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Prospectus - Notowania

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205<br />

>> Condensed Consolidated Financial Statements<br />

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

The entities provide a summary of the activities carried out and assess whether they comply with regulations and Group<br />

standards. Where areas for improvement are identified, the proposed actions must be defined, along with, where possible,<br />

the predicted timeframe for their implementation.<br />

The entities applying the advanced model (Advanced Measurement Approach) and those of the Italian entities using the<br />

standard approach (Traditional Standardized Approach) must compile the validation document and submit it to Parent<br />

company. The validation document, together with Parent company’s opinion and the Internal Audit report, are submitted to<br />

the entity's Board of Directors for approval.<br />

Parent company’s Risk management function is responsible for drawing up the Group validation document and submitting it<br />

to the UniCredit Board of Directors for approval, together with the Internal Audit report.<br />

Reporting<br />

A reporting system has been developed by Parent company to inform senior management and internal control bodies about<br />

the Group's operational risk exposure and the risk mitigation actions.<br />

In particular, quarterly updates are provided on operating losses, capital-at-risk estimates, relevant external events and the<br />

main initiatives undertaken to mitigate operational risk in the various business areas. A summary of the most important risk<br />

indicators is drawn up each month.<br />

The results of the main scenario analyses carried out at Group level and the relevant mitigation actions undertaken are also<br />

submitted to the attention of the Group's Operational Risk Committee.<br />

Operational risk management and mitigation<br />

Operational risk management consists of process reengineering to reduce risk exposure, including outsourcing<br />

considerations, and insurance policies management, defining proper deductibles and policies’ limits.<br />

Regularly tested business continuity plans will also assure operational risk management in case of interruption of main<br />

business services.<br />

The Risk Committee (or other bodies in accordance with local regulations) reviews risks tracked by the Operational Risk<br />

functions of the Legal entities, with the support of functions involved in daily operational risk control and monitors the risk<br />

mitigation initiatives.<br />

Risk capital measurement and allocation mechanism<br />

UniCredit developed a proprietary model for measuring capital requirements. The system for measuring operational risk is<br />

based on internal loss data, external loss data (consortium and public data), scenario generated loss data and risk indicators.<br />

Capital requirements are calculated per operational event type class. For each risk class, severity and frequency of loss data<br />

are separately estimated to obtain the annual loss distribution through simulation, considering also insurance coverage. The<br />

severity distribution is estimated on internal, external and scenario generated data, while the frequency distribution is<br />

determined using only the internal data. An adjustment for key operational risk indicators is applied to each risk class. Annual<br />

loss distributions of each risk class are aggregated through a copula based method. Capital at risk is calculated at a<br />

confidence level of 99.9% on the overall loss distribution for regulatory purposes and at a confidence level 99.97% for<br />

economic capital purposes.<br />

By the allocation mechanism, the individual legal entities’ capital requirements are identified, reflecting the Legal Entities’ risk<br />

exposure and risk management effectiveness.<br />

The internal model (AMA) has been formally approved by the Supervisory Authority and is expected to be rolled out to all the<br />

relevant Group entities before the end of 2012. The entities not yet authorised to use the advanced methods contribute to the<br />

consolidated capital requirement on the basis of the standard (TSA) or basic (BIA) method.

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