- Transfers from/to securities accounts with the Bank to/from securities accounts with other banks and/or custodians

- Maintenance and servicing of securities accounts

- Administration of customer’s securities portfolios

- Custody services for pension funds, CIUs, investment funds and SPEs

The customer’s securities are held on individual customer securities accounts and are separated from the Bank’s own assets.

Fees and commissions received from transactions with securities are recognized in profit or loss when the service is provided.

t) Changes in accounting policy and disclosures

The accounting policies adopted are consistent with those of the previous financial year. The following amendments to standards have been adopted by the Company as of 1 January 2016:

IAS 16 Property, Plant and Equipment and IAS 38 Intangible assets (Amendments): Clarification of Acceptable Methods of Depreciation and Amortization

The amendments clarify the principle in IAS 16 and IAS 38 that revenue reflects a pattern of economic benefits that are generated from operating a business (of which the asset is part) rather than the economic benefits that are consumed through use of the asset. As a




result, the ratio of revenue generated to total revenue expected to be generated cannot be used to depreciate property, plant and equipment or amortise intangible assets. The amendments have no effect on the Group’s financial position or performance.

IAS 16 Property, Plant and Equipment and IAS 41 Agriculture (Amendments): Bearer Plants

The amendments are not relevant to the Group’s activity.

IAS 19 Employee benefits (Amended): Employee Contributions

The amendment applies to contributions from employees or third parties to defined benefit plans. The objective of the amendment is to simplify the accounting for contributions that are independent of the number of years of employee service, for example, employee contributions that are calculated according to a fixed percentage of salary. The amendment has no effect on the Group’s financial position or performance.

IFRS 11 Joint Arrangements (Amendment): Accounting for Acquisitions of Interests in Joint Operations

The amendment adds new guidance on how to account for the acquisition of an interest in a joint operation that constitutes a business in accordance with IFRS. The Group has no interests that could fall within the scope of this amendment.

IFRS 10, IFRS 12 and IAS 28: Investment Entities: Applying the Consolidation Exception (Amendments)

The amendments clarify that the exemption from presenting consolidated financial statements applies to a parent entity that is a subsidiary of an investment entity, when the investment entity measures all of its subsidiaries at fair value. Also, the amendments clarify that only a subsidiary that is not an investment entity itself and provides support services to the investment entity is consolidated. All other subsidiaries of an investment entity are measured at fair value. The amendments to IAS 28 Investments in Associates and Joint Ventures allow the investor, when applying the equity method, to retain the fair value measurement applied by the investment entity associate or joint venture to its interests in subsidiaries. The amendments have no effect on the Group’s financial position or performance.

IAS 1 Presentation of Financial Statements: Disclosure Initiative (Amendment)

The amendments to IAS 1 Presentation of Financial Statements further encourage companies to apply professional judgment in determining what information to disclose and how to structure it in their financial statements. They clarify, rather than significantly change, existing IAS 1 requirements. The amendments relate to materiality, order of the notes, subtotals and disaggregation, accounting policies and presentation of items of other comprehensive income (OCI) arising from equity accounted Investments. The amendments affect presentation only and have no impact on the Group’s financial position or performance.

IAS 27 Separate Financial Statements (Amended)

The amendment allows entities to use the equity method to account for investments in subsidiaries, joint ventures and associates in their separate financial statements. The amendment has no effect on the Group’s consolidated financial statements.




Annual improvements to IFRSs 2010-2012 Cycle

Summary of amendments and related standards are provided below:

IFRS 2 Share-based Payments – amended definitions of ‘vesting condiitons’ and ‘market

condition’ and adding the definitions of ‘performance condition’ and ‘service condition’;

IFRS 3 Business Combinations – clarification on the accounting for contingent consideration arising from business combination;

IFRS 8 Operating Segments – additional disclosures of management judgement on aggregating operating segments and clarification on reconciliation of total segments’ assets to the entity’s assets;

IFRS 13 Fair Value Measurement – clarification on interaction with IFRS 9 as regards short-term receivables and payables;

IAS 16 Property, Plant and Equipment – amended to state that when an item of property, plant and equipment is revalued, the gross carrying amount is adjusted in a manner that is consistent with the revaluation of the carrying amount while the accumulated depreciation is calculated as a difference between the gross carrying amount and the carrying amount after taking into account accumulated impairment losses;

IAS 24 Related Party Disclosures – clarified that a management entity that provides key management services to a reporting entity is deemed to be a related party; disclosure of the service fee paid or payable is required;

IAS 38 Intangible Assets – same amendment as IAS 16 above.

The adoption of the above amendments to standards has no effect on these financial statements of the Group.

Annual improvements to IFRSs 2012-2014 Cycle

Summary of amendments and related standards are provided below:

IFRS 5 Non-current Assets Held for Sale and Discontinued Operations – clarification that changing from one of the disposal methods to the other (through sale or through distribution to the owners) should not be considered to be a new plan of disposal, rather it is a continuation of the original plan;

IFRS 7 Financial Instruments: Disclosures – provides examples of continuing involvement in a financial asset and clarifies required disclosures in the condensed interim financial report;

IAS 19 Employee Benefits – clarification on long-term liability discount rate determination;

IAS 34 Interim Financial Reporting – clarification on required interim disclosures: they must either be in the interim financial statements or incorporated by cross-reference to other interim financial information (e.g., in the management report) that is available to users on the same terms as the interim financial statements and at the same time.

The adoption of the above amendments to standards has no effect on these financial statements of the Group.

Standards issued but not yet effective and not early adopted

Standards issued but not yet effective and not early adopted up to the date of issuance of the Company’s financial statements are listed below. This listing is of standards and interpretations issued, which the Company reasonably expects to have an impact on




disclosures, financial position or performance when applied at a future date. The Company intends to adopt those standards when they become effective.

IFRS 9 Financial Instruments: Classification and Measurement

The standard is effective for annual periods beginning on or after 1 January 2018 with early adoption permitted. The final version of IFRS 9 reflects all phases of the financial instruments project and replaces IAS 39 Financial Instruments: Recognition and Measurement and all previous versions of IFRS 9. The standard introduces new requirements for classification and measurement, impairment, and hedge accounting. The Group is in process of analysing and assessing the impact of the new standard on its future financial position or performance. In 2016 the Group started a large scale project under the methodological guidance of Raiffeisen Bank International focused on the analysis and assessment how the standard will impact the Group’s future financial position and activity. Within the scope of the project is also the preparation of the Group’s IT systems for the implementation of the new standard. The project is led by the Bank’s project office with the participation of representatives from different business units, Finance division, Risk controlling and IT. The project work is divided into two main streams – classification and measurement and respectively impairment of financial instruments.

IFRS 15 Revenue from Contracts with Customers

The standard is effective for annual periods beginning on or after 1 January 2018 with earlier application permitted. IFRS 15 establishes a five-step model that will apply to revenue earned from a contract with a customer (with limited exceptions), regardless of the type of revenue transaction or the industry. The standard’s requirements will also apply to the recognition and measurement of gains and losses on the sale of some non-financial assets that are not an output of the entity’s ordinary activities (e.g., sales of property, plant and equipment or intangibles). Extensive disclosures will be required, including disaggregation of total revenue; information about performance obligations; changes in contract asset and liability account balances between periods and key judgments and estimates. The Group will analyse and assess the impact of the new standard on its financial position or performance.

IFRS 15 Revenue from Contracts with Customers (Clarifications)

The clarifications apply for annual periods beginning on or after 1 January 2018 with earlier application permitted. The objective of the clarifications is to clarify the IASB’s intentions when developing the requirements in IFRS 15 Revenue from Contracts with Customers, particularly the accounting of identifying performance obligations amending the wording of the “separately identifiable” principle, of principal versus agent considerations including the assessment of whether an entity is a principal or an agent as well as applications of control principle and of licensing providing additional guidance for accounting of intellectual property and royalties. The clarifications also provide additional practical expedients for entities that either apply IFRS 15 fully retrospectively or that elect to apply the modified retrospective approach. These clarifications have not yet been endorsed by the EU. The Group will analyse and assess the impact of these clarifications on its financial position or performance.

IFRS 16 Leases

The standard is effective for annual periods beginning on or after 1 January 2019. IFRS 16 sets out the principles for the recognition, measurement, presentation and disclosure of leases for both parties to a contract, i.e. the customer (‘lessee’) and the supplier (‘lessor’).




The new standard requires lessees to recognize most leases on their balance sheet and to have a single accounting model for all leases, with certain exemptions. Lessor accounting is substantially unchanged. The standard has not been yet endorsed by the EU. The Group will analyse and assess the impact of the new standard on its financial position or performance.

Amendments in IFRS 10 Consolidated Financial Statements and IAS 28 Investments in Associates and Joint Ventures: Sale or Contribution of Assets between an Investor and its Associate or Joint Venture

The amendments address an acknowledged inconsistency between the requirements in IFRS 10 and those in IAS 28, in dealing with the sale or contribution of assets between an investor and its associate or joint venture. A full gain or loss is recognized when a transaction involves a business or a partial gain or loss is recognized when a transaction involves assets that do not constitute a business. The IASB postponed the effective date of this amendment indefinitely pending the outcome of its research project on the equity method of accounting. The amendments have not yet been endorsed by the EU. It is not expected that these amendments would impact the Group’s financial position or performance of the Company.

IAS 12 Income taxes (Amendments): Recognition of Deferred Tax Assets for Unrealised Losses

The amendments are effective for annual periods beginning on or after 1 January 2017, with early application permitted. The objective of these amendments is to clarify the accounting for deferred tax assets for unrealised losses in order to address diversity in practice in the application of IAS 12 Income Taxes. The specific issues where diversity in practice existed relate to the existence of a deductible temporary difference upon a decrease in fair value, to recovering an asset for more than its carrying amount, to probable future taxable profit and combined versus separate assessment. These amendments have not yet been endorsed by the EU. It is not expected that these amendments would be relevant to the Group.

IAS 7 Statement of Cash Flows (Amendments): Disclosure Initiative

The amendments are effective for annual periods beginning on or after 1 January 2017, with earlier application permitted. The objective of these amendments is to enable users of financial statements to evaluate changes in liabilities arising from financing activities. The amendments will require entities to provide disclosures that enable investors to evaluate changes in liabilities arising from financing activities, including changes arising from cash flows and non-cash changes. These amendments have not yet been endorsed by the EU. It is not expected that these amendments would be relevant to the Group.

IFRS 2 Share-based Payment (Amendments): Classification and Measurement of Share based Payment Transactions

The amendments are effective for annual periods beginning on or after 1 January 2018 with earlier application permitted. The amendments provide requirements on the accounting for the effects of vesting and non-vesting conditions on the measurement of cash-settled share-based payments, for share-based payment transactions with a net settlement feature for withholding tax obligations and for modifications to the terms and conditions of a share-based payment that changes the classification of the transaction from cash-settled to equity-settled. These amendments have not yet been endorsed by




the EU. It is not expected that these amendments would impact the Group’s financial position or performance.

IFRS 4 Insurance Contracts (Amendments): Applying IFRS 9 Financial Instruments with IFRS 4 Insurance Contracts

The amendments are not relevant to the Group would not impact its financial position or performance.

IFRIC 22 Foreign Currency Transactions and Advance Consideration

The interpretation is effective for annual periods beginning on or after 1 January 2018 with earlier application permitted. This interpretation addresses how to determine the date of the transaction for the purpose of determining the exchange rate to use on initial recognition of the related asset, expense or income (or part of it) on the derecognition of a non-monetary asset or non-monetary liability arising from the payment or receipt of advance consideration in a foreign currency. The interpretation has not yet been endorsed by the EU. The Group will assess the impact of the new interpretation on its financial position or performance.

IAS 40 Investment Property (Amendments): Transfers of Investment Property

The amendments are effective for annual periods beginning on or after 1 January 2018 with earlier application permitted. The amendments clarify transfers of property to, or from, investment property when there is a change in the use of such property which is supported by evidence. These amendments have not yet been endorsed by the EU. It is not expected that these amendments would impact the Group’s financial position or performance.

Annual Improvements to IFRSs 2014-2016 Cycle

In the 2014-2016 annual improvements cycle, the IASB issued amendments to three standards which are effective for annual periods beginning on or after 1 January 2017 / 1 January 2018. Summary of amendments and related standards are provided below: IFRS 1 First-time Adoption of International Financial Reporting Standards - deletion of

short-term exemptions for first-time adopters (effective for annual periods beginning on or after 1 January 2018);

IFRS 12 Disclosure of Interests in Other Entities - clarification of the scope of the Standard (effective for annual periods beginning on or after 1 January 2017), and

IAS 28 Investments in Associates and Joint Ventures - measuring an associate or joint venture at fair value (effective for annual periods beginning on or after 1 January 2018).

The improvements to IFRSs 2014 – 2016 Cycle have not yet been endorsed by EU. The will assess the impact of the amendments on its financial statements.

3. FINANCIAL RISK MANAGEMENT

Introduction and overview

The Group is exposed to the following risks from its use of financial instruments:

A. Credit risk

B. Liquidity risk




C. Market risks

D. Capital management

Risk management framework

The Management Board has overall responsibility for the establishment and oversight of the Group’s risk management framework.

Risk management is been overseen by the Supervisory Board Risk Committee established following the requirements of art. 6 of the Bulgarian national bank Ordinance 7 on organization and risk management of banks. The SB Risk Committee shall advise the Management Board and the Supervisory Board on the Group’s overall current and future risk appetite and strategy and assist the Management Board and the Supervisory Board in overseeing the implementation of that strategy by senior management.

The Board has established in addition the Group’s Asset and Liability Committee (ALCO), Credit Committee, Problem Loans Committee, Operational Risk Management Committee and Portfolio Committees of the Group, which are responsible for developing and monitoring Group risk management policies in their specified areas.

The Group’s risk management policies are established to identify and analyze the risks faced by the Group, to set appropriate risk limits and controls, and to monitor risks and adherence to limits. Risk management policies and systems are reviewed regularly to reflect changes in market conditions, products and services offered. The Group, through its training programs and management standards and procedures, aims to develop a disciplined and constructive control environment, in which all employees understand their roles and obligations.

By its nature the Group’s activities are principally related to the use of financial instruments. The Bank accepts deposits from customers at both fixed and floating rates and for various periods and seeks to invest these funds in high quality assets.

A. Credit risk

The Group is permanently exposed to credit risk, arising from the probability that counterparties might default on their contractual obligation under loans and advances when due or in full. Credit risk is the most important risk for the Group’s business; management therefore carefully manages its exposure to credit risk. The Group has a set of policies and procedures in relation to credit approval and credit exposures management. In addition, the Group is exposed to off-balance sheet credit risk through commitments under unutilized extended credit lines and issued guarantees.

Concentrations of credit risk (whether on or off-balance sheet) might arise from risk exposures to one borrower or group of borrowers, with similar economic characteristics, that might be affected in equal terms by changes in economic or other circumstances in meeting their contractual obligations.

The Group is exposed to credit risk also in result of its trading and investment activities, as well as in result of its activities as an investment intermediary for its customers or for third parties. The credit risk arising on trading and investment activities is managed through the management of market risk.

