1 GROUP CONCISE RISK STATEMENT

As part of setting its Risk Appetite, Societe Generale seeks a sustainable development based on a diversified and balanced banking model with a strong European foothold and a global presence targeted on a few areas of strong business expertise. The Group also aims to maintain long-term relationships with its customers built on well-earned trust, and to respond responsibly to the expectations of all of its stakeholders. At 31 December 2022, the indicators of the Group’s risk appetite in terms of solvency, earnings, market risk, cost of risk and non performing loans rate were within the risk appetite levels defined by the Group. They have not reached the tolerance thresholds defined by the Board.

1.1 FINANCIAL STRENGTH PROFILE

The Group seeks sustainable profitability, relying on a robust financial strength profile, consistent with its diversified banking model. In terms of financial ratios, the Group calibrates its objectives to ensure a sufficient margin of safety in relation to regulatory requirements. As of 31 December 2022, the Group’s CET1 ratio stood at 13.5% compared to 13.7% at the end of 2021, well above the regulatory requirement of 9.35% (“MDA” threshold - Maximum Distributable Amount, calculated at end of Decembre 2022).

The solvency and leverage prudential ratios, as well as the amounts of regulatory capital and RWA featured here take into account the IFRS 9 phasing (fully-loaded CET1 ratio of 13.34% at end 2022, the phasing effect being +17 bps) and the effects of the ECB’s Covid-19 transitional measures ending on 31 December 2022.

As of 31 December 2022, the Group’s leverage ratio stood at 4.4%, taking into account an amount of Tier 1 capital of EUR 58.7 billion compared to a leverage exposure of EUR 1,345 billion. euros (compared to 4.9% as of 31 December 2021, with EUR 57.9 billion and EUR 1,190 billion respectively).

In addition, as of 31 December 2022, the Group has a TLAC (Total Loss Absorbing Capacity) ratio of 33.64% of weighted exposures (compared to 31.1% as of 31 December 2021, for a regulatory requirement of 21.66% at the end of 2022).

Regarding its risk profile, the Group has a balanced distribution of risk-weighted exposures (RWA) between its Global Banking and Investor Solutions divisions (34% as of 31 December 2022), Retail Banking and International Financial Services (31% as of 31 December 2022), Retail Banking in France (29% as of 31 December 2022) and Corporate Center (6% as of 31 December 2022). In terms of change, the Group’s weighted exposures stood at EUR 360.5 billion as of 31 December 2022 compared to EUR 363.4 billion as of 31 December 2021, a decrease of -1%.

Concerning the internal economic approach of the ICAAP, the rate of coverage of the Group’s internal capital requirement by the internal capital the end of 2022 is greater than 100%.

(In EURbn)

Credit and

counterparty credit

Market

Operational

Total 31.12.2022

French Retail Banking

101.0

0

5.1

106.1

International Retail Banking and Financial Services

105.6

0.2

4.6

110.4

Global Banking and Investor Solutions

82.1

12.6

29.0

123.7

Corporate Centre

12.1

0.9

7.4

20.3

Group

300.7

13.7

46.0

360.5

(In EURbn)

Credit and

counterparty credit

Market

Operational

Total 31.12.2021

French Retail Banking

91.8

0.1

3.7

95.5

International Retail Banking and Financial Services

112.1

0.1

5.5

117.7

Global Banking and Investor Solutions

89.3

11.5

30.3

131.2

Corporate Centre

11.7

0.0

7.3

19.0

Group

304.9

11.6

46.8

363.4

In addition, the Group presents its unconsolidated structured entities in Note 2.4 of the financial statements of the 2023 Universal Registration Document. Intra-group transactions are governed by a credit granting process respecting different levels of delegation within the Business Units, the Risk Department and the Finance Department. The entities’ structural risk management and oversight systems are also submitted to the Finance Department and the Risk Department.

1.2 CREDIT RISK AND COUNTERPARTY CREDIT RISK

Weighted exposures for credit risk and counterparty risk represent the Group’s main risk with an amount of risk-weighted exposures (RWA) of EUR 300.7 billion as of 31 December 2022, i.e. 83% of the total RWAs. These weighted exposures decreased by -1.4% compared to 31 December 2021 and are mainly based on the internal model approach (67% of credit and counterparty risk RWA). This decrease is mainly due to a methodology effect (-8 billion euros), a perimeter effect (-6 billion euros) related to the sale of Rosbank, and a volume effect (-4.4 billion euros) partially offset by a model effect update (+7.8 billion euros), a downgrade of assets quality (+3.9 billion euros) and a foreign exchange effect (+2.6 billion euros).

