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UBI Banca Group

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1.2 Policies for the management of credit risk<br />

1.2.1 Organisational aspects<br />

In the performance of its traditional banking business, the <strong>Group</strong> is exposed to the risk that the<br />

loans it grants will not be repaid by borrowers when they are due and that partial or full impairment<br />

losses must be recognised on them. More specifically the risk profile for lending is sensitive to the<br />

performance of the economy as a whole, to the deterioration in the financial position of<br />

counterparties (shortage of liquidity, insolvency, etc.), or to changes in their competitiveness, to<br />

structural or technological changes in corporate debtors and to other external factors (e.g. changes in<br />

legislation, deterioration in the value of financial guarantees and mortgages connected with market<br />

performance). A further risk factor to which the <strong>Group</strong> pays particular attention is the degree of<br />

diversification in the lending portfolio among different borrowers and among the different sectors in<br />

which they operate.<br />

The organisational model on which the units which manage lending activity is based is as follows:<br />

Parent units for centralised monitoring and co-ordination;<br />

the General Managements of banks and <strong>Group</strong> companies, to which the following report:<br />

- credit departments;<br />

- local credit centres,<br />

- branches;<br />

- corporate banking units (CBUs);<br />

- private banking units (PBUs).<br />

The characteristics of that organisational model ensure strong standardisation between the units of<br />

the Parent and the corresponding units in the network banks, with consequent linearity in the<br />

processes and the optimisation of information flows. Loan granting activity is also differentiated, at<br />

local level, by customer segment (retail/private banking/corporate and institutional) and specialised<br />

by the status of the loan: “performing” (managed by retail, private banking and corporate lending<br />

units) and “default” (managed by problem loan units).<br />

Furthermore, with regard to banks, the introduction of decentralised Local Credit Units to support<br />

retail branches and corporate banking and private banking units, ensures effective co-ordination and<br />

liaison between units operating on their respective markets. The Parent oversees policy management,<br />

overall portfolio monitoring, the refinement of assessment systems, problem loan management and<br />

compliance with regulations through the Credit and Credit Recovery, Risk Control, Strategic<br />

Development and Planning and the Parent and <strong>Group</strong> Audit Macro Areas.<br />

For all those entities (individual companies or groups) with authorised credit from banks and<br />

companies in the <strong>Group</strong> (including risk activities involving issuer and related risks), which totals<br />

more than €50 million, the Parent must set an operational limit which is the maximum credit that<br />

may be authorised for the counterparty at <strong>UBI</strong> <strong>Group</strong> level. The Management Board of the Parent is<br />

responsible for granting, changing and renewing operational limits on the proposal of the <strong>UBI</strong> Credit<br />

Area after first consulting the <strong>UBI</strong> Credit Committee.<br />

The banks and companies of the <strong>Group</strong> must also request a prior, consultative, non binding opinion<br />

from the Parent for combinations of a) amounts of authorised credit and b) determined internal rating<br />

classes. It is the Parent’s duty to assess whether it is consistent with the credit policies of the <strong>Group</strong>,<br />

according to the criteria and parameters laid down in the credit authorisation regulations of the<br />

<strong>Group</strong>. A prior opinion is not required for credit authorisations for single counterparties or groups of<br />

companies which fall within the operational limits that have been set.<br />

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