The risk that counterparts to financial instruments might default on their obligations is monitored on an ongoing basis by the Group. In monitoring credit risk exposures related to trading instruments, consideration is given to instruments with a positive fair value and to the volatility of the fair value of trading instruments.




Management of credit risk

The Supervisory Board has delegated responsibility for the management of credit risk to

the Group’s Management Board. The Management Board defines the credit policy based

on analysis of the business situation and the assessment of the risk associated with credit

business. The scope of the Corporate Lending Policy is to present a clear picture in which

direction the Group’s corporate credit portfolio shall develop within the next year. The

approval of the Corporate Lending Policy by Supervisory Board ensures, that the steps

proposed by the Group with regards to targeted industries, products, etc. and the

subsequent impacts of those steps on the corporate credit portfolio are in line with the

plans of the Supervisory Board and therefore in line with the basic strategy of RBI Group.

The credit risk management is performed by the organizational units reporting to the Chief

Risk Officer. The main responsibilities of these units are:

Recommend and manage portfolio concentration limits based on approved limits for

proactive steering of the concentrations on GCC (Group of Connected Customers) level;

Provide independent review of limit applications and credit risk assessment based on

internal models;

Perform proactive risk management of transactional and portfolio activities;

Ensure that risk management standards, policies, practices and tools of the RBI Group

are adhered to by all business units in the credit process;

Assist the Risk Originating Units/Account Managers in establishing business-specific risk

management practices (not contradicting standard tools introduced by RBI Group) for

the approval, measurement, reporting, monitoring, limiting and analysis of credit risk of

corporate customers;

Assist in the identification, classification and management of problematic exposures,

including exposures with forbearance;

Ensure that “early warning signs” reported by the Risk Originating Units are considered

properly and internal actions (e.g. downgrading of Customer Rating, Review and

establishment of action plans for potential problematic exposures) are initiated quickly;

Cooperate with the Risk Originating Unit in establishing the Credit Policy, review the final

Credit Policy paper and recommend amendments whenever necessary as well as

monitor the compliance with the approved Credit Policy.

Risk limit control and mitigation policies

The Group manages limits and controls concentrations of credit risk wherever they are identified – in particular, to individual counterparties and groups, and to industries and countries.

The Group structures the levels of credit risk it undertakes by placing limits on the amount of risk accepted in relation to one borrower, or group of borrowers, and to geographical and industry segments. Such risks are monitored on a revolving basis and subject to regular reviews, when considered necessary.

Exposure to credit risk is also managed through regular analysis of the ability of borrowers and potential borrowers to meet interest and capital repayment obligations.




Credit risk measurement

In measuring credit risk of loans and advances to customers and to banks at a counterparty level, the Group reflects three components (i) the probability of default by the client or counterparty on its contractual obligations; (ii) current exposures to the counterparty and its likely future development, from which the Group derives the “exposure at default”; (iii) the likely recovery ratio on the defaulted obligations (the loss given default), and (iv) loss identification period which is the probability of default horizon.

These credit risk components, which reflect expected loss are compliant with the regulatory requirements of Bulgarian National Bank and the European Directive for capital adequacy and are embedded in the Group’s daily operational management. However, when determining the impairment losses to reduce the carrying amount of the exposure, the requirements of IAS 39 are applied, which are based on losses that have been incurred at the reporting date.

The Group assesses the probability of default of individual counterparties using internal rating tools tailored to the various categories of exposures and counterparty. They have been developed internally and combine statistical analysis with judgment and are validated, where appropriate, by comparison with externally available data. Clients of the Group are segmented into rating classes, reflecting the range of default probabilities defined for each rating class. This means, that in principle, exposures migrate between classes as the assessment of their probability of default changes. The rating tools are kept under review and upgraded as necessary. The Group regularly validates the performance of the rating and their predictive power with regard to default events. The Group uses the assessments of recognized external credit assessment institutions where available to benchmark the internal credit risk assessment.

Since November 1st, 2014 Raiffeisenbank (Bulgaria) EAD has received an approval to apply internal ratings based approach for the assessment and management of the credit risk according to the requirements of the current bank regulations, namely Regulation (EC) 575/2013.

Exposure at default is based on the amounts the Group expects to be owed at the time of default. For example, for a loan this is the outstanding principal. For a commitment, the Group includes any amount already drawn plus the further amount that may have been drawn by the time of default, should it occur.

Loss given default represents the Group’s expectation of the extent of loss on a claim should default occur. It varies by type of counterparty, type of seniority of claim and availability of collateral or other credit mitigation.

For debt securities or other bills, both internal and external ratings are used for managing of the credit risk exposures. The investments in those securities and bills are viewed as a way to gain a better credit quality mapping and maintain a readily available source to meet the funding requirement at the same time, hence ensuring also compliance with the respective regulatory requirements and ratios.

Collateral

The Group employs a range of policies and practices to mitigate credit risk. The most

traditional of these is taking security for funds advances. The Group implements guidelines

on the acceptability of specific classes of collateral or credit risk mitigation. The principal

collateral types used by the Group are:




- mortgages over residential properties;

- cash deposits;

- pledge of business assets such as premises, inventory and accounts receivable;

- bank guarantees;

- portfolio guarantees issued by first-class international or national institutions;

- pledge of financial instruments such as debt securities and equities.

Long-term finance and lending to corporate entities are generally secured; consumer

loans for individual persons are generally unsecured. In addition, in order to minimize the

credit loss the Group might seek additional collateral from the counterparty when

impairment indicators are noticed for the relevant individual loans and advances.

Derivatives

The Group maintains strict credit risk limits towards its counterparties which have derivative

deals (exposures) having in mind the deal structure in terms of currencies, term and

notional amount. They can be split into two categories as follows:

- Settlement Limit: limits the maximum payments due on each single day;

- FX-Derivatives Limit: limits the replacement cost of all OTC Derivative products in case the

counterparty defaults.

At any time, the amount subject to credit risk is limited to the current fair value of

instruments that are favorable to the Group (i.e. assets, where their fair value is positive),

which in relation to derivatives is only a small fraction of the contract, or notional values

used to express the volume of instruments outstanding. The credit risk exposure is

managed as part of the overall lending limits with customers, together with potential

exposures from market movements. Collateral or other security is not usually obtained for

credit risk exposures on these instruments.

Settlement risk arises in any situation where a payment in cash, securities or equities is

made in the expectation of a corresponding receipt in cash, securities or equities. Daily

settlement limits are established for each counterparty to cover the aggregate of all

settlement risk arising from the Bank’s market transactions on any single day.

Credit-related commitments

The primary purpose of these instruments is to ensure that funds are available to a

customer as required. Guarantees and standby letters of credit carry the same credit risk

as loans. Documentary and commercial letters of credit – which are written undertakings

by the Group on behalf of a customer authorizing a third party to draw drafts on the Bank

up to a stipulated amount under specific terms and conditions – are collateralized by the

underlying shipments of goods to which they relate and therefore carry less risk than a

direct loan.

Commitments to extend credit represent unused portions of authorizations to extend

credit in the form of loans, guarantees or letters of credit. With respect to credit risk on

commitments to extend credit, the Group is potentially exposed to loss in an amount

equal to the total unused commitments. However, the likely amount of loss is less than the

total unused commitments, as most commitments to extend credit are contingent upon




customers maintaining specific credit standards. The Group monitors the term to maturity

of credit commitments because long-term commitments generally have a greater degree

of credit risk than short-term commitments. However, any commitments that are

unconditionally cancellable at any time by the Group without prior notice, or that

effectively provide for automatic cancellation due to deterioration in the borrower’s

creditworthiness, are considered by the Group to bear no risk.

Policy for risk exposures assessment and allocation of impairment allowances for credit risk

The internal and external rating systems focus more on credit quality mapping from the inception of the lending and investment activities. In contrast, impairment allowances are recognized for financial reporting purposes only for losses that have been incurred at the reporting date based on objective evidence of impairment. The Group applies different approaches with regard to assessment of impairment and determination of the credit loss, depending on the customer segment and product type. Individual impairment allowance is set aside for defaulted customers in all segments: - exposure is past due more than 90 days; - exposure is identified as unlikely to be paid on the basis of default indicators Allowances for impairment of retail customers’ secured exposures are measured at 100% after considering the collateral value if it is mortgage. For unsecured products for private individuals individual impairment is defined based on time since default, accounting for the observed discounted historical recovery after default until the ultimate collection period is reached. Exposures of retail customers, for which no individual impairment has been identified, are grouped together in pools according to their internal rating. The collective impairment of each pool is measured according to the historic default rate and loss upon default for the respective rating class. The historic default rate represents the number of defaulted exposures during the observation period as percentage from total number of exposures in the respective pool. The observation period is 12 months and the average is calculated on historically available consecutive 12-month periods and considers only existing non-defaulted exposures at the beginning of the period. The collective impairment is determined by multiplying the exposure by the historic default rate, which corresponds to the rating class of the customer and by the level of Loss Given Default (LGD). LGD values are also based on historical data spanning more than 5 years, as defined for IRB parameter estimation. LGD is defined as 100% less the average historically observed recovery rate. For certain retail products with non-significant exposure that are not covered by IRB models, individual allowances are calculated after 180 days past due and in case of other unlikely to pay indicators. Accounts that are individually assessed for impairment and identified as impaired are excluded from a collective assessment of impairment, but they may enter into the model, which determines loss factors used for collective allowances for impairment. In December 2015 Raiffeisenbank (Bulgaria) EAD has introduced internal-rating based model in the calculation of allowance for impairment losses for loans to private individuals and micro entities. Estimates of specific parameters (Historic Default Rate, Loss Given Default and Credit Conversion Factor) are subject to annual recalculation, following the




established internal processes of the Bank for internal-rating models. With this change being in default is the main criteria for the calculation of impairment allowance on collective and individual level.

Exposures to non-retail customers are evaluated and classified based on the credit risk level, the period of delay of amounts due, the assessment of the debtor’s financial state and the main sources for repayment of the debtor’s obligations. The Group applies a policy for determining allowance for collective impairment of exposures to corporate customers. Exposures to large, middle and small corporate customers, as well as financial institutions for which no individual impairment has been identified, are grouped together in pools according to their internal rating. The collective impairment of each pool is measured according to the historic default rate for the respective rating class. The historic default rate represents the number of defaulted customers within the observation period as percentage from total number of customers in the respective pool. The observation period is 12 months and the average is calculated on 5 consecutive 12-month periods and considers only customers with existing exposures at the beginning and the end of the period. The collective impairment is determined by multiplying the net exposure after deduction of the highly liquid collateral by the historic default rate, which corresponds to the rating class of the customer and by the level of loss on the unsecured part of the exposure (Loss Given Default, LGD). Due to the limited historical data for recovered amounts on defaulted exposures, the Group applies the Group benchmark for LGD according to the respective rating models. Except for trading assets and derivatives (considered later), the Group’s maximum credit risk exposure net of impairment is presented in the below table. Balances with the Central bank do not bear credit risk.

Loans and advances to

customers


banks

Investment securities

(excluding equity

investments)

Contingent liabilities

In BGN

‘000 31.12.2016 31.12.2015 31.12.2016 31.12.2015 31.12.2016 31.12.2015 31.12.2016 31.12.2015

Carrying

amount 3,979,675 3,555,359 382,606 780,530 961,656 706,658 - -

Commit

ment 1,227,084 1,172,180 43,407 14,906 - - 313,897 262,002




Credit risk exposures

As at 31 December 2016

In BGN '000

Loans and

advances to

customers

Contingent

liabilities

Unutilized

loan

commitments

Individually impaired:

Minimal risk - - -

Very good credit standing - - -

Good credit standing - - -

Sound credit standing - - -

Acceptable credit standing - - -

Marginal credit standing - - -

Weak credit standing / sub-standard - - -

Very weak credit standing / doubtful 16 - -

Default 162,349 5,535 79

Unrated

Retail 135,482 0 2,716

Gross amount 297,847 5,535 2,795

Allowance for impairment (215,708) (3,363) -

Carrying amount 82,139 2,172 2,795 Including exposures with forbearance

measures 185,417 987 1

Collectively impaired subject to IBNR:

Minimal risk - - -

Very good credit standing 1,204 45,417 -

Good credit standing 167,292 45,173 219

Sound credit standing 745,053 92,053 -

Acceptable credit standing 537,063 29,432 -

Marginal credit standing 127,750 6,726 637

Weak credit standing / sub-standard 42,953 2,044 -

Very weak credit standing / doubtful 7,876 2,069 -

Default 8 - -

Unrated 81 120 0

Retail 1,906,228 6,253 178,462

Gross amount 3,535,508 229,287 179,318

Allowance for impairment (31,394) (244) (1,263)

Carrying amount 3,504,114 229,043 178,055 Including exposures with forbearance

measures 85,732 - -

Past due, but not impaired:

Good credit standing 42 - 263

Sound credit standing 1,013 59 7,095

Acceptable credit standing 571 - 191

Marginal credit standing 1,531 - -

Weak credit standing / sub-standard 862 - 7


Default 0 - 2

Retail 988 - 449

Gross amount 5,482 59 8,007




Including exposures with forbearance

measures 1,170 - -

Past due comprises:

1-30 days 5,035 59

30-60 days 192 - -

60-90 days 209 - -

90-180 days 46 - -

180 days + 0 - -

Gross amount 5,482 59 Including exposures with forbearance

measures 1,170 - -

Neither past due, nor impaired:

Minimal risk 49 - 84

Excellent credit standing 2,288 783 7,734

Very good credit standing 19,404 11,764 35,543

Good credit standing 93,991 39,891 299,762

Sound credit standing 109,982 10,742 433,066

Acceptable credit standing 84,453 10,667 186,740

Marginal credit standing 35,407 1,480 27,343

Weak credit standing / sub-standard 12,790 496 6,547

Very weak credit standing / doubtful 8,526 12 646

Default - - 1

Unrated 321 - 53

Retail 20,729 352 39,445

Gross amount 387,940 76,187 1,036,964


measures 10,349 39 973

Total portfolio 4,226,777 311,068 1,227,084

Allowance for impairment (247,102) (3,607) (1,263)

Carrying amount 3,979,675 307,462 1,225,821


measures 282,668 1,026 975





In BGN '000

Loans and

advances to

customers

Contingent

liabilities

Unutilized

loan

commitments

Individually impaired:

Minimal risk - - -

Very good credit standing - - -

Good credit standing - - -

Sound credit standing - - -

Acceptable credit standing - - -

Marginal credit standing 3 - -

Weak credit standing / sub-standard 1 - -


Default 269,561 12,546 -

Unrated 16 - -

Retail 151,475 - -

Gross amount 421,057 12,546 -


Carrying amount 172,969 11,299 - Including exposures with forbearance

measures 285,019 1,927 -

Collectively impaired subject to IBNR:

Minimal risk - - -

Very good credit standing 960 4,441 -

Good credit standing 196,744 26,529 -

Sound credit standing 443,612 38,797 -

Acceptable credit standing 399,327 69,013 -

Marginal credit standing 104,244 3,148 -

Weak credit standing / sub-standard 16,113 273 -

Very weak credit standing / doubtful 24,953 2,600 -

Unrated 709 30 -

Retail 1,682,124 5,553 -

Gross amount 2,868,786 150,384 -

Allowance for impairment (30,872) (274) -

Carrying amount 2,837,914 150,110 - Including exposures with forbearance

measures 97,242 39 -

Past due, but not impaired:

Good credit standing 247 - -

Sound credit standing 370 - -

Acceptable credit standing 1,354 - -

Marginal credit standing 559 - -

Weak credit standing / sub-standard 130 - -

Very weak credit standing / doubtful 1,478 - -

Retail 770 - -

Gross amount 4,908 - - Including exposures with forbearance

measures 989 - -

Past due comprises: -

1-30 days 4,484 - -




30-60 days 303 - -

60-90 days 39 - -

90-180 days 68 - -

180 days + 14 - -

Gross amount 4,908 - - Including exposures with forbearance

measures 989 - -

Neither past due, nor impaired:

Excellent credit standing 6 59 4,923

Very good credit standing 144,946 55,708 125,559

Good credit standing 47,415 9,158 227,383

Sound credit standing 114,338 9,154 390,313

Acceptable credit standing 98,833 14,475 182,085

Marginal credit standing 38,719 3,268 37,684

Weak credit standing / sub-standard 9,778 768 3,327

Very weak credit standing / doubtful 20,045 175 4,733

Default - - 20

Unrated 5 6 189

Retail 65,483 250 195,964

Gross amount 539,568 93,021 1,172,180


measures 16,111 175 -

Total portfolio 3,834,319 255,951 1,172,180


Carrying amount 3,555,359 254,430 1,172,180


measures 399,360 2,142 -

Individually impaired

Individually impaired are those exposures with criteria for individual impairment as described above in the “Policy for risk exposures assessment and allocation of impairment allowances for credit risk”. Collectively impaired Collectively impaired exposures are those without indications for need of individual impairment. Past due, but not impaired Past due, but not impaired are past due exposure which are subject to collective impairment, however it is 0. Neither past due, nor impaired Neither past due, nor impaired are exposures that are not past due and are subject to collective impairment, however it is 0.