The credit portfolio presents a diversified profile. As of 31 December 2022, exposure to credit and counterparty risk represented an amount of EAD of 1,119 billion euros, up (+4%) compared to the end of 2021, driven in particular by the increase of ” Sovereigns”exposures. The breakdown of the portfolio between main customer categories is balanced: Sovereigns (29%), Corporates (32%), Retail customers (20%), Institutions (9%) and Others (10%).

In terms of geographic breakdown of the portfolio, exposure to emerging countries remains limited: the Group’s exposure is 70% in Western Europe (including 48% in France) and 14% in over North America. In sectoral terms, only the Financial Activities sector represents 7% of the Group’s Corporate exposures, followed by the Real Estate Activities and Business Services sectors.

With regard more specifically to counterparty risk, exposure represents an amount of EAD of 160 billion euros, increased (+11%) compared to the end of 2021, linked to the significant increase in exposure to Sovereigns.

As of 31 December 2022, EAD’s exposure to Russia represented 2.2 billion euros (exc. Private Banking) mainly made up of operations set up as part of the financing activities of Global Banking and Investor Solutions.

(See details in Chapter 6 “Credit risk” and Chapter 7 “Counterparty credit risk”.)

The Group’s net cost of risk in 2022 is EUR 1,647 million, up by 135% compared to 2021. This higher cost of risk compared to a low 2021 reference base is composed by a cost of risk which remains low on defaulted outstandings (stage 3), 17 bp compared to 18 bp in 2021, and provisions on sound outstandings (stage 1/stage 2) of 12 bp in order to maintain a prudent provisioning policy in an environment marked by economic prospects less favorable and in particular the rise in inflation and interest rates.

The cost of risk (expressed in basis points on the average of outstandings at the beginning of the period for the four quarters preceding the closing, including operating leases) thus stands at 28 basis points for the year 2022 compared to 13 basis points in 2021.

In French Retail Banking, the cost of risk is up to 20 basis points in 2022 compared to 5 basis points in 2021. This NCR includes an allocation of 4 bps on sound outstandings (compared to the stage 1/stage 2 recovery of -7bp in 2021).

At 52 basis points in 2022 (compared to 38 basis points in 2021), the cost of risk of the International Retail Banking and Financial Services division increased despite a lower NCR on defaulted outstandings (internship 3) due to an allocation of 15 base points on stage 1/stage 2.

The cost of risk for Global Banking and Investor Solutions posted a level of 23 basis points (compared to 4 basis points in 2021), reflecting a sharp rise in the cost of risk on performing loans (stage 1/ stage 2) at 20 bp, while the NCR on defaulted outstandings remains very moderate (4 bp against 7 bp in 2021).

(See details in section 6 of Chapter 6 “Credit risk”.)

Elements relating to ESG risks are presented in Chapter 14 of this Pillar 3 document.

Within the meaning of Template 1 of Pillar 3 on ESG risks concerning transition risk, exposures towards sectors that highly contribute to climate change(1) (based on the NACE codes provided by the EBA) represent 177 billion euros of gross carrying amount.

(1)

In accordance with the Commission delegated regulation EU) 2020/1818 supplementing regulation (EU) 2016/1011 as regards minimum standards for EU Climate Transition Benchmarks and EU Paris-aligned Benchmarks -Climate Benchmark Standards Regulation - Recital 6: Sectors listed in Sections A to H and Section L of Annex I to Regulation (EC) No 1893/2006.

(In EURbn)

31.12.2022

31.12.2021

Group gross doubtful loans ratio(1)

2.8%

2.9%

Doubtful loans (Stage 3)

15.9

16.5

Stage 3 Provisions

7.7

8.4

Group gross doubtful loans coverage ratio

48%

51%

(1)

Customer loans and advances, deposits at banks and loans due from banks, finance leases, excluding loans and advances classified as held for sale, cash balances at central banks and other demand deposits, in accordance with the EBA/ITS/2019/02 Implementing Technical Standards amending Commission Implementing Regulation (EU) No 680/2014 with regard to the reporting of financial information (FINREP). The NPL rate calculation was modified in order to exclude from the gross exposure in the denominator the net accounting value of the tangible assets for operating lease. Performing and non-performing loans include loans at fair value through profit or loss which are not eligible to IFRS 9 provisioning and so not split by stage. Historical data restated.