Risk Categories Risk categories are defined according to the rating and the correspondent limits of the estimated probability of default in the corporate segments as follows:

Risk categories Lower limit of probability of default

Upper limit of probability of default

Minimal risk >0.0000% ≤0.0300%

Excellent credit standing >0.0300% ≤0.0751%

Very good credit standing >0.0751% ≤0.1878%

Good credit standing >0.1878% ≤0.4694%

Sound credit standing >0.4694% ≤1.1735%

Acceptable credit standing >1.1735% ≤2.9338%

Marginal credit standing >2.9338% ≤7.3344%

Weak credit standing/ sub-standing

>7.3344% ≤18.3360%

Very weak credit standing/ doubtful

>18.3360% <100%

Default 100% n.a.

Forborne exposures For the purpose of the reports above, forborne exposures are debt contracts in respect of which forbearance measures have been extended. Forbearance measures consist of concessions towards a debtor facing or about to face difficulties in meeting its financial commitments (“financial difficulties”). Investment securities are treated as neither past due, nor impaired with good/ very good credit standing. Set out below is an analysis of the gross and net (of allowances for impairment) amounts of individually impaired assets by risk grade

In BGN '000

Gross

amount

Carrying

amount


Minimal risk - -

Very good credit standing - -

Good credit standing - -

Sound credit standing - -

Acceptable credit standing - -

Marginal credit standing - -

Weak credit standing / sub-standard - -

Very weak credit standing / doubtful 16 16

Default 162,349 48,173

Unrated

Retail 135,482 33,950

Total 297,847 82,139





Minimal risk - -

Very good credit standing - -

Good credit standing - -

Sound credit standing - -

Acceptable credit standing - -

Marginal credit standing 3 -

Weak credit standing / sub-standard 1 -

Very weak credit standing / doubtful 1 -

Default 269,561 112,700

Unrated 16 -

Retail 151,475 60,269

Total 421,057 172,969

Upon initial recognition of loans and advances, the fair value of collateral is based on valuation techniques commonly used for the corresponding assets. In subsequent periods, the fair value is updated by reference to market price or indexes of similar assets where the update frequency depends on the asset type and the market conditions. The table below stratifies credit exposures from mortgage loans and advances to retail customers by ranges of loan-to-value (LTV) ratio. LTV is calculated as the ratio of the gross amount of the loan to the value of the collateral. The gross amounts exclude any impairment allowances. The valuation of the collateral excludes any adjustments for obtaining and selling the collateral. The value of the collateral for residential mortgage loans is based on the collateral value at origination updated based on changes in house prices indices or individual review where applicable.

in BGN '000 2016 2015

Loan to value (LTV) ratio:

Less than 50% 49,428 151,529

51% to 70% 370,219 205,044

71% to 90% 266,458 223,322

91% to 100% 38,395 41,085

More than 100% 61,268 120,135

Total 785,768 741,116




The table below indicates the finance lease exposure in mortgages classified by Loan-to-value (LTV) ratio. The LTV is calculated as a relation of the gross finance lease exposure to the underlying market value of the mortgage. The impairment is not considered in the gross exposure. The valuation of the collateral does not include future acquisition and realization costs. As at 31 December 2016 the net investment in mortgages amounts to BGN 35,250 thousand and the weighted value of the collateral related to these finance leases amounts to BGN 29,632 thousand.

in BGN '000

2016

Loan-to-Value (LTV) ratio:

Less than 50% 1,259

51% to 70% 861

71% to 90% 7,294

91% to 100% 19,476

More than 100% 9,202

Total 38,092

Concentration of risks of loans and advances by industry sector

The following table breaks down the Group’s main credit exposures at their gross carrying amounts, as categorized by the industry sectors:

in BGN '000 2016 % 2015 %

Manufacturing 1,027,644 24% 864,144 22%

Construction and real estate 219,854 5% 212,624 6%

Transport 155,723 4% 86,499 2%

Trade 810,298 19% 771,883 20%

Other 355,274 9% 406,693 11%

Individuals 1,657,984 39% 1,492,476 39%

hereof mortgages 785,768 19% 741,116 19%

Total 4,226,777 3,834,319

Concentration of risks of loans and advances by customers

As at 31 December 2016 the sum of the ten largest credit exposures to customers amounts to BGN 598,873 thousand, respectively BGN 560,404 thousand as at 31 December 2015.

Exposures to banks

The Bank places free liquidity on the money market and as short-term credit facilities only to credit institutions with very good credit rating. Free liquidity is placed mainly with the mother company or other members of the Raiffeisen banking group.

The Bank has established correspondent banking relations with other credit institutions worldwide and maintains accounts in different currencies with first-class international banks.




Risk from the residual amount of leased assets

Due to its leasing business the Group is exposed to risk from the residual amount of the leased assets. In case of default or seizure of assets under finance lease or expiry of operational lease, the assets’ residual amount may not be recovered by direct sale or subsequent lease.

The Group manages the risk from not recovery of the residual amount in case of finance lease by demanding from customers initial instalments that are determined based on the kind of the asset and whether it is new or second hand. In case of operational lease the Group analyses the expected residual value in order to determine the term of the lease agreement and the regular lease payments.

The table below illustrates the concentration of finance lease receivables by asset kind:

31 December 2016

Asset kind

Net investment in

finance lease %

in BGN '000

Vehicles 109,814 38%

Immovable property 38,092 13%

Trucks 64,091 22%

Agricultural machinery 39,267 14%

Machinery and equipment 21,448 8%

Construction machinery 9,349 3%

Other 5,244 2%

Gross amount 287,305 100%

Allowance for impairment (5,996)

Net amount 281,309

Credit risk from exposure in securities

An analysis of the credit quality of the maximum credit exposure for securities, based on ratings assigned by rating agencies where applicable, is as follows:

Securities held for trading

in BGN '000 2016 2015

Bulgarian government securities

BB+/Ba1 32,326 54,292

Bulgarian corporate bonds

Unrated - 820

Foreign government securities

AAA/Aaa 1,910 -

AA+/Aa1 1,000 -

AA/Aa2 613 -

Total securities held for trading 35,849 55,112




Securities measured at fair value through profit or loss

in BGN '000 2016 2015


Unrated - 3,145

Bulgarian corporate shares

Unrated 2,272 2,259

Securities available for sale

in BGN '000 2016 2015


BB+/Ba1 174,866 147,529


AA+/Aa1 27,765 28,103

AAA/Aaa 74,668 -

Foreign corporate bonds

A+/A1 97,579 -

Foreign corporate shares

A+/A1 3,186 9,927

Securities held to maturity

in BGN '000 2016 2015


BB+/Ba1 506,544 451,488


Unrated 9,830 -

Bulgarian municipality bonds

BB+/Ba1 22,840 27,408


AA+/Aa1 47,564 48,985

Total investment securities 967,114 718,844

B. Liquidity risk

Liquidity risk may be defined as the potential inability of the Group to fund the increases in assets or meet its payment obligations associated with its financial liabilities when they fall due, without incurring unacceptable losses.

With view of conducting effective management and control, the Group distinguishes two dimensions of the liquidity risk - short-term liquidity risk and funding liquidity risk.




Organizational structure for liquidity risk management

By virtue of the liquidity risk management framework, established on Group level, the Assets and Liabilities Committee (ALCO) shall oversee the Group’s liquidity position in light of the risk limits set in place and approve the Funding plans (an annual plan for meeting the funding needs as well as a strategic plan for the next three calendar years). In addition, the Committee strives to ensure compliance with liquidity risk standards and policies, as well as with relevant legal and regulatory requirements.

Liquidity management process and strategy

The Liquidity position of the Group is managed on day-to-day basis and the figures are being reported regularly at ALCO.

The Group’s liquidity management strategy revolves around the aim to timely deliver liquidity resources that are sufficient in amount, quality and structure for meeting obligations, when due, in both normal and stressed conditions without incurring unacceptable losses or risking damage to the Group’s reputation.

The Group does not maintain liquid assets for covering the total amount of all outflows, as historical experience has shown that part of the deposits would not be withdrawn but rolled over. In light of the above, cash inflows and outflows are analyzed under both “going concern” and “stress-test” scenarios, taking into consideration contractual features and behavioral peculiarities. Liquidity gaps are viewed under the perspective of different time horizons and currencies. If a liquidity gap reaches an unacceptable level, relevant escalation procedures are activated and countermeasures are put in place depending on the gap significance and time bucket.

The key elements of the Bank’s Liquidity Strategy are as follows:

- Maintaining a diversified funding base with an adequate proportion of customer deposits (both retail and corporate) and wholesale funding;

- Carrying a portfolio of liquid assets, diversified by currency and maturity;

- Applying an adequate system of tools for measuring and monitoring the Group’s liquidity situation with respect to the internally imposed limitations and regulatory requirements; monitoring of liquidity ratios, maturity mismatches, behavioral characteristics of the Bank’s financial assets and liabilities;

- Dynamic process for carrying out stress tests of the Group’s liquidity position. The latter are subject to continuous redevelopment and improvement in line with the regulatory requirements on both local and European level. They are supplemented by a system of early warning indicators designed to timely identify the emergence of liquidity risk, as well as by action plans to be activated in case of a crisis situation;

- Adequate reporting framework enabling a continuous evaluation of the liquidity

profile and application of relevant corrective actions, if needed;

- Avoiding concentrations on Group of connected customers level and inclusion of

these concentrations as potential outflow on the first day.

Liquidity Stress Tests

The Group performs three types of stress tests with view of capturing its capacity to withstand negative circumstances: market specific, reputational and a combination of the two. The results are reviewed/analyzed on an on-going basis and also are reported to the Managing Board for further countermeasures, if needed.




The stress-testing framework involves monitoring of a system of limits imposed on the Group’s liquidity position. They designate a survival period of at least one month, the latter being translated by a requirement for positive liquidity mismatches over the first 30 days. The liquidity limits are defined on both total currency level as well as for each material currency (BGN, EUR, USD and joint BGN/EUR basis). The stress test results over the first 30 days for BGN and USD have to be positive; the EUR result may be negative up to EUR -100 mn. but given that the joint BGN/EUR is positive.

In accordance with a recommendation issued by the European Central Bank (ECB) towards RBI Vienna, the 30-day focus would be extended over a 90-day horizon for all currency. The latter would capture the additional countermeasures on top of the CBC – potentially ones of the corrective actions stated in the RBBG Recovery Plan.

Liquidity buffer

The Group maintains a Liquidity Buffer composed of cash and core liquid assets to ensure, to the maximum extent possible, an extended survival period. Therefore the Group constantly strives for optimization of the Net liquid assets to the total Group’s liabilities ratio.

For this purpose net liquid assets are considered as including cash and cash equivalents, balances with the Bulgarian national bank, nostro accounts and placements with banks with a remaining maturity up to 7 days, tradable debt securities, issued by central governments and central banks, treasury bills and bonds of the Government of Republic of Bulgaria, tradable debt securities, issued by institutions with first-class credit rating, tradable debt securities, issued by international development banks and international organizations. Liquid assets do not include pledged assets. The amount of the pledged assets as at 31 December 2016 and 31 December 2015 is BGN 229 mn and BGN 304 mn respectively.

The table below illustrates the liquid assets to total attracted funds ratio for the past two years.

2016 2015

Average for the period 36.1% 34.1%

Maximum for the period 39.5% 35.8%

Minimum for the period 33.6% 31.5%

As of 31 December 33.8% 35.4%

Monitoring and reporting take the form of cash flow measurement and projections for the next day, week and month respectively, as these are key periods for liquidity management. The starting point for those projections is an analysis of the contractual maturity of the financial liabilities and the expected collection date of the financial assets.

Unmatched medium term assets, the level and type of undrawn lending commitments, the usage of overdraft facilities and the impact of contingent liabilities such as standby letters of credit and guarantees are also monitored and analyzed.

Funding approach

Sources of liquidity are regularly reviewed by Treasury/ALM Department to maintain a wide diversification by currency, geography, provider, product type and term.

The diversification of wholesale funding is controlled/limited by a special Group-wide concept named “Counterparty Funding Concentration Risk”. It impacts the Stress Test




results and de-incentives the attraction of significant funding from Group of connected customers.

Early warning system

The Group periodically monitors certain liquidity ratios considered to be representative when first signals of liquidity deficiencies occur. The ratios observed cover the following areas - quality of receivables, liabilities dependability, liquid assets tradability, market environment and other qualitative and quantitative ratios.

Cash flows from non-derivative liabilities

The maturity of non-derivative liabilities is expressed as the cash flows payable by the Group under financial liabilities by remaining contractual maturities at the reporting date. The amounts disclosed in the table are the contractual undiscounted cash flows, whereas the Group manages the inherent liquidity risk based on expected undiscounted cash inflows.

Cash flows from derivative liabilities

The Group’s derivatives will be settled on a gross basis and include:

- Foreign exchange derivatives – currency forwards, currency swaps

- Interest rate derivatives – single currency interest rate swaps, cross currency interest rate swaps.




The tables below set out the remaining contractual maturities of the Group’s financial liabilities:

As at 31 December

2015

In BGN '000

Less than 1

month 1-3 months

3 months to

1 year 1-5 years

More than

5 years

Total inflow/

outflow

Carrying

amount

Non derivative

liabilities

Deposits from banks (48,325) - - - - (48,325) 48,325

Deposits from

customers (3,879,186) (330,989) (521,939) (21,946) - (4,754,060) 4,752,846

Borrowings from

banks (3,714) (12,080) (50,112) (188,873) (48,357) (303,136) 298,181

Subordinated

liabilities (2,159) (944) (9,253) (49,323) (395,331) (457,010) 365,457

Other liabilities (7,461) (29,030) (13,555) (2,437) - (52,483) 52,483

Loan commitments - (1,187,086) - - - (1,187,086) -

Total non-derivative

instruments (3,940,845) (1,560,129) (594,859) (262,579) (443,688) (6,802,100) 5,517,292

As at 31 December

2016

In BGN '000

Less than 1

month 1-3 months

3 months to

1 year 1-5 years

More than

5 years

Total inflow/

outflow

Carrying

amount

Non derivative

liabilities

Deposits from banks (31,763) - - - - (31,763) 31,763

Deposits from

customers (3,995,465) (237,368) (487,519) (14,685) - (4,735,037) 4,734,884

Borrowings from

banks (3,453) (36,266) (94,135) (240,058) (19,306) (393,218) 387,662

Subordinated

liabilities (2,020) (845) (8,541) (45,656) (384,559) (441,621) 365,281

Current tax liabilities (33) - - - - (33) 33

Other liabilities (644) (21,936) (13,337) (6,854) - (42,771) 42,771

Loan commitments - (1,270,491) - - - (1,270,491) -

Total non-derivative

instruments (4,033,378) (1,566,906) (603,532) (307,253) (403,865) (6,914,934) 5,562,394

Derivative liabilities

- Foreign exchange

derivatives 6,047

- Outflow (42,116) (77,018) (67,232) (18,110) - (204,476)

- Inflow 41,075 75,308 63,626 17,709 - 197,718

- Interest rate

derivatives

182

- Outflow (32) (64) (287) (1,080) - (1,463)

- Inflow 24 48 217 817 - 1,106

Total derivative

liabilities (1,049) (1,726) (3,676) (664)

- (7,115) 6,229




Derivative liabilities

- Foreign exchange

derivatives 2,413

- Outflow (8,210) (28,418) (51,038) - - (87,666)

- Inflow 7,997 27,730 49,262 - - 84,989

- Interest rate

derivatives 186

- Outflow (20) (40) (181) (925) - (1,166)

- Inflow 19 38 170 882 - 1,109

Total derivative

liabilities (214) (690) (1,787) (43) - (2,734) 2,599

The next table illustrates the carrying amounts of assets and liabilities by remaining

maturities less than and more than 12 months.

In BGN '000 2016 2015

Less than

12 months

More than

12 months

Less than

12 months

More than

12 months

Assets

Cash and balances with the Central

bank 1,044,846 - 1,275,552 -

Trading assets 35,849 - 55,112 -

Derivatives 6,029 289 2,561 186

Loans and advances to banks 243,712 138,894 762,054 18,476

Loans and advances to customers 1,450,074 2,529,601 1,321,184 2,234,175

Investment securities 331,725 635,389 69,552 649,292

Investments in associates - 1,708 - 6,556

Current tax assets 257 - 1,808 -

Property, plant and equipment - 29,753 - 23,878

Intangible assets - 21,359 - 18,292

Other assets 25,918 14,016 7,830 15,664

Deferred tax assets - 1,143 - 1,265

Total assets 3,138,410 3,372,152 3,495,653 2,967,784

Liabilities

Derivatives 5,931 298 2,413 186

Deposits from banks 31,763 - 48,325 -

Deposits from customers 4,720,148 14,736 4,727,617 25,229

Borrowings from banks 132,389 255,273 58,494 239,687

Subordinated liabilities - 365,281 - 365,457

Current tax liabilities 33 - 22 -

Other liabilities 51,725 17,140 55,410 21,069

Total liabilities 4,941,989 652,728 4,892,281 651,628




In the table below is presented the analysis of the financial assets comprising the liquidity reserve that is available to the Group in order to cover outgoing cash-flows on its financial liabilities in case of liquidity crisis:

In BGN '000

Liquid assets 2016 2015

Cash and balances with the Central

bank 1,047,684 1,275,552

Government treasury bills and

investment grade debt securities 636,655 426,626

Nostro accounts and placements with

banks with a remaining maturity up to 7

days 129,349 240,157

Total liquid assets 1,813,688 1,942,335

C. Market risk

In general market risk is the risk from experiencing loss due to unexpected changes in the market factors (interest rates, foreign currency rates, prices etc.) which are influencing in a negative way the value of the assets and/or the entire portfolio. The Group takes on exposure to market risks, which is the risk that the fair value or future cash flows of a financial instrument or the bank’s assets in the portfolio will fluctuate because of changes in market prices. Market risks arise from open positions in interest rate, currency and equity products, all of which are exposed to unexpected and unfavorable market movements and volatility changes of the market factors (interest rates, credit spreads, foreign exchange rates, etc.) and changes in indices and equity prices. The Group separates exposures to market risk into either trading or non-trading portfolios. All marked-to-market instruments are recognized at fair value in the statement of financial position based on quoted bid prices, and all changes in market conditions directly affect net trading income (through trading instruments) or equity value (through available for sale instruments). The Group manages its trading portfolios in accordance with the changes in market conditions, as well as through setting by the management of respective limits for the relative instruments.

Management of Market risk

Exposure to market risk is formally managed in accordance with risk limits set by senior management for buying or selling of financial instruments. Overall authority for market risk is vested in ALCO. Market Risk Management responsible departments on Bank and Group Level are developing detailed risk management policies (subject to review and approval by ALCO and Group Market Risk Committee) and for the day-to-day review of their implementation.




The table below sets out the allocation of assets and liabilities subject to market risk between trading and non-trading portfolios.


In BGN '000 Carrying amount

Trading

portfolios

Non-trading

portfolios

Assets subject to market

risk

Cash and balances with

the Central bank 1,044,846 - 1,044,846

Trading assets 35,849 35,849 -

Derivatives 6,318 6,318 -


banks 382,606 - 382,606


customers 3,979,675 - 3,979,675

Investment securities 967,114 - 967,114

Liabilities subject to

market risk


Deposits from banks 31,763 - 31,763

Deposits from customers 4,734,884 - 4,734,884

Borrowings from banks 387,662 - 387,662

Subordinated liabilities 365,281 - 365,281


In BGN '000 Carrying amount Trading portfolios

Non-trading

portfolios

Assets subject to market

risk


the Central bank 1,275,552 - 1,275,552

Trading assets 55,112 55,112 -



banks 780,530 - 780,530


customers 3,555,359 - 3,555,359

Investment securities 718,844 - 718,844

Liabilities subject to

market risk


Deposits from banks 48,325 - 48,325

Deposits from customers 4,752,846 - 4,752,846

Borrowings from banks 298,181 - 298,181

Subordinated liabilities 365,457 - 365,457




Market risk measurement techniques

Market risk is the risk from experiencing loss or negative effect that unexpected and unfavorable changes in market prices, such as interest rates, equity prices, foreign exchange rates and credit spreads (not relating to changes in the obligor’s/issuer’s credit standing) will affect the Group’s income or the value of its holdings of financial instruments. The objective of the Group’s market risk management is to manage and control market risk exposures within acceptable parameters in connection with the risk appetite and the entire Group’s strategy. Value at risk The Group applies a “value at risk” methodology (VAR) to its trading and non-trading portfolios to estimate the market risk of positions held and the potential losses expected, through appropriate analytical method, supported by empirical conditions and documented analyses. This method is applied consecutively and with a certain level of conservatism, which is usually higher if there is only limited data available. The Group uses VaR Limits for market risk on both total and split by the following risk factors levels: foreign exchange (FX), interest rate risk (IR), basis risk (Bs) and spread risk (SP). The overall structure of VaR Limits is subject to review and approval by ALCO. VaR Limits are allocated to both trading and non-trading portfolios but also on total Bank level as well. VAR is a statistically based estimate of the potential loss on the current portfolio from adverse market movements. It expresses the maximum amount the Group might lose, but only to a certain level of confidence (99%). There is therefore a specified statistical probability (1%) that actual loss could be greater that the VAR estimate. The VAR model assumes a certain “holding period” until positions can be closed (1 day). It also assumes that market moves occurring over this holding period will follow a similar pattern to those that have occurred in the past. The VAR approach used in the Group since the beginning of 2010 is a hybrid one, i.e. both aspects of historical simulation and of a parametric approach are combined and extreme events resulting from a period of stressed risk factors are added. Volatility regimes are taken into consideration via rescaling of historic returns (used volatility is a weighted average of 80% of the recent 20 business days and 20% of the past two years) giving significant stress on the recent market conditions. Actual outcomes are monitored regularly to test the validity of the assumptions and parameters/factors used in the VAR calculation. The use of this approach does not prevent losses outside of these limits, but to a certain extent the application of the hybrid model takes into consideration extreme events of significant market movements. The quality of the VAR model is continuously monitored by back-testing the VAR results on the trading portfolio of the Bank. All back-testing exceptions and any exceptional revenues on the profit and loss sides of the VAR distribution are investigated, and all back-testing results are reported to the Management board.




VAR summary

In BGN '000 (1d, 99 %)

As at 31

December 2016

As at 31

December 2015

Trading portfolio VAR

Diversified 84 116

Hereof interest rate risk 70 113

Hereof spread risk 20 62

Non-trading portfolio VAR

Diversified 1,171 955

Hereof interest rate risk 1,194 882


Total VaR Diversified 1,227 987

Hereof interest rate risk 1,257 847


VaR development during 2016 by risk type

In BGN '000 (1d, 99 %) Average Maximum Minimum

Trading portfolio VAR

Diversified 94 228

38

Hereof interest rate risk 53 169 8

Hereof spread risk 64 201 15

Non-trading portfolio VAR

Diversified 1,191 1,878

757

Hereof interest rate risk 981 1,842 605

Hereof spread risk 620 1,293 206

Total VaR Diversified 1,244 1,910 771

Hereof interest rate risk 995 1,870 609

Hereof spread risk 681 1,436 231

The limitations of the VaR methodology are recognized by supplementing VaR Limits with other position and sensitivity limit structures. In addition the Group uses a wide range of stress tests to model the financial impact of a variety of market scenarios on the trading and non-trading portfolios. The output of the respective simulations and their impact on Group level are reported regularly at ALCO meetings. Stress tests Stress tests provide an indication of the potential size of losses that could arise in extreme conditions. The stress tests include risk factor stress testing, where the worst case scenario stress movements are applied to each risk category; emerging market stress testing, where emerging market portfolios are subject to stress movements; and ad hoc stress testing, which includes applying possible stress events to specific position or regions.




The results of the stress tests are presented and reviewed on ALCO meetings by the Management Board on an on-going basis. The stress testing is tailored to the business and typically uses scenario analysis.

Interest rate risk Interest rate risk is the probable negative influence of the market interest rates on the net interest income, which forms main part of the Group’s financial result. In comparison to the other risks the interest rate risk could be minimized trough the mutual management of assets and liabilities. The policy of the Group to minimize interest rate risk is to grant floating rate loans against the received floating rate external financings. Interest rate risk is also managed through the balanced use of different funding sources (borrowings from other local banks, long-term borrowings from foreign banks, customer deposits etc.), as well as through purposeful credit policy, providing for increasing return. In the current low and negative interest rates’ market environment the Group continues its policy for optimization and willingness to minimize its interest rate risk by introducing possible strategies which will allow it to grant loans with fixed interest rate for a mid-term period having in mind the expectations for keeping the low interest rate market environment in Europe within this period. It is of crucial importance for the Management of the Group to control the interest rate sensitivity of assets and liabilities. Due to the nature of banking an absolute matching in maturities or in periods of re-pricing of contracted interests on financial assets and liabilities is not possible. The Group’s interest rate exposures are monitored and managed by generating interest rate sensitivity reports. The majority of the Group 's interest bearing assets and liabilities are structured to match either short-term assets and short-term liabilities, or long-term assets and liabilities with re-pricing opportunities within one year, or long-term assets and corresponding liabilities whereby re-pricing is performed simultaneously. For most interest-bearing assets and liabilities exists a possibility of re-pricing at a relatively short notice and any interest rate sensitivity gaps are considered immaterial.




The following table indicates the periods in which interest bearing financial assets and liabilities re-price as at 31 December 2016.

In BGN '000

Up to 3

months

From 3

months to 1

year

From 1

year to 5

years

More

than 5

years Total

Assets


banks 276,928 46,906 58,772 - 382,606


customers 3,434,774 133,434 333,972 77,495 3,979,675

Investment securities 101,275 224,992 519,893 115,496 961,656

Total assets 3,812,977 405,332 912,637 192,991 5,323,937

Liabilities

Deposits from banks 31,763 31,763

Deposits from customers 4,248,290 482,154 4,440 - 4,734,884

Borrowings from banks 261,366 95,841 3,912 26,543 387,662

Subordinated liabilities 365,281 - - - 365,281

Total liabilities 4,906,700 577,995 8,352 26,543 5,519,590

Net position (1,093,723) (172,663) 904,285 166,448 (195,653)

The following table indicates the periods in which interest bearing financial assets and liabilities re-price as at 31 December 2015

In BGN '000

Up to 3

months

From 3

months to 1

year

From 1

year to 5

years

More

than 5

years Total

Assets


banks 604,092 176,438 - - 780,530


customers 3,086,759 315,482 108,606 44,512 3,555,359

Investment securities 47,430 9,936 558,566 90,726 706,658

Total assets 3,738,281 501,856 667,172 135,238 5,042,547

Liabilities

Deposits from banks 48,325 - - - 48,325

Deposits from customers 4,245,400 505,116 2,330 - 4,752,846

Borrowings from banks 101,873 173,503 - 22,805 298,181

Subordinated liabilities 365,457 - - - 365,457

Total liabilities 4,761,055 678,619 2,330 22,805 5,464,809

Net position (1,022,774) (176,763) 664,842 112,433 (422,262)




The management of interest rate risk against interest rate gap limits is supplemented by monitoring the sensitivity of the Group’s financial assets and liabilities to various standard and non-standard interest rate scenarios. Standard scenarios that are considered on a monthly basis include a 100 basis point (bp) parallel fall or rise in all yield curves worldwide and a 50 bp rise or fall in the greater than 12-month portion of all yield curves. This analysis is presented in the table below for the year 2016, respectively 2015. Sensitivity of the expected net interest income (Banking book)

+100 bp -100 bp +50 bp -50 bp

2016

parallel

increase

parallel

decrease

parallel

increase

parallel

decrease

after 1 year after 1 year

in BGN '000

as at 31 December (38,902) 38,902 (16,000) 16,000

Average for the period (34,395) 34,395 (14,125) 14,125

Maximum for the period (38,902) 38,902 (16,018) 16,018

Minimum for the period (31,040) 31,040 (12,601) 12,601

+100 bp

-100 bp

+50 bp

-50 bp

2015

parallel

increase

parallel

decrease

parallel

increase

parallel

decrease

after 1 year after 1 year

in BGN '000

as at 31 December (33,271) 33,271 (13,892) 13,892

Average for the period (30,661) 30,661 (12,661) 12,661

Maximum for the period (33,793) 33,793 (14,180) 14,180

Minimum for the period (24,511) 24,511 (9,474) 9,474

Early warning limits To support the operative steering of risk-based limits and structural limits, different boundary values for the limit utilization are defined. Such “early warning limits” serve as a warning signal when risk exposures approach the limit in certain business areas or risk types (usually 70% of the limit) and giving signal to the management of the Group for the situation and discussion of the possible decisions aiming at preventing and/or mitigating the negative effect in order to prevent stop loss limit breach. A violation of these early warning limits leads to intensified monitoring and closer supervision of the respective exposure. Hence these limits are not considered as a separate and independent type of limit but rather serve the purpose of supporting operative approved limits management. Stop-loss limits All Risks (including interest rate risk) are limited effectively through stop loss processes which lead to an automatic reduction in exposure if the portfolio loss exceeds a predefined amount. Such a stop loss limit figuratively truncates the loss distribution at the stop loss level (plus a loss amount for transaction costs for closing open positions). Stop loss limits typically are used in trading book operations but can be employed for




banking book positions as well if a fairly liquid market for these assets exists or if hedging instruments are available. The potential loss will not materialize with its whole amount, as stop loss limits are effectively in place. The Group applies a High Watermark YTD S/L limit with immediate effect has been introduced, which locks the negative effect out of the trading and the daily Mark-to-Market revaluation in certain amount from the highest achieved YTD result for the Trading Portfolio.