(In bps)

31.12.2022

31.12.2021

Cost of risk

28

13

1.3 OPERATIONAL RISK

As of 31 December 2022, operational risk-weighted exposures represented EUR 46 billion, or 13% of the Group’s RWA, down -2% compared to the end of 2021 (EUR 46.8 billion). These weighted exposures are mainly determined using the internal model (97% of the total). The total amount of exposures weighted assets decreases in 2022 (-0.8 billion euros, i.e. -1.7%) mainly due to the disposal of activities in Russia.

(See details in section 4 of Chapter 10 “Operational risk”).

1.4 MARKET RISK

Market risk-weighted exposures are mainly determined using internal models (86% of the total at the end of 2022). These weighted exposures amounted to EUR 13.7 billion at the end of 2022, i.e. 3.8% of the Group’s total RWA, up +18% compared to the end of 2021 (EUR 11.6 billion).

Capital requirements for market risk increased in 2022. This increase is reflected in the VaR and the risks calculated under the standard approach:

the VaR gradually increased over 2022, from a historically low level at the end of 2021;

risks calculated under the standard approach are on the rise, mainly due to the currency portion.

(See details in Chapter 9 “Market risk”).

(In EURm)

2022

2021

VaR (1 day, 99%) average value

18

15

SVaR (1 day, 99%) average value

32

37

1.5 STRUCTURAL RISK - LIQUIDITY

The LCR (Liquidity Coverage Ratio) ratio stood at 141% at the end of 2022 (compared to 129% at the end of 2021), corresponding to excess liquidity of EUR 74 billion (compared to EUR 51 billion at the end of 2021), compared to a regulatory requirement of 100%. The increase in the LCR of Société Générale between end of 2021 and end of 2022 reflects a precautionary and anticipatory stance, whereby Société Générale has increased its term deposits in the money market and anticipated a portion of its 2023 funding plan. This was driven by (i) favorable market conditions at the end of the year, (ii) the new context of positive interest rates, that may reduce deposits from corporate clients to monetary supports; (iii) anticipating the reduction in liquidity generated by the end of the TLTRO.

Liquidity reserves amounted to EUR 279 billion as of 31 December 2022 (compared to EUR 229 billion as of 31 December 2021). This variation is mainly due to an increase in HQLA securities available for sale on the market (after discount), partially offset by an increase in central bank deposits (excluding mandatory reserves).

(See details in sections 5 and 6 of Chapter 12 “Liquidity risk”).

1.6 STRUCTURAL RISK - RATES

In a parallel schock scenario where the interest rate increase, the impact of the changes of EVE (economic value of equity) in 2022 is -2,900 EUR million and 375 EUR million on interest margin. On the contrary, in a parallel schock scenario where the interest rate decrease, the impact of the changes of EVE (economic value of equity) in 2022 is 1,011 EUR million and -1,102 EUR million on interest margin.

(See details in section 2 of Chapter 11 “Structural interest rate and exchange rate risks”).

(In EURm)

31.12.2022

Changes of the economic value

of equity (EVE)

Changes of the net interest income

(NII)

Supervisory shock scenarios*

 

 

1

Parallel up

(2 900)

 375

2

Parallel down 

1 011

(1 102)

3

Steepener 

1 875

 

4

Flattener

(2 547)

 

5

Short rates up

(2 747)

 

6

Short rates down

2 862

 

(In EURm)

31.12.2021

Changes of the economic value

of equity (EVE)

Changes of the net interest income

(NII)

Supervisory shock scenarios*

 

 

1

Parallel up

(6,784)

240

2

Parallel down 

(2,683)

(219)

3

Steepener 

463

 

4

Flattener

(4,033)

 

5

Short rates up

(3,643)

 

6

Short rates down

79

 

*

The above 6 shock scenarios are detailed in appendix 3 of the EBA/GL/2018/02 regulation (refer to EBA BS 2018 XXX Proposed final revised IRRBB Guidelines.docx (europa.eu)).