Currency risk The Group is exposed to currency risk through transactions in foreign currencies. The Group operates in the main currencies: US dollars, Euro, GB pounds, Swiss francs and others. As a result of the currency Board in place in Bulgaria, the Bulgarian currency (BGN) is pegged to the Euro, therefore currency risk arises mainly from exchange rate Euro/US dollar fluctuations. The Group is not exposed to substantial currency risk due to the fact that it monitors and maintains the proportion between amounts and terms of its US dollar assets and liabilities. The Group’s transactional exposures give rise to foreign currency gains and losses that are recognized in profit or loss. These exposures comprise the monetary assets and monetary liabilities of the Group that are not denominated in Bulgarian leva. Foreign currency position as at 31 December 2016

in BGN '000 In Bulgarian

Levs

EUR Other foreign

currency

Total

Financial assets


the Central bank 891,307 143,937 9,602 1,044,846

Trading assets 6,789 29,060 - 35,849

Derivatives 0 488 5,830 6,318


banks 4,740 199,222 178,644 382,606


customers 2,063,087 1,845,032 71,556 3,979,675


Other assets 35,936 3,793 205 39,934

Total financial assets 3,356,621 2,756,030 343,691 6,456,342

Financial liabilities

Derivatives - 5,841 388 6,229

Deposits from banks 30,965 139 659 31,763

Deposits from customers 2,649,170 1,709,381 376,333 4,734,884

Borrowings from banks - 387,662 - 387,662



Total financial liabilities 2,720,327 2,492,773 381,584 5,594,684

Net position 636,294 263,257 (37,893) 861,658




Foreign currency position as at 31 December 2015

in BGN '000 In Bulgarian

Levs

EUR Other foreign

currency

Total

Financial assets


the Central bank 1,192,511 70,973 12,068 1,275,552

Trading assets 25,721 29,391 55,112

Derivatives 222 2,525 2,747


banks 8,289 440,984 331,257 780,530


customers 1,717,486 1,791,052 46,821 3,555,359

Investment securities 334,181 384,663 - 718,844

Other assets 20,568 2,587 339 23,494

Total financial assets 3,298,756 2,719,872 393,010 6,411,638

Liabilities

Derivatives - 2,568 31 2,599

Deposits from banks 42,022 1,188 5,115 48,325

Deposits from customers 2,608,459 1,732,166 412,221 4,752,846

Borrowings from banks - 298,181 - 298,181



Total financial liabilities 2,686,094 2,434,120 422,949 5,543,163

Net position 612,662 285,752 (29,939) 920,432

D. Capital management

The Group’s objective when managing capital, which is broader concept than the equity on the face of the statement of financial position are:

- To comply with the capital requirements set by the local banking regulator;

- To safeguard the Group’s ability to continue as a going concern so that it can continue to provide returns for shareholders;

- To maintain a strong capital base to support the development of Group’s business

The Bulgarian central bank is the competent authority in the Republic of Bulgaria that is exercising prudential supervision over credit institutions according to Regulation (ЕС) № 575/2013 of the European parliament and of the Council on prudential requirements for credit institutions and investment firms (Basel III), effective from 01 January 2014.

Following the requirements on capital buffers according to Directive 2013/36/ЕС (CRD IV), the management board of the Bulgarian national bank adopted a capital conservation buffer and a systemic risk buffer to be maintained by all local banks as a percentage of their risk weighted assets, as laid down in Ordinance № 8 of the Bulgarian national bank from 24 April 2014 regarding Banks’ capital buffers. In accordance with the ordinance, from 1 January 2016 the BNB shall assess and set the appropriate countercyclical capital buffer rate for banks in the country on a quarterly basis.




Capital conservation buffer

Aim of the buffer – the establishment of a capital conservation buffer is aiming at

avoiding future situations, in which failed banks will need government support, i.e.

taxpayers’ money. This buffer shall provide additional funds in case of recovery and

resolution of credit institutions in crisis conditions;

Level of the buffer – credit institutions shall maintain a capital conservation buffer from

their common equity Tier I capital at the amount of 2.5% of their total risk exposure

amount;

Entry into force – the capital conservation buffer shall be effective with the entry into

force of Ordinance № 8 from 24 April 2014 of the Bulgarian central bank on the capital

buffers of credit institutions.

Systemic risk capital buffer

Aim of the buffer – preservation of the year to date accumulated capital reserves in the

Bulgarian banking system, as well as to prevent and mitigate the effect of long-term

non-cyclical systemic or macro prudential risks, which could cause disruption in the

financial system and serious negative consequences to it;

Level of the buffer –the buffer shall be at the amount of 3% from the total risk exposure

amount of exposures in the Republic of Bulgaria, and in the exercise of the supervisory

judgment by the BNB, it shall apply to exposures in third countries;

Entry into force – the systemic risk buffer shall be effective as of 31 December 2014 and

shall apply to all Bulgarian credit institutions.

Countercyclical capital buffer

Aim of the buffer - the countercyclical capital buffer is a macro prudential instrument

provided for in BNB Ordinance No. 8 on Banks’ Capital Buffers, in accordance with the

requirements of Directive 2013/36/EU. The main purpose of the buffer is to safeguard the

banking system against potential losses, stemming from build-up of cyclical systemic risk

during periods of excessive credit growth;

Level of the buffer – in order to determine the buffer rate, the BNB applies the Basel

Committee on Banking Supervision (BCBS) methodology, contained also in parts I and II

of the Annex to the Recommendation of the European Systemic Risk Board of 18 June

2014 on guidance for setting countercyclical buffer rates (ESRB/2014/1). As of 31

December 2016 the countercyclical capital buffer is set to 0%.

In accordance with art.9, paragraph 1 of the BNB Ordinance No. 8 in relation to art. 39, paragraph 2 of the Law on credit institutions and in line with the Guidelines of the European Banking Authority, the Bulgarian national bank identified 10 Bulgarian banks as other systemic important institutions (OSII), among which is also Raiffeisenbank (Bulgaria) EAD. The level of the OSII capital buffer set by BNB for the Bank is as follows:

2017г. – 0%

2018г. – 0.25%

2019г. – 0.50%

2020г. – 0.75%

http://bnb.bg/bnbweb/groups/public/documents/bnb_law/regulations_capital_buffers_en.pdf

https://www.esrb.europa.eu/pub/pdf/recommendations/2014/140630_ESRB_Recommendation.en.pdf?8da798e5327204709ed22ce2d4125924

https://www.esrb.europa.eu/pub/pdf/recommendations/2014/140630_ESRB_Recommendation.en.pdf?8da798e5327204709ed22ce2d4125924




Basel III introduces the requirement of total capital ratio, core equity tier I capital ratio and tier I capital ratio, as well as the capital requirements for credit, market and operational risks. It defines the minimum required amount, the elements and the structure of own funds of credit institutions and the minimum capital requirements for the risks they undertake.

The capital ratios as percentage of the total risk exposures of credit institutions are defined as follows:

Core equity tier I ratio – 4.5%

Tier I ratio – 6% and

Total capital ratio – 8%

The capital adequacy and the adherence to the regulatory capital requirements are monitored by the Bank’s management.

The Group’s regulatory capital consists of:

- Core tier I capital – ordinary share capital and retained earnings (incl. statutory reserve fund)

- Tier II capital – qualified subordinated debt

The following items are deducted from the capital:

- Accumulated other comprehensive income

- Intangible assets

- IRB shortfall of credit risk adjustments to expected losses

As at December 31, 2016 the Capital base of the Group comprises as follows (unaudited):

in BGN '000

Common equity Tier I items:

- Paid in capital instruments 603,448

- Retained earnings 173,629

- Total deductions from Tier I (25,421)

Tier II capital:

- Subordinated debt eligible for Tier II capital 363,002

- Total deductions from Tier II (927)

TOTAL OWN FUNDS 1,113,731

In compliance with Basel III requirements the Bank is calculating its total risk exposure as a sum of:

- the risk weighted exposure amounts for credit, counterparty credit and dilution risks for its total exposures excluding the risk weighted exposures from its trading portfolios;

- the capital requirement for position, foreign exchange and commodities risk, multiplied by 12.5;




- the capital requirement for operational risk, multiplied by 12.5;

- The amount of capital requirement in respect of the risk associated with credit valuation adjustment for OTC derivative instruments other than credit derivatives recognized to reduce risk-weighted exposure amounts for credit risk, multiplied by 12.5.

Effectively November 01, 2014 the Raiffeisenbank (Bulgaria) EAD has been granted the official permission to apply IRB model in managing and measuring credit risk, according to the requirements of the most contemporary banking regulations, namely the Regulation (ЕС) № 575/2013 of the European parliament and of the Council.

The Group applies the Standardized Approach (TSA) for calculating Operational Risk regulatory capital requirements.

During the financial year the Bank complied with all requirements of regulatory capital and capital buffers and maintained its capital ratios above the required regulatory minimum.

The table below illustrates the Bank’s total risk exposure and capital ratios as of December

31, 2016.

in BGN ‘000

TOTAL RISK EXPOSURE AMOUNT 3,454,356

RISK WEIGHTED EXPOSURE AMOUNTS FOR CREDIT, COUNTERPARTY

CREDIT AND DILUTION RISKS AND FREE DELIVERIES 2,949,343

Standardised approach 325,811

SA exposure classes excluding securitisation positions 325,811

Corporates 182,341

Retail 55,652

Secured by mortgages on immovable property 9,177

Exposures in default 9,540

Other items 69,101

Internal ratings based Approach (IRB) 2,623,532

IRB approaches when neither own estimates of LGD nor

Conversion Factors are used 1,764,016

Institutions 231,083

Corporates - SME 762,118

Corporates - Specialised Lending 41,960

Corporates - Other 728,855

IRB approaches when own estimates of LGD and/or

Conversion Factors are used 854,264

Retail - Secured by real estate SME 123,523

Retail - Secured by real estate non-SME 276,155

Retail - Qualifying revolving 32,615

Retail - Other SME 51,499

Retail - Other non-SME 370,472

Equity IRB 5,252

TOTAL RISK EXPOSURE AMOUNT FOR POSITION, FOREIGN EXCHANGE

AND COMMODITIES RISKS 8,563

Risk exposure amount for position, foreign exchange and

commodities risks under standardised approaches (SA) 8,563

Traded debt instruments 8,563

TOTAL RISK EXPOSURE AMOUNT FOR OPERATIONAL RISK (OpR ) 496,375

OpR Standardised (STA) / Alternative Standardised (ASA)

approaches 496,375




TOTAL RISK EXPOSURE AMOUNT FOR CREDIT VALUATION ADJUSTMENT 75

Standardised approach 75

CET1 Capital ratio 21.76%

Surplus(+)/Deficit(-) of CET1 capital 596,210

T1 Capital ratio 21.76%

Surplus(+)/Deficit(-) of T1 capital 544,395

Total capital ratio 32.24%

Surplus(+)/Deficit(-) of total capital 837,383

4. USE OF ESTIMATES AND JUDGEMENTS

The preparation of these separate financial statements requires management to exercise its judgment in the process of applying the Bank’s accounting policies and the reported value of assets, liabilities, income and expense. Actual results may differ from these estimates and judgments.

Estimates and underlying assumptions are reviewed on an ongoing basis. Revisions to accounting estimates are recognized in the period in which the estimate is revised and in any future periods affected.

Impairment of financial assets

Financial assets accounted for at amortised cost are evaluated for impairment on a basis described in the accounting policy. At each reporting date financial assets are reviewed for the presence of indications of impairment.

The specific counterparty component of the total allowances for impairment applies to financial assets evaluated individually for impairment and is based upon management’s best estimate of the present value of the cash flows that are expected to be received. In estimating these cash flows, management makes judgments about the counterparty’s financial situation and the net realizable value of any underlying collateral. Financial assets carried at amortized cost, are presented in the statement of financial position net of allowances for impairment losses.

Collectively assessed impairment allowances cover credit losses inherent in portfolios of loans and advances with similar credit risk characteristics when there is objective evidence to suggest that they contain impaired loans and advances, but the individually impaired items cannot yet be identified. The Bank’s policy for allocation of collective allowances for impairment losses determines the principles for reducing the statement of financial position amount of a portfolio of loans with similar credit risk characteristics to their recoverable amount as at the reporting date. In assessing the need for collective loss allowances, management considers factors such as credit quality, portfolio size, concentrations and economic factors. In order to estimate the required allowance, assumptions are made to define the way inherent losses are modelled and to determine the required input parameters, based on historical experience and current economic conditions.

The accuracy of the allowances depends on the estimates of future cash flows for specific counterparty allowances and the model assumptions and parameters used in determining collective allowances. In December 2015 Raiffeisenbank (Bulgaria) EAD has introduced internal-rating based model in the calculation of allowance for impairment losses for loans to private individuals and micro entities. Estimates of specific parameters (Historic Default Rate, Loss Given




Default and Credit Conversion Factor) are subject to annual recalculation, following the established internal processes of the Bank for internal-rating models. With this change being in default is the main criteria for the calculation of impairment allowance on collective and individual level.

Determining fair values

Valuation of financial instruments

Fair value is the price that would be received to sell an asset or paid to transfer a liability in

an orderly transaction between market participants at the measurement date. The Group

discloses information on the fair values of those financial assets and financial liabilities, for

which there is available market information and the fair value of which significantly differs

from their carrying amount.

If there is no active market for a certain financial instrument, then the Group determines

fair values by using valuation techniques. The valuation techniques consider recent direct

deals between knowledgeable, willing market participants (if such exist), information

about current fair values of similar financial instruments, analysis of discounted cash flows,

as well as models with option prices. The chosen valuation technique maximises the use of

observable market data, relies as less as possible on specific for the Group valuations,

includes factors that market participants would take into account when determining the

price. The valuation technique is compatible with the accepted methodology for pricing

of financial instruments. The information used by the valuation technique adequately

represents the market expectations and valuations of the risk factors and the yield

inherent for the financial instrument. The Group verifies the valuation techniques and tests

their validity by using prices from observable current market transactions with the same

financial instrument or based on other observable market data.

The best evidence of the fair value of a financial instrument at initial recognition is normally

the transaction price – i.e. the fair value of the consideration given or received, except for

transactions, where the fair value of the financial instrument is evident from the

comparison with other similar observable market transactions with the same financial

instrument, or could be based on valuation techniques that uses only data from

observable markets. When the transaction price is the best evidence of the fair value of

the financial instrument at initial recognition, then the financial instrument is initially

recognised at its transaction price and each difference between that price and the value

derived from a valuation technique is recognised subsequently in profit or loss on an

appropriate basis over the life of the instrument but not later than when the valuation is

wholly supported by observable market data or the transaction is closed out.

Assets and long positions are measured at a bid price and liabilities and short positions at

an ask price. Fair values reflect the credit risk of the instrument and include adjustments to

take account of the credit risk of the Group and the counterparty where appropriate. Fair

value estimates obtained from models are adjusted for any other factors, such as liquidity

risk or model uncertainties to the extent that the Bank believes that a third party market

participant would take them into account in pricing a transaction.

The Group measures fair values using the following fair value hierarchy, which reflects the

significance of the inputs used in making the measurement:

Level 1: inputs that are quoted market price (unadjusted) in active markets for

identical financial instruments.




Level 2: inputs other than quoted prices included within Level 1 that are observable

either directly (i.e. as prices) or indirectly (i.e. derived from prices). This category includes

instruments valued using: quoted market prices in active markets for similar instruments;

quoted prices for identical or similar instruments in markets that are considered less than

active; or other valuation techniques in which all significant inputs are directly or indirectly

observable from market data.

Level 3: inputs that are unobservable. This category includes all instruments for which

the valuation technique includes inputs not based on observable data and the

unobservable inputs have a significant effect on the instrument’s valuation. This category

includes instruments that are valued based on quoted prices for similar instruments for

which significant unobservable adjustments or assumptions are required to reflect

differences between the instruments.

The Group uses widely recognized valuation models for determining the fair value of common and simpler financial instruments, like interest rate and currency swaps that use only observable market data. For these financial instruments market conditions enable the use of valuation models.

For more complex instruments, the Bank uses proprietary valuation models, which usually are developed from recognized valuation models. Some or all of the significant inputs into these models may not be observable in the market, and are derived from market prices or rates or are estimated based on assumptions. When entering into a transaction, the financial instrument is recognized initially at the transaction price, which is the best indicator of fair value, although the value obtained from the valuation model may differ from the transaction price. This initial difference, usually an increase, in fair value indicated by valuation techniques is recognized in profit or loss depending upon the individual facts and circumstances of each transaction and not later than when the market data becomes observable.

The value produced by a model or other valuation technique is adjusted to allow for a number of factors as appropriate, because valuation techniques cannot appropriately reflect all factors market participants take into account when entering into a transaction. Valuation adjustments are recorded to allow for model risks, bid-ask spreads, liquidity risks, as well as other factors. Management believes that these valuation adjustments are necessary and appropriate to fairly state financial instruments carried at fair value on the Bank’s statement of financial position, so that they are as close as possible to a market price, which would be determined on an arm’s length principle between not related parties.

The determination of fair values is monitored by the Group’s “Risk controlling Division” and is independent of trading and investment operations. Specific controls include: verification of observable pricing inputs and re-performance of model valuations; a review and approval process for new models and changes to models.

The tables below analyse financial instruments measured at fair value by the level in the

fair value hierarchy into which the fair value measurement is categorised:




December 31, 2016

in BGN '000 Level 1 Level 2 Level 3 Total

Assets

Trading assets 35,849 - - 35,849

Derivatives - 6,318 - 6,318


Liabilities


December 31, 2015

in BGN '000 Level 1 Level 2 Level 3 Total

Assets

Trading assets 54,292 820 - 55,112



Liabilities


Derivatives are classified within level 2, because they are OTC and their fair value is calculated using observable inputs for similar financial instruments traded on active markets.

The following tables set out the fair values of financial instruments not measured at fair value and analyses them by the level in the fair value hierarchy into which each fair value measurement is categorized:

December 31, 2016

in BGN '000 Level 1 Level 2 Level 3 Fair value

Total

carrying

amount

Assets


central banks - - 1,044,846 1,044,846 1,044,846


banks - - 384,672 384,672 382,606


customers - - 4,081,873 4,081,873 3,979,675

Investment securities 561,541 32,670 - 594,211 586,778

Liabilities

Deposits from banks - - 31,763 31,763 31,763

Deposits from customers - - 4,735,173 4,735,173 4,734,884

Borrowings from banks - - 389,005 389,005 387,662

Subordinated liabilities - - 365,281 365,281 365,281




December 31, 2015

in BGN '000 Level 1 Level 2 Level 3 Fair value

Total

carrying

amount

Assets


central banks - - 1,275,552 1,275,552 1,275,552

Loans and advances to banks - - 780,639 780,639 780,530


customers - - 3,286,515 3,286,515 3,555,359

Investment securities 512,511 27,408 - 539,919 527,882

Liabilities

Deposits from banks - - 48,325 48,325 48,325

Deposits from customers - - 4,754,073 4,754,073 4,752,846

Borrowings from banks - - 303,175 303,175 298,181

Subordinated liabilities - - 365,457 365,457 365,457

Cash and balances with central banks are classified within level 3 as they cannot be related to an active market or to other observable inputs. It is assumed that the carrying amount is their fair value.

The fair value of loans and advances to banks is determined considering the nature of the receivable. When it is a short-term money market placement of liquid funds it is assumed that the carrying amount is the fair value. For these instruments there is no active market and observable inputs to determine their fair value.

Loans and advances to customers are classified within level 3 as there is no active market for such financial instruments. The fair value of loans and advances to customers that are not in default is obtained by valuation techniques based on discounted expected cash flows. The discount factor used is the rate of return of a risk free investment, adjusted for the probability of default and the expected loss. For exposures in default, as well as for short-term receivables and overdrafts the Group assumes that their fair value corresponds to their carrying amount. The calculation of fair value of loans and advances is sensitive to changes in the adjustment for probability of default and expected loss, which is in fact the main unobservable input. When probability of default increases, the fair value will decrease and vice versa when probability of default decreases.

For liabilities measured at amortized cost there is also lack of observable inputs, because of the absence of an active market for such financial instrument. Their fair value is obtained by using valuation techniques based on expected discounted cash flows. The discount factor used for fixed interest rate liabilities is the rate of return of a risk free investment, increased with the liquidity premium for the respective maturity band. The discount factor for floating rate liabilities is only the liquidity premium. The liquidity premium is based on the CDS of Bulgaria for the respective maturity band. Short-term deposits from banks are not discounted and it is assumed that the carrying amount is their fair value.




5. CLASSIFICATION OF FINANCIAL ASSETS AND LIABILITIES

The following tables illustrate the categories of financial assets and financial liabilities that

are recognized in the statement of financial position of the Group.

December 31, 2016

in BGN '000

Held for

trading

At fair

value

through

profit or

loss

Available

for sale

Held to

maturity

Loans

and

advances

Other

financial

liabilities

Total

carrying

amount

Assets

Cash and balances

with the Central bank - - - - 1,044,846 - 1,044,846

Trading assets 35,849 - - - - - 35,849

Derivatives 6,318 - - - - - 6,318

Loans and advances

to banks - - - - 382,606 - 382,606

Loans and advances

to customers - - - - 3,979,675 - 3,979,675

Investment securities:

At fair value through

profit or loss - 2,272 - - - - 2,272


OCI - - 378,064 - - - 378,064

At amortized cost - - - 586,778 - - 586,778

Total Assets 42,167 2,272 378,064 586,778 5,407,127 - 6,416,408

Liabilities

Derivatives 6,229 - - - - - 6,229

Deposits from banks - - - - - 31,763 31,763

Deposits from

customers - - - - - 4,734,884 4,734,884

Borrowings from banks - - - - - 387,662 387,662

Subordinated liabilities - - - - - 365,281 365,281

Total Liabilities 6,229 - - - 5,519,590 5,525,819




December 31, 2015

in BGN '000

Held for

trading

At fair

value

through

profit or

loss

Available

for sale

Held to

maturity

Loans

and

advances

Other

financial

liabilities

Total

carrying

amount

Assets

Cash and balances

with the Central bank - - - - 1,275,552 - 1,275,552

Trading assets 55,112 - - - - - 55,112

Derivatives 2,747 - - - - - 2,747

Loans and advances

to banks - - - - 780,530 - 780,530

Loans and advances

to customers - - - - 3,555,359 - 3,555,359

Investment securities:


profit or loss - 5,404 - - - - 5,404


OCI - - 185,559 - - - 185,559

At amortized cost - - - 527,881 - - 527,881

Total Assets 57,859 5,405 185,558 527,881 5,611,441 - 6,388,144

Liabilities

Derivatives 2,599 - - - - - 2,599

Deposits from banks - - - - - 48,325 48,325

Deposits from

customers - - - - - 4,752,846 4,752,846

Borrowings from banks - - - - - 298,181 298,181

Subordinated liabilities - - - - - 365,457 365,457

Total Liabilities 2,599 - - - - 5,464,809 5,467,408

6. SEGMENT ANALYSIS

The Group operates in the following main segments:

- Retail customers – incorporating private banking services, private customer current accounts, savings, deposits, credit and debit cards, consumer loans and mortgages;

- Large corporate – incorporating current accounts, deposits, overdraft facilities, loan and other credit facilities, real estate financing, foreign currency and derivative products;

- SMEs - incorporating current accounts, deposits, overdraft facilities, loan and other credit facilities, micro lending, foreign currency and derivative products;

- Proprietary business – incorporating business transactions conducted on own account and risk of the Bank that are originated from managing market risk positions like FX-dealing, securities and derivatives trading, money market trading, liquidity management and funding, strategic positioning (investment portfolio), interest rate gapping (maturity transformation).




- Segment “Other” includes cash, capital and reserves, dividends received and other assets and liabilities and corresponding results reflected in segment profit or loss, which cannot be distributed in the other segments.

- Segment results incorporate internal funds transfer pricing.


In BGN '000

Retail

customers

Large

corporates

and

budgetary

companies SMEs

Proprietary

business Other Total

Segment operating

income 147,803 77,010 89,385 10,418 3,210 327,826

Hereof net interest

income 101,362 52,426 56,740 3,620 (129) 214,017

Hereof net fee and

commission income 33,176 18,313 26,923 1,131 (498) 79,046

Segment assets 1,459,746 1,725,368 836,008 2,266,948 222,492 6,510,562

Segment liabilities 2,721,032 1,111,696 902,156 427,530 432,303 5,594,717

Impairment charge (10,567) 4,217 5,255 3 - (1,092)

Administrative expenses and other operating

expenses (80,311) (34,728) (50,283) (2,202) (5,360) (172,884)

Profit before tax 56,925 48,295 44,358 8,219 (3,947) 153,850


In BGN '000

Retail

customers

Large

corporates

and

budgetary

companies SMEs

Proprietary

business Other Total

Segment operating

income 136,285 73,531 88,877 3,330 5,293 307,316

Hereof net interest

income 101,796 48,388 58,959 606 3,316 213,066

Hereof net fee and

commission income 31,687 20,823 25,973 - (1,449) 77,034

Segment assets 1,360,512 1,462,559 732,288 2,676,153 231,925 6,463,437

Segment liabilities 2,652,515 1,238,271 862,179 535,931 255,013 5,543,909

Impairment charge (36,002) (14,067) (10,780) (4) - (60,853)

Administrative expenses and other operating

expenses (81,950) (33,478) (48,032) (3,705) (9,858) (177,023)

Profit before tax 18,333 25,986 30,065 (379) (4,565) 69,440




7. NET INTEREST INCOME

In BGN '000 2016 2015

Interest income

Loans and advances to banks 3,156 1,502

Loans and advances to customers 216,781 229,286

Investment securities 15,847 14,496

Negative interest from financial liabilities 400 -

Total interest income 236,184 245,284

Interest expense

Deposits from banks (93) (306)

Deposits from customers (3,906) (16,880)

Long-term borrowings (3,871) (2,236)

Subordinated liabilities (11,714) (12,571)

Negative interest from financial assets (2,583) (225)

Total interest expense (22,167) (32,218)

Net interest income 214,017 213,066

Recognition of interest income is ceased when payments on interest or principal are past due more than 90 days. Subsequently interest income is recognized only upon real payment. Interest income begins again to be accrued on-balance in case all past due payments are settled.

For 2016 interest income on impaired loans amount to BGN 15,309 and respectively BGN 18,580 for 2015.




8. NET FEE AND COMMISSION INCOME

In BGN '000 2016 2015

Fee and commission income

Payment transactions 25,811 25,690

Card transactions 30,610 29,329

Cash transactions 7,335 7,617

Opening and maintenance of accounts 13,974 11,810

Other loan fees 3,317 2,877

Documentary transactions 3,583 3,827

Securities business 826 1,017

Asset management 958 1,841

Other 2,031 2,273

Total fee and commission income 88,445 86,281

Fee and commission expense

Payment transactions (2,440) (2,597)

Card operations (domestic and foreign card

operators) (13,043) (12,187)

Guarantees and loans (1,332) (955)

Securities business (124) (103)

Other (42) (40)

Total fee and commission expense (16,981) (15,882)

Net fee and commission income 71,464 70,399

9. NET TRADING RESULT

In BGN '000 2016 2015

Debt securities 521 90

Foreign exchange 16,064 14,447

Net trading income 16,585 14,537

Fixed income trading comprises of realized and unrealized dealers margins from changes

in market prices of Government treasury bills and corporate bonds.

Trading result from foreign exchange represents the net result arising from purchases and

sales of foreign currencies, gains arising from the translation of assets and liabilities,

denominated in foreign currencies into Bulgarian leva, as well as the revaluation result of

precious metals.




10. NET RESULT FROM DERIVATIVES

In BGN '000 2016 2015

Foreign exchange instruments 12 104

Interest rate instruments (57) 6

Net result from derivatives (45) 110

Foreign exchange instruments represent FX forwards and cross currency swaps. Interest

rate derivative instruments are interest rate swaps.