1.7 SIGNIFICANT OPERATIONS IN 2022

In 2022, the Group finalized the sale of Rosbank in Russia in the context of the russo-ukrainian crisis and the net income was around -3 billion euros. Furthermore, some important milestones have been reached concerning the merger of the retail network in France, in accordance to the schedule, and lead to the legal merger of retail network of Société Générale and Crédit du Nord on January, 1st. The new SG retail bank is launched. Partnership between Société Générale and ING has been finalised, pushing further ahead Boursorama (new clients +1.4 million clients reaching 4.7 million clients at end of 2022). The planned acquisition of LeasePlan by ALD in the mobility sector and Bernstein joint venture deal for our Equities business will create global leaders.

1.8 KEY FIGURES

(In EURm)

 

31.12.2022

30.09.2022

30.06.2022

31.03.2022

31.12.2021

AVAILABLE OWN FUNDS (AMOUNTS)

1

Common Equity Tier 1 (CET1) capital 

48,639

47,614

47,254

48,211

49,835

2

Tier 1 capital 

58,727

57,053

56,024

56,443

57,907

3

Total capital 

69,724

69,444

67,835

66,990

68,487

RISK-WEIGHTED EXPOSURE AMOUNTS

4

Total risk-weighted assets

360,465

371,645

367,637

376,636

363,371

CAPITAL RATIO (AS A PERCENTAGE OF RISK-WEIGHTED AMOUNTS)

5

Common Equity Tier 1 ratio (%)

13.49%

12.81%

12.85%

12.80%

13.71%

6

Tier 1 ratio (%)

16.29%

15.35%

15.24%

14.99%

15.94%

7

Total capital ratio (%)

19.34%

18.69%

18.45%

17.79%

18.85%

ADDITIONAL OWN FUNDS REQUIREMENTS TO ADDRESS RISKS OTHER THAN THE RISK OF EXCESSIVE LEVERAGE (AS A PERCENTAGE OF RISK-WEIGHTED EXPOSURE AMOUNT)(1)

EU 7a

Additional own funds requirements to address risks other than the risk of excessive leverage (%) 

2.12%

2.12%

2.12%

2.12%

1.75%

EU 7b

of which to be made up of CET1 capital (%)

1.19%

1.19%

1.19%

1.19%

0.98%

EU 7c

of which to be made up of Tier 1 capital (%)

1.59%

1.59%

1.59%

1.59%

1.31%

EU 7d

Total SREP own funds requirements (%)

10.12%

10.12%

10.12%

10.12%

9.75%

COMBINED BUFFER REQUIREMENT (AS A PERCENTAGE OF RISK-WEIGHTED EXPOSURE AMOUNT)

8

Capital conservation buffer (%)

2.50%

2.50%

2.50%

2.50%

2.50%

EU 8a

Conservation buffer due to macro-prudential or systemic risk identified at the level of a Member State (%)

-

-

-

-

-

9

Institution-specific countercyclical capital buffer (%)

0.16%

0.08%

0.05%

0.04%

0.04%

EU 9a

Systemic risk buffer (%)

-

-

-

-

-

10

Global Systemically Important Institution buffer (%)

1.00%

1.00%

1.00%

1.00%

1.00%

EU 10a

Other Systemically Important Institution buffer

-

-

-

-

-

11

Combined buffer requirement (%)

3.66%

3.58%

3.55%

3.54%

3.54%

EU 11a

Overall capital requirements (%)

13.78%

13.70%

13.67%

13.66%

13.29%

12

CET1 available after meeting the total SREP
own funds requirements (%)

7.80%

7.12%

7.16%

7.11%

8.23%

LEVERAGE RATIO

13

Leverage ratio total exposure measure(2)

1,344,870

1,392.918 

1,382,334

1,319,813

1,189,253

14

Leverage ratio

4.37%

4.10%

4.05%

4.28%

4.87%

ADDITIONAL OWN FUNDS REQUIREMENTS TO ADDRESS RISK OF EXCESSIVE LEVERAGE
(AS A PERCENTAGE OF LEVERAGE RATIO TOTAL EXPOSURE EXPOSURE AMOUNT)

EU 14a

Additional own funds requirements to address
the risk of excessive leverage (%) 

-

-

-

-

-

EU 14b

of which to be made up of CET1 capital (%)

-

-

-

-

-

EU 14c

Total SREP leverage ratio requirements (%)(3)