11. NET RESULT FROM INVESTMENTS

In BGN '000 2016 2015

Net valuation result (1,187) 70

Net gains/(losses) on realization of

investments 14,384 (914)

Net result from investments 13,197 (844)

12. ADMINISTRATIVE EXPENSES

Administrative expenses

2016 2015

In BGN '000

Personnel expenses (75,175) (70,905)

Materials and services (67,174) (63,913)

Depreciation and amortization charge (12,134) (11,333)

Annual contribution to the Bulgarian

Resolution Fund (6,468) (7,099)

Annual contribution in Bulgarian Deposit

Insurance Fund (8,422) (20,121)

Total administrative expenses (169,373) (173,371)

Personnel expenses include salaries, social and health security contributions under the requirements of the local legislation.

In 2016 the cost for audit, legal and advisory services amounts to BGN 220 thousand (2015: BGN 162 thousand).




13. OTHER OPERATING EXPENSES

In BGN '000 2016 2015

Impairment of assets acquired from collateral (928) (121)

Other (2,583) (3,531)

Total (3,511) (3,652)

14. NET IMPAIRMENT LOSS ON LOANS AND ADVANCES

Impairment Allowance 2016 2015

In BGN '000

Balance as аt January 1 278,960 300,833

Change in consolidation group 10,863 -

Additional allowances for impairment losses 84,328 117,423

Reversals (72,177) (40,967)

Written off receivables (54,873) (98,329)

Balance as at December 31 247,101 278,960

2016 2015

In BGN '000

Additional allowances for impairment (88,719) (118,562)

Reversal of write downs 72,526 41,828

Recoveries from non-performing loans

previously written off 15,101 15,881

Net impairment loss on loans and advances (1,092) (60,853)

The net impairment loss on loans and advances includes also the impairment losses for credit risk stemming from the Group’s irrevocable commitments on contingent liabilities. Impairment loss for commitments and contingent liabilities amount to BGN 4,041 thousand for 2016 and BGN 279 thousand for 2015 respectively.




The following tables illustrate the breakdown of impairment losses into individual and

collective allowances for impairment.

Individual allowances for impairment

2016 2015

In BGN '000

Balance as it January 1 248,117 289,167


Charge for the period 66,541 91,396

Reversals (54,179) (34,117)

Write-offs (54,873) (98,329)


Collective allowances for impairment

2016 2015

In BGN '000

Balance as it January 1 30,843 11,666

Change in consolidation group 759 -

Charge for the period 17,789 26,027

Reversals (17,998) (6,850)


Total 247,101 278,960

15. TAX

2016 2015

In BGN '000

Current tax (expense) (14,860) (6,816)

Deferred tax (expense)/income related to origination and

reversal of temporary differences (222) (30)

Total tax (expense)/income (15,082) (6,846)

Current income tax expense represents the amount of corporate tax due under Bulgarian law. Deferred tax income or expense results from the change in the carrying amounts of deferred tax assets and deferred tax liabilities.




The relationship between tax expense and accounting profit is as follows:

2016 2015

In BGN '000

Accounting profit 153,850 69,440

Tax at the applicable tax rate (10% for 2015, 10% for

2016) (15,385) (6,944)

Tax effect on permanent differences 303 98

Total tax expense (15,082) (6,846)

Effective tax rate 9.80% 9.86%

2016 2015

In BGN '000

Other comprehensive income (10,292)

10,206

Tax at the applicable tax rate (10% for 2015, 10% for

2016) 1,029

(1,021)

Tax expense in OCI 1,029 (1,021)

Reported deferred tax liabilities at December 31, 2016 and 2015 comprise the following:

In BGN '000 Assets Liabilities

Net

(Assets)/Liabilities

2016 2015 2016 2015 2016 2015

Fixed assets - - 1,442

822 1,442 822

Unused leave of personnel (447) (411) - - (447) (411)

Provisions for employee

remuneration (1,088) (864) - - (1,088) (864)

Other provisions (548) (571) - - (548) (571)

Investments - - 162 162 162 162

Impairment of assets

acquired from collateral (420)

(295) - - (420) (295)

Impairment of investments (120) - - - (120) -

Tax loss (124) (108) - - (124) (108)

Net (Assets)/Liabilities (2,748) (2,249) 1,604 984 (1,143) (1,265)




Deferred taxes are calculated on all temporary differences using a principal tax rate of

10%.

Movements in temporary differences during the year are recognized in statement of

comprehensive income on the following items:

Movements during the year

Net tax (assets) / liabilities 2015 Changes 2016

In BGN '000

comprehensive

income -

loss/(profit)

Fixed assets, net 822 620 1,442

Unused leave of personnel (411) (36) (447)

Provisions for employee

remuneration (864) (224) (1,088)

Other provisions (571) 23 (548)

Investments 162 - 162

Impairment of assets

acquired from collateral (295) (125) (420)

Impairment of investments - (120) (120)

Tax loss (108) (16) (124)

Change in consolidation

group - 100 -

(1,265) 222 (1,143)

16. OTHER COMPREHENSIVE INCOME

In BGN '000 2016 2015

Items that will never be reclassified to profit or loss

Remeasurements of defined benefit plans

23 (275)

Items that will be reclassified to profit or loss

Changes in fair value of financial assets available

for sale

3,936 10,206

Tax effect on other comprehensive income

(394) (1,021)

Reclassified to profit or loss (14,228) -

Tax effect on other comprehensive income 1,423 -

Other comprehensive income

(9,240) 8,910

The changes in fair value of assets available for sale in 2015 represent mainly the expected

cash proceeds from the sale of 100% of the issued and outstanding share capital of Visa

Europe Limited (“Visa Europe”) to Visa Inc. The Bank is a principal member of Visa Europe

and its share of the up-front consideration relating to the proposed sale of the issued and

outstanding share capital of Visa Europe to Visa Inc. is calculated based on its

contribution to Visa Europe’s business.




After all regulatory approvals were obtained the deal was finalized in 2016 and the Bank

received income to the amount of BGN 15.2 mn (of which BGN 3.8 mn was received in the

form of VISA Inc. class C shares).

17. CASH AND BALANCES WITH THE CENTRAL BANK

In BGN '000 2016 2015

Cash on hand 102,329 101,427

ATM cash 54,045 55,371

Balances with Central Banks 888,472 1,118,754

Total 1,044,846 1,275,552

Balances with Central Banks include the current account with the Bulgarian national bank, used for direct participation in the money and treasury bills markets and for settlement purposes, as well as the accounts for holding the obligatory minimum reserves. The current account balances are also eligible to cover the required by the Bulgarian national bank minimum reserves.

18. TRADING ASSETS

In BGN '000 2016 2015

Bulgarian government securities 32,326 54,292

Bulgarian corporate bonds - 820

Foreign government securities 3,523 -

Total trading assets 35,849 55,112

19. DERIVATIVES

The Group uses the following derivative instruments for both hedging and non-hedging purposes. Currency forwards represent commitments to purchase-sale of foreign and domestic currency, including undelivered spot transactions. Currency and interest rate swaps are commitments to exchange one set of cash flows for another. Swaps result in an economic exchange of currencies or interest rates (for example fixed interest for floating rate) or a combination of all these (i.e. cross currency interest rate swaps). Usually for such deals no exchange of principal takes place. The Group’s credit risk represents the potential cost to replace the swap contracts if counterparties fail to fulfil their obligations. The risk is monitored on an ongoing basis with reference to the current fair value, a proportion of the notional amount of the contracts and the liquidity of the market. To control the level of credit risk taken, the Group assesses counterparties using the same techniques as for its lending activities.




The following table indicates all derivative instruments held by the Group.

in BGN '000

Contract

/notional Fair values

amount Assets Liabilities


Currency forwards 396,689 6,111 6,040

Forex swaps 40,191 37 7

Interest rate swaps 19,599 170 182

456,479 6,318 6,229


Currency forwards 191,845 2,545 2,413

Forex swaps 30,967 16 -

Interest rate swaps 25,329 186 186

248,141 2,747 2,599

20. LOANS AND ADVANCES TO BANKS

in BGN '000 2016 2015

Money market deposits

Domestic commercial banks 66,581 64,488

Foreign commercial banks 93,774 603,887

160,355 668,375

Loans to banks

Local commercial banks 17 -


166,378 58,778

Nostro accounts

Domestic commercial banks 2,857 2,885


55,873 53,377

Total 382,606 780,530




21. LOANS AND ADVANCES TO CUSTOMERS

in BGN '000 2016 2015

Individual (retail customers):

- Overdrafts 4,078 4,042

- Credit cards 55,877 59,478

- Consumer loans 669,495 641,337

- Mortgages 785,768 741,116

- Finance lease 22,835 -

1,538,052 1,445,973

Corporate entities:

- Large corporates 1,800,772 1,582,760

hereof finance lease 187,009 -

- SMEs 887,953 805,586

hereof finance lease 76,023 -

2,388,346 2,492,098

Gross loans and advances 4,226,777 3,834,319

Less: allowance for impairment (247,102) (278,960)

Net 3,979,675 3,555,359

Net investment in finance lease

The net investment in finance lease represents the gross investment in finance lease less

the unrealized finance income and less accumulated impairment.

2016

in BGN '000

Remaining maturity less than 1 year 34,437

Remaining maturity 1 to 5 years 241,885

Remaining maturity more than 5 years 36,882

Gross investment in finance lease 313,204

Unrealized finance income (25,899)

Minimum lease payments 287,305

Impairment (5,996)

Net investment in finance lease 281,309




22. INVESTMENT SECURITIES

A. Securities at fair value through profit or loss

In BGN ‘000 2016 2015

Bulgarian corporate bonds - 3,145

Bulgarian corporate shares 2,272 2,259

2,272 5,404

B. Securities available for sale

In BGN ‘000 2016 2015

Bulgarian government bonds 174,866 147,529

Foreign government bonds 102,433 28,103

Foreign corporate bonds 97,579 -

Foreign corporate shares 3,186 9,927

378,064 185,559

C. Securities held to maturity

In BGN ‘000 2016 2015

Bulgarian government bonds 506,544 451,488

Bulgarian corporate bonds 9,830 -

Bulgarian municipal bonds 22,840 27,408

Foreign government bonds 47,564 48,985

586,778 527,881

Total Investment securities 967,114 718,844




23. PROPERTY, PLANT AND EQUIPMENT

Computer

Equipment

Office

reconstructions In BGN ‘000 Total

Premises

Office

Furniture

Motor

Vehicles

Cost

January 1, 2016 133,278 6,057 42,896 49,469 1,202 33,654

Additions 11,245 - 5,155 3,499 558 2,032

Change in

consolidation group 2,680 286 280 102 2,012 -

Write offs (11,990) - (4,025) (4,554) (552) (2,859)

December 31, 2016 135,213 6,343 44,306 48,515 3,220 32,827

Accumulated

Depreciation

January 1, 2016 109,400 2,196 36,069 41,553 180 29,402

Charge for the

period 6,628 244 2,719 1,998 587 1,079

Depreciation of

write offs (11,809) - (4,021) (4,527) (403) (2,858)

Change in

consolidation group 1,241 - 221 73 947 -

December 31, 2016 105,460 2,440 34,988 39,097 1,311 27,624

Net Book Value

December 31, 2016 29,753 3,903 9,318 9,418 1,910 5,204

Cost

January 1, 2015 134,735 6,498 41,046 51,348 166 35,677

Additions 13,200 - 3,733 5,101 1,133 3,233

Write offs (14,657) (441) (1,883) (6,980) (97) (5,256)

December 31, 2015 133,278 6,057 42,896 49,469 1,202 33,654

Accumulated

Depreciation

January 1, 2015 116,996 2,037 35,833 45,886 150 33,090

Charge for the

period 6,715 259 2,121 2,640 127 1,568

Depreciation of

write offs (14,311) (100) (1,885) (6,973) (97) (5,256)

December 31, 2015 109,400 2,196 36,069 41,553 180 29,402

Net Book Value

December 31, 2015 23,878 3,861 6,827 7,916 1,022 4,252

Net Book Value

January 1, 2015 17,739 4,461 5,213 5,462 16 2,587




24. INTANGIBLE ASSETS

In BGN ‘000 Total Software Licences

Cost

January 1,2016 63,630 63,275 355

Additions 8,465 8,465 -

Write offs (81) (81) -

Change in

consolidation

group 1,041 1,041 -

December 31, 2016 73,055 72,700 355

Accumulated

amortization

January 1,2016 45,338 44,983 355

Charge for the

period 5,502 5,501 -

Amortization of

write offs (34) (34) -

Change in

consolidation

group 891 891 -

December 31, 2016 51,697 51,342 355

Net Book Value

December 31,2016 21,359 21,359 -

Cost

January 1,2015 50,287 49,932 355

Additions 13,412 13,412 -

Write offs (69) (69) -

December 31, 2015 63,630 63,275 355

Accumulated

amortization

January 1,2015 40,785 40,430 355

Charge for the

period 4,618 4,618 -

Amortization of

write offs (65) (65) -

December 31, 2015 45,338 44,983 355

Net Book Value

December 31,2015 18,292 18,292 18,292

Net Book Value

January 1, 2015 9,502 9,502 -




25. OTHER ASSETS

in BGN ‘000 2016 2015

Prepayments and other deferrals 19,780 12,028

Repossessed collateral 5,858 3,793

Other 14,296 7,673

Total 39,934 23,494

The table below indicates the movement of assets acquired from collateral.

in BGN ‘000 2016 2015

Balance as at 1 January 3,793 4,015

Acquisitions 4,906 1,022

Disposals (5,135) (1,123)

Write-down (938) (121)


Balance as at 31 December 5,858 3,793

26. DEPOSITS FROM BANKS

in BGN ‘000 2016 2015

Current accounts

Domestic commercial banks 839 6,446


Total 31,763 48,325




27. DEPOSITS FROM CUSTOMERS

in BGN ‘000 2016 2015

Large corporate customers

and budget entities

- Current accounts 1,076,093 1,141,200

- Term deposits 35,602 96,950

1,111,695 1,238,150

SMEs

- Current accounts 851,826 802,072

- Term deposits 50,330 60,108

902,156 862,180

Retail customers

- Current accounts 1,381,943 1,080,389

- Term deposits 1,339,090 1,572,127

2,721,033 2,652,516

Total 4,734,884 4,752,846

28. BORROWINGS FROM BANKS

Borrowings from banks include long-term loans attracted from international financial

institutions for financing small- and medium-sized companies in the field of environmental

protection, energy savings, industry, services and tourism as well as municipalities and

private individuals.

To finance its credit activities, the Group also attracts syndicated and other loans from

foreign credit institutions.

in BGN ‘000 2016 2015

Credit lines from International financial

institutions 205,348 245,183

Other borrowings from foreign banks 152,976 52,998

Borrowings from local banks 29,337 -

Total 387,662 298,181

29. SUBORDINATED LIABILITIES

As at December 31, 2016 the subordinated liabilities comprise:

u) Debt-capital hybrid instrument in the amount of BGN 177,981 thousand (carrying

amount BGN 178,372 thousand), attracted by the Bank in 2001. The repayment of the

debt is not bound by any maturity. Management believes that the use of this instrument




will be for a term of over 5 years.

v) Subordinated debt in the amount of BGN 185,022 thousand (carrying amount BGN

186,910 thousand), attracted by the Bank in 2013 and 2014 with an original maturity of 10

years.

The Bank received the permission of the Bulgarian Central Bank to treat these funds as

supplementary capital reserve and to increase its capital base for regulatory purposes.

30. OTHER LIABILITIES

In BGN '000 2016 2015

Transfers in process 18,681 21,604

Provisions for employees’ remuneration 10,794 8,656

Provisions for unused paid leave 4,465 4,085

Provisions for defined contribution plans 1,597 1,356

Impairment losses on credit commitments 4,871 1,521

Other payables 28,457 39,257

Total 68,865 76,479

Transfers in process represent customers’ money transfer orders with value date after 31

December 2016.

The Group recognizes a provision for unused paid leave, which is the undiscounted

amount of the expected short-term income of its employees for the work performed

during the current period.

Provision is recognized also for other liabilities to its employees, such as accrued but not

paid remuneration related to performance, according to Management’s assessment for

the achieved results and goals during the financial year.

Obligations under defined benefit plans

The provision for retirement compensation as at 31 December 2015 amounts to BGN 1,356

thousand. The estimated amount of the liability is based on an actuarial report, which was

prepared based on the following actuarial assumptions:

Discount rate: 2,5%;

Retirement date: in accordance with regulations on length of service and age.




Movement in the present value of the defined benefit obligations

In BGN '000 2016 2015

Defined benefit obligations at 1 January 1,356 923

Benefits paid by the plan (50) (37)

Current service cost 223 154

Interest expense 44 41

Actuarial (gains) losses for the period (23) 275

Change in consolidation group 47 -

Defined benefit obligations at 31 December 1,597 1,356

The current service costs and interest expense are recognized in personnel expenses in

profit or loss. Actuarial (gains) losses for the period are recognized in other.

31. EQUITY

Share capital

As of December 31, 2016 the registered and fully paid-in capital of the Group comprised

of 603,447,952 registered shares with a par value of BGN 1 each.

Statutory reserve

Statutory reserves comprise amounts appropriated for purposes defined by the local legislation. Under the Bulgarian Commercial code, the Group is required to set aside one tenth of its profit in a statutory reserve until it reaches at least 10% of its equity.

Retained earnings

The Group presents under retained earnings section all distributable reserves in excess of the statutory reserves.

Fair value reserve

The fair value reserve comprises the cumulative net change in the fair value of available-for-sale financial assets, until the assets are derecognized or impaired.

32. COMMITMENTS AND CONTINGENT LIABILITIES

The Group provides financial guarantees and letters of credit to guarantee the performance of customers to third parties. They represent off-balance financial instruments, being by nature credit substitutes, which engage the Group and expose it to credit risk.

The contractual amounts of commitments and contingent liabilities are set out in the following table by category. The amounts reflected in the table for guarantees and letters of credit represent the maximum accounting loss that would be recognized at the reporting date if counterparties failed completely to perform as contracted.




In BGN '000 2016 2015

Letters of guarantee and letters of credit issued 313,897 262,002

hereof to banks 2,828 7,572

Unused credit lines 1,270,491 1,187,086

hereof to banks 43,407 14,906

Total 1,584,388 1,449,088

The Group allocates provisions to cover its credit risk from commitments and contingent liabilities, where its engagement is irrevocable. The provisions for credit risk from commitments and contingent liabilities represent the valuation of the potential loss, which the Group would realize, considering the probability that the customer utilizes the commitment. In order to determine this loss, the Group converts the net off-balance sheet exposure (after deducting liquid collaterals) into a balance sheet exposure, by applying respective credit conversion factors.

For the converted off-balance sheet commitments the same calculation methods for impairment are applied as for the balance sheet exposures.

33. INVESTMENTS IN ASSOCIATES

An associate is an entity, including an unincorporated entity such as a partnership, over which the investor has significant influence, but not the control, and that is neither a subsidiary nor an interest in a joint venture.

The investments in associates are consolidated in the Group’s financial statements by using the equity method.

As at December 31, 2016 the Group’s participations are as follows:

Cash Collection Company AD – 20%

The activity of the entity is described in note 35.

34. CASH AND CASH EQUIVALENTS

For the purposes of the cash flow statement, cash and cash equivalents comprise the following balances with less than 3 months original maturity:

2016 2015

In BGN '000

Cash on hand and nostro accounts 212,241 210,175

Current account with the Central Bank 888,472 1,118,754

Placements with banks with original

maturity of less than 3 months 83,968 226,315

Total 1,184,681 1,555,244




35. GROUP MEMBERS

- Subsidiaries

Subsidiaries are these entities, which are controlled by the Bank.

Control is the power to govern the financial and operating policies of an entity so as to obtain benefits from its activities.

In order that the consolidated financial statements present financial information about the group as that of a single economic entity, income and expenses of a subsidiary are included in the consolidated statements from the date of acquisition until the Group ceases to exercise control over the entity.

Intragroup balances and transactions, including income, expenses and dividends, are eliminated in full. Profits and losses resulting from intragroup transactions that are recognised in assets, such as inventory and fixed assets, are eliminated in full.

The subsidiaries controlled by the Bank as at December 31, 2016 are:

Raiffeisen Leasing Bulgaria EOOD – 100% share

Raiffeisen Leasing Bulgaria OOD was established in 2004 with associates Raiffeisenbank

(Bulgaria) EAD (24.5%) and Raiffeisen Leasing International GmbH (75.5%). In 2016 the Bank

became 100% owner of the company by acquiring the share of Raiffeisen Leasing

International GmbH. After the acquisition the legal form of the company changed to

Raiffeisen Leasing Bulgaria EOOD.

Raiffeisen Leasing Bulgaria OOD actively participates in the Bulgarian leasing business and the main products offered to its customers are: leasing of new and used motor vehicles, building and agricultural machines, light and heavy-freight trucks, trailers and motor trucks, leasing of machines and equipment, as well as leasing of immovable property.

As of 31 December 31 2016 the company reaches a market share of 9.02% based on its leasing portfolio (as per statistics of the Bulgarian national bank). The total volume of the local leasing market amounts to BGN 3,314 mn and the total assets of the company amount to BGN 313 mn. The company’s registered capital amounts to BGN 5,900 thousand.

Raiffeisen Service EOOD – 100% ownership

Raiffeisen Service EOOD is registered in the Bulgarian Trade registry with a capital of BGN 4,220 thousand. Its scope of activity includes property management, financial and accounting consultancy, legal consultancy, accounting services, evaluation of movable and immovable property, financial assets and companies, electronic data handling and analysis, information services, rental of safe boxes, leasing. As of 31 December 2016 the company’s net assets amount to BGN 5,112 thousand.

Raiffeisen Asset Management (Bulgaria) EAD - 100% ownership

Raiffeisen Asset Management (Bulgaria) EAD has been granted a permission for its activities by the Financial Supervision Commission in 2005. The entity is licensed to exercise the activities per art. 202, (1), pp. 1, 2, 3 of the Law on public offering of securities and




treasury bonds, namely managing of mutual funds and investment companies, management of individual portfolios in its own name, advisory services on investments in securities. As at December 31, 2016 the company’s registered capital amounts to BGN 250 thousand and its net assets BGN 863 thousand.

Raiffeisen Insurance Broker EOOD - 100% ownership

Raiffeisen Insurance Broker EOOD has been established in 2006 with 100% ownership of Raiffeisenbank (Bulgaria) EAD. The company has been entered in the register of the insurance brokers on 30, March 2006 with decision №250-ЗB of the Financial Supervision Commission.

The company’s activity is related to intermediation between its customers and the insurance companies.

Raiffeisen Insurance Broker EOOD analyses and researches the insurance market, offers insurance products, which meet the individual requirements of its customers, administers the insurance contracts and lends support in case of insurance events.

Customers of Raiffeisen Insurance Broker EOOD are the borrowers of Raiffeisenbank (Bulgaria) EAD, the lessees of Raiffeisen Leasing Bulgaria OOD and Raiffeisen Real Estate EOOD, as well as customers outside the Group. As at December 31, 2016 the company’s registered capital amounts to BGN 5 thousand and its net assets BGN 5,927 thousand.

Raiffeisen Real Estate EOOD - 100% ownership

In 2016 the Bank decided to terminate the activity of the company through liquidation and Raiffeisen Real Estate EOOD was deregistered from the Bulgarian Trade registry.

- Associates

An associate is an entity, including an unincorporated entity such as a partnership, over which the investor has significant influence, but not the control, and that is neither a subsidiary nor an interest in a joint venture.

The investments in associates are consolidated in the Group’s financial statements by using the equity method. Under the equity method, the investment in an associate is initially recognised at cost and the carrying amount is increased or decreased to recognise the investor's share of the profit or loss of the investee after the date of acquisition. The investor's share of the profit or loss of the investee is recognised in the investor's profit or loss. Distributions received from an investee reduce the carrying amount of the investment. Adjustments to the carrying amount may also be necessary for changes in the investor's proportionate interest in the investee arising from changes in the investee's equity that have not been recognised in the investee's profit or loss. Such changes include those arising from the revaluation of property, plant and equipment and from foreign exchange translation differences. The investor's share of those changes is recognised directly in equity of the investor.




Cash Collection Company – 20% share

In 2009 the Bank became shareholder in the Cash collection company, with 20% participation, amounting to BGN 2,500 thousand. In 2016 indications for impairment of the investment were identified and the Bank recognized a loss in the amount of BGN 1,200 thousand.

The table below illustrates the consolidation methods by entities:

36. RELATED PARTY TRANSACTIONS

Parties are considered to be related if one party has the ability to control or exercise significant influence over the other party on making financial or operational decisions, or the parties are under common control with the Bank. A number of banking transactions are entered into with related parties in the normal course of business. These include loans, deposits and other transactions.

Parent and ultimate controlling party

The Bank’s immediate parent is Raiffeisen SEE Region Holding GmbH in which Raiffeisen Bank International AG, Austria ultimately holds a 100% interest. The Bank therefore considers that it has a related-party relationship, in accordance with International Accounting Standard 24 Related Party Disclosures (“IAS 24”) with the following: - Shareholders and parties related to shareholders - Key management personnel and parties related to key management personnel

Participation as

at December

31, 2016

Participation as

at December 31,

2015

Consolidation

method 2016

Consolidation

method 2015

Raiffeisen Service EAD 100% 100%

Full

consolidation

Full

consolidation

Raiffeisen Asset Management

(Bulgaria) EAD 100% 100%

Full

consolidation

Full

consolidation

Raiffeisen Insurance broker EOOD 100% 100%

Full

consolidation

Full

consolidation

Raiffeisen Real Estate EOOD - 100% -

Full

consolidation

Raiffeisen Leasing Bulgaria OOD 100% 24.5%

Full

consolidation

Equity

method

Cash collection company 20% 20%

Equity

method

Equity

method




Shareholders and parties related to shareholders

Related party Type of

transaction

Value of the

transactions for the

year ended

In BGN ‘000

Balance as of 31

December

In BGN '000

2016 2015 2016 2015

Mother company

Loans and

advances to

banks

93,407 553,993

Mother company Positive fair

value of

derivatives

4,689 1,250

Mother company Tangible and

intangible

assets

3,225 4,098

Mother company Other assets 1,265 1,260

Mother company Deposits from

banks

15,618 25,219

Mother company Negative fair

value of

derivatives

1,718 1,250

Mother company Subordinated

liabilities

365,281 365,457

Mother company Other liabilities

86 251

Mother company Interest income 525 1,063

Mother company Interest expense (11,618) (12,571)

Mother company Fee and

commission

income 48 39

Mother company Fee and

commission

expense (423) (668)

Mother company Net result from

derivatives (101) (158)

Mother company Administrative

expenses (8,706) (9,054)

Mother company

Other operating

expenses (52) (107)

Mother company

Other operating

income - 1

Mother company

Contingent

liabilities and

commitments 7,851 8,164

Companies related

to the mother

company

Loans and

advances to

banks

78,866 118,121

Companies related

to the mother

company

Loans and

advances to

customers

- 58,676

Companies related

to the mother

company

Investment

securities

97,579 -

Companies related Tangible and 2,212 2,783




to the mother

company

intangible fixed

assets

Companies related

to the mother

company

Deposits from

banks

469 143

Companies related

to the mother

company

Deposits from

customers

2,629 4,497

Companies related

to the mother

company Interest income 1,838 534

Companies related

to the mother

company Interest expense 1 -

Companies related

to the mother

company

Fee and

commission

income 30 32

Companies related

to the mother

company

Fee and

commission

expense (1,996) (1,039)

Companies related

to the mother

company

Administrative

expenses (4,346) (2,734)

Companies related

to the mother

company

Contingent

liabilities and

commitments

1,053 4,415

Associated

companies

Loans and

advances to

customers

-

68,029

Associated

companies

Positive fair

value of

derivatives

-

16

Associated

companies

Deposits from

customers

- 3,564

Associated

companies

Finance lease

liabilities - 764

Associated

companies Interest income -

558

Associated

companies Interest expense -

(27)

Associated

companies

Net result from

derivatives

-

7

Associated

companies

Administrative

expenses (226)

(397)

Associated

companies

Other operating

income -

321

Associated

companies

Contingent

liabilities

(guarantees

issued) - 16,220

Associated

companies

Dividend

income 178

966

Key management personnel and parties related to key management personnel




Supervisory Board members, Management Board members and other key management personnel defined as persons having authority and responsibility for planning, directing and controlling the activities of the Bank, directly or indirectly, including any director (whether executive or otherwise) of the Bank, collectively “key management personnel”, close family members of key management personnel, and companies and unincorporated businesses controlled by key management personnel and/or their close family members. During the year 4 persons served as Supervisory Board members and 6 served as Management Board members. Except the Supervisory and Management Board members, the Bank does not consider any other persons at the reporting date, to be key management personnel.

The table below shows the key management personnel compensation:

Related party transactions are summarized below.

Banking services

The Bank provides current accounts to related parties, and takes deposits from them, on which it incurs interest expense, and provides loans to them, on which it earns interest income. The Bank also earns fee and commission income on banking services provided to related parties. Other transactions

Other related party transactions includes rent receivable from and payable to related parties for property occupancy, and costs for other services.

Key management personnel

Type of transaction

Value of the transactions for the

year ended End balances as of 31

December

In thousands of BGN 2016 2015 2016 2015

Current accounts and

deposits 3,779 3,532

Interest expense (20) (52)

Interest income - 10

Fee and commission

income 2 4

Remuneration 4,009 3,606

Loans and credit

commitments 2 364

37. SUBSEQUENT EVENTS

There are no events after the statement of financial position that would require either adjustments or additional disclosures in these consolidated financial statements.

Compensation for key management personnel

in BGN ‘000 2016

2015

Short-term employee benefits 4,009 3,606

Total 4,009 3,606

raiffeisenbank (bulgaria) ead consolidated annual … · raiffeisenbank (bulgaria) ead consolidated...

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