3.00%

3.00%

3.00%

3.09%

3.09%

LEVERAGE RATIO BUFFER AND OVERALL LEVERAGE RATIO

EU 14d

Leverage ratio buffer requirement (%)

-

-

-

-

-

EU 14e

Overall leverage ratio requirements (%)(3)

3.00%

3.00%

3.00%

3.09%

3.09%

LIQUIDITY COVERAGE RATIO

15

Total high-quality liquid assets (HQLA)
(Weighted value – average)

246,749

242,177

238,136

235,333

229,464

EU 16a

Cash outflows – Total weighted value 

413,693

434,078

420,815

409,590

395,120

EU 16b

Cash inflows – Total weighted value 

233,039

258,705

245,812

235,158

226,434

16

Total net cash outflows (adjusted value)

174,670

175.377

175,003

174,432

168,687

17

Liquidity coverage ratio (%)

141.41%

138.05%

136.00%

134.72%

135.95%

NET STABLE FUNDING RATIO

18

Total available stable funding

617,491

617,615

615,879

629,042

619,442

19

Total required stable funding

543,549

548,457

549,492

561,828

561,043

20

NSFR ratio (%)

113.60%

112.61%

112.08%

111.96%

110.41%

(1)

The own funds requirement applicable to Societe Generale group in relation to Pillar 2 reaches 2.12% (of which 1.19% in CET1) until 31/12/2022 resulting in a total SREP own funds requirements of 10.12%.

(2)

Over the whole historical period considered, the measurement of the leverage exposure has been taking into account the option to exempt temporarily some central bank exposures in accordance with the European regulation.

(3)

The leverage ratio requirement applicable to Societe Generale group is 3.09% (enhancement of the initial regulatory requirement of 3% in relation to the abovementioned central bank exemption) until 3/31/2022 and then 3% effective 6/30/2022.

(in EURm)

TLAC

31.12.2022

30.09.2022

30.06.2022

31.03.2022

31.12.2021

OWN FUNDS AND ELIGIBLE LIABILITIES, RATIOS AND COMPONENTS(1)

1

Own funds and eligible liabilities 

121,249

119,337

116,539

114,436

113,098

2

Total RWA of the Group

360,465

371,645

367,637

376,636

363,371

3

Own funds and eligible liabilities as a percentage of RWA

33.64%

32.11%

31.70%

30.38%

31.12%

4

Total exposure measure of the Group

1,344,870

1,392,918

1,382,334

1,319,813

1,189,253

5

Own funds and eligible liabilities as percentage of the total exposure measure

9.02%

8.57%

8.43%

8.67%

9.51%

6a

Does the subordination exemption in Article 72b(4) of the CRR apply? (5% exemption)

No

No

No

No

No

6b

Pro-memo item: Aggregate amount of permitted non-subordinated eligible liabilities in-struments
If the subordination discretion as per Article 72b(3) CRR is applied (max 3.5% exemption)

11,430

9,287

9,023

7,114

6,921

6c

Pro-memo item: If a capped subordination exemption applies under Article 72b (3) CRR, the amount of funding issued that ranks pari passu
with excluded liabilities and that is recognised under row 1, divided by funding issued that ranks pari passu with excluded Liabilities and that would be recognised under row 1 if no cap was applied (%)

100.00%

100.00%

100.00%

100.00%

100.00%

(1)

With IFRS 9 phasing effect taken into account over the whole historical period considered.

As at 31 December 2022, the Group presents a TLAC ratio of 33.64% of risk-weighted assets (RWA) with the option of Senior preferred debt limited to 3.5% of RWA (the ratio being 30.47% without this option) for a regulatory requirement of 21.66%, and of 9.02% of the leverage exposure for a regulatory requirement of 6.75%.

 

2 RISK FACTORS

 

IN BRIEF

This section describes the various types of risks and the risks to which Societe Generale is exposed.

2.1 RISK FACTORS BY CATEGORY

This section identifies the main risk factors that the Group estimates could have a significant effect on its business, profitability, solvency or access to financing.

As part of its internal risk management, Societe Generale has updated its risk typology. For the purposes of this section, these different types of risks have been grouped into six main categories (4.1 to 4.1.6), in accordance with Article 16 of the Regulation (EU) 2017/1129, also known as “Prospectus 3” regulation of 14 June 2017, according to the main risk factors that the Group believes could impact the risk categories. Risk factors are presented based on an evaluation of their materiality, with the most material risks indicated first within each category.

The diagram below illustrates how the categories of risks identified in the risk typology have been grouped into the six categories and which risk factors principally impact them.

2.1.1 RISKS RELATED TO THE MACROECONOMIC, GEOPOLITICAL, MARKET AND REGULATORY ENVIRONMENTS

2.1.1.1 The global economic and financial context, geopolitical tensions, as well as the market environment in which the Group operates, may adversely affect its activities, financial position and results of operations.

As a global financial institution, the Group’s activities are sensitive to changes in financial markets and economic conditions generally in Europe, the United States and elsewhere around the world. The Group generates 49% of its business in France (in terms of net banking income for the financial year ended 31 December 2022), 32% in Europe, 7% in the Americas and 12% in the rest of the world. The Group could face significant deteriorations in market and economic conditions resulting from, in particular, crises affecting capital or credit markets, liquidity constraints, regional or global recessions and fluctuations in commodity prices (notably oil and natural gas). Other factors could explain such deteriorations, such as variations in currency exchange rates or interest rates, inflation or deflation, rating downgrades, restructuring or defaults of sovereign or private debt, or adverse geopolitical events (including acts of terrorism and military conflicts). In addition, the Covid-19 crisis continues to have an impact mainly in China, where the so-called “Zero Covid” policy has begun to be relaxed. Such events, which can develop quickly and whose effects may not have been anticipated and hedged, could affect the Group’s operating environment for short or extended periods and have a material adverse effect on its financial position, cost of risk and results of operations.

The economic and financial environment is exposed to intensifying geopolitical risks. The war in Ukraine which began in February 2022 has led to high tensions between Russia and Western countries, with significant impacts on global growth, energy and raw materials prices, as well as on a humanitarian level. The economic and financial sanctions imposed by a large number of countries, particularly in Europe and the United States, against Russia and Belarus could significantly affect operators with direct or indirect links to Russia, with a material impact on the Group’s risks (credit and counterparty, market, reputation, compliance, legal, operational, etc.). The Group will continue to analyse in real time the global impact of this crisis and to take all necessary measures to comply with applicable regulations.

In Asia, US-China relations are fraught with trade tensions and the risk of technological fractures.

After a long period of low interest rates, the current inflationary environment is leading the major central banks to raise rates. The entire economy will need to adapt to a context of higher interest rates. In addition to the impact on the valuation of equities, interest rate-sensitive sectors such as real estate will have to adjust. The US Federal Reserve and the European Central Bank (ECB) are expected to continue to tighten monetary conditions in the first half of 2023 before taking a break as inflation recedes according to our predictions. In the meantime, inflation in the US and Europe continues to impact the price of services, food and energy.

This crisis could generate strong volatility on the financial markets and a significant drop in the price of certain financial assets, potentially leading to payment defaults, with consequences that are difficult to anticipate for the Group. In France, after the long period of low interest rates which fostered an upturn of the housing market, a reversal of activity in this area could have an adverse effect on the Group’s asset value and on business, by decreasing demand for loans and resulting in higher rates of non-performing loans. More generally, the higher interest rates environment in a context where public and private debts have tended to increase is an additional source of risk.

Considering the uncertainty generated by this situation, both in terms of duration and scale, these disruptions could persist throughout 2023 and have a significant impact on the activity and profitability of certain Group counterparties.

Against the backdrop of the continuing war in Ukraine, the reduction in Russian gas imports and the introduction of an embargo on Russian oil on 5 December 2022, the European energy sector is facing a more difficult and uncertain situation. Gas prices have risen and remain highly volatile. A total halt in Russian gas supplies combined with a post-Covid-19 economic recovery in China could lead to a further spike in gas prices, affecting European economic growth.

In the longer term, the energy transition to a “low-carbon economy” could adversely affect fossil energy producers, energy-intensive sectors of activity and the countries that depend on them.

With regard to financial markets, in the context of Brexit, the topic of non-equivalence of clearing houses (central counterparties, or CCPs) remains a point of vigilance, with possible impacts on financial stability, notably in Europe, and therefore on the Group’s business. In addition, capital markets (including foreign exchange activity) and securities trading activities in emerging markets may be more volatile than those in developed markets and may also be vulnerable to certain specific risks, such as political instability and currency volatility. These elements could negatively impact the Group’s activity and results of operations.

On the mobility market, due to the shortage of new car supply, demand for used vehicles has risen, pushing up resale prices sharply. As a result, ALD has recorded a historically high result on used vehicle sales for the past year. The Group is exposed to a potential loss in a financial year from (i) resale of vehicles related to leases which expire during the period whose resale value is lower than their net carrying amount and (ii) additional impairment during the lease period if residual value drops below contractual residual value. Future sales and estimated losses are impacted by external factors such as macroeconomic conditions, government policies, tax and environmental regulations, consumer preferences, new vehicle prices, etc. The Group anticipates for 2023 that supply chains may not return to normal immediately, which could support the resale prices of used vehicles.

The Group’s results are therefore exposed to the economic, financial, political and geopolitical conditions of the main markets in which the Group operates.

2.1.1.2 The Group’s failure to achieve its strategic and financial objectives disclosed to the market could have an adverse effect on its business, results of operations and the value of its financial instruments.

The Group is fully on track to achieving its strategic milestones and has set targets for profitable and sustainable growth out to 2025 with:

average annual revenue growth of 3% or greater over the 2021-2025 period by focusing on growth in the most profitable businesses;

an improved cost to income ratio equal to or lower than 62% in 2025 and ROTE of 10% based on a targeted CET1 ratio of 12% in 2025;

disciplined management of scarce resources, in addition to keeping a tight rein on risks, will help strengthen and improve the quality of the Bank’s balance sheet;

stringent loan portfolio management with cost of risk of around 30 basis points in 2025;

increased use of new technologies and digital transformation;

commitments in Environmental, Social and Governance areas.

More precisely, the Group’s “Vision 2025” project anticipates the merger between the Retail Banking network of Societe Generale in France and Crédit du Nord. Although this project has been designed to achieve controlled execution, the merger could have a short-term material adverse effect on the Group’s business, financial position and costs. System reconciliations could undergo delays, thereby postponing part of the expected merger benefits. The project could lead to some staff departures, requiring replacements and training efforts which could potentially generate additional costs. The merger could also lead to the departure of some of the Group’s customers, resulting in loss of revenue. The legal and regulatory aspects of the transaction could prompt delays and additional costs.

Following ALD’s announcement on 6 January 2022 of its plan to acquire LeasePlan, Societe Generale and ALD announced on 22 April 2022 the signing of a framework agreement, with the aim of creating a global leader in mobility solutions. The acquisition is subject to receiving certain regulatory approvals and to the performance of other standard conditions precedent.

The Group also announced in November 2022 the signing of a letter of intent with AllianceBernstein to combine the equity research and execution businesses in a joint venture to create a leading global franchise in these activities. This announcement was followed by the signature of an acquisition agreement in early February 2023.

The conclusion of final agreements on these strategic transactions depends on several stakeholders and, accordingly, is subject to a degree of uncertainty. The inability to close on the transactions would not have an immediate impact on the Group’s activity, but could potentially weigh on the share price, at least temporarily.

Societe Generale has placed Environmental, Social and Governance (ESG) at the heart of its strategy in order to contribute to positive transformations in the environment and the development of local regions. In this respect, the Group has made a certain number of commitments (see Chapter 2, page 46 and following and Chapter 5, page 289 and following). Failure to comply with these commitments, and those that the Group may make in the future, could harm its reputation. Furthermore, the rollout of these commitments may have an impact on the Group’s business model. Last, failure to make specific commitments could also generate reputation and strategic risk.

The Group may face execution risk on these strategic projects, which are to be carried out simultaneously. Any difficulty encountered during the process of integrating the activities (particularly from a human resources standpoint) is likely to generate higher integration costs and lower-than-anticipated savings, synergies and benefits. Moreover, the process of integrating the acquired operational businesses into the Group could disrupt the operations of one or more of its subsidiaries and divert General Management’s attention, which could have a negative impact on the Group’s business and results.

2.1.1.3 The Group is subject to an extended regulatory framework in each of the countries in which it operates and changes to this regulatory framework could have a negative effect on the Group’s businesses, financial position and costs, as well as on the financial and economic environment in which it operates.

The Group is subject to the laws of the jurisdictions in which it operates. This includes French, European and US legislation as well as other local laws in light of the Group’s cross-border activities, among other factors. The application of existing laws and the implementation of future legislation require significant resources that could affect the Group’s performance. In addition, possible failure to compliance with laws could lead to fines, damage to the Group’s reputation, force the suspension of its operations or, in extreme cases, the withdrawal of operating licences.

Among the laws that could have a significant influence on the Group:

several regulatory changes are still likely to significantly alter the framework for Market activities: (i) the possible strengthening of transparency constraints related to the implementation of the new requirements and investor protection measures (review of MiFID II/MiFIR, IDD, ELTIF (European Long-Term Investment Fund Regulation)), (ii) the implementation of the fundamental review of the trading book, or FRTB, which may significantly increase requirements applicable to European banks and (iii) possible relocations of clearing activities could be requested, despite the European Commission’s decision of 8 February 2022 to extend the equivalence granted to UK central counterparties until 30 June 2025;

new requirements resulting from the EU banking regulation reform proposal presented on 27 October 2021 by the European Commission. The reform consists of several legislative instruments to amend the directive on capital requirements (European Parliament and EU Council, Directive 2013/36/EU, 26 June 2013) as well as the regulation on capital requirements (CRR) (European Parliament and EU Council, regulation (EU) No. 575/2013, 26 June 2013);

in the United States, the implementation of the Dodd-Frank Act has almost been finalised. The Securities and Exchange Commission’s (SEC) regulations relating to security-based swap dealers have been implemented and Societe Generale has been registered with the SEC as a Securities Based Swap Dealer;

european measures aimed at restoring banks’ balance sheets, especially through active management of non-performing loans (“NPLs”), which are leading to a rise of prudential requirements and an adaptation of the Group’s strategy for managing NPLs. More generally, additional measures to define a framework of good practices for granting (e.g., loan origination orientations published by the European Banking Authority) and monitoring loans could also have an impact on the Group;

the strengthening of data quality and protection requirements and a future strengthening of cyber-resilience requirements in relation to the adoption by the Council on 28 November 2022, which completes the legislative process, of the European directive and regulation package on digital operational resilience for the financial sector;

the implementation of the European sustainable finance regulatory framework, with an increase in non-financial reporting obligations, enhanced inclusion of environmental, social and governance issues in risk management activities and the inclusion of such risks in the supervisory review and assessment process (Supervisory Review and Evaluation Process, or SREP);

the strengthening of the crisis prevention and resolution regime set out in the Bank Recovery and Resolution Directive of 15 May 2014 (“BRRD”), as revised, which gives the Single Resolution Board (“SRB”) the power to initiate a resolution procedure towards a credit institution when the point of non-viability is considered reached. In this context, the SRB could, in order to limit the cost to the taxpayer, force some creditors and the shareholders of the Group to incur losses in priority. Should the resolution mechanism be triggered, the Group could, in particular, be forced to sell certain of its activities, modify the terms and conditions of the remuneration of its debt instruments, issue new debt instruments, accept a depreciation of its debt instruments or convert them into equity securities.

New legal and regulatory obligations could also be imposed on the Group in the future, such as:

-

the ongoing implementation in France of consumer-oriented measures affecting retail banking,

-

the potential requirement at the European level to open more access to banking data to third-party service providers,

-

new obligations arising from a package of proposed measures announced by the European Commission on 20 July 2021 aiming to strengthen the European supervisory framework around the fight against money laundering and terrorist financing, as well as the creation of a new European agency to fight money laundering;

from 2023, new regulatory texts will enter into force concerning rate risk of Banking Book (stress on IM, caps on maturity of deposits flows, ...) and credit rate of banking portfolio. These new texts could constrain certain aspects of rate and credit risk monitoring.

The Group is also subject to complex tax rules in the countries where it operates. Changes in applicable tax rules, uncertainty regarding the interpretation of certain evolutions or their effects may have a negative impact on the Group’s business, financial position and costs.

Moreover, as an international bank that handles transactions with US persons, denominated in US dollars, or involving US financial institutions, the Group is subject to US regulations relating in particular to compliance with economic sanctions, the fight against corruption and market abuse. More generally, in the context of agreements with US and French authorities, the Group largely implemented, through a dedicated programme and a specific organisation, corrective actions to address identified deficiencies and strengthen its compliance programme. In the event of a failure to comply with relevant US regulations, or a breach of the Group’s commitments under these agreements, the Group could be exposed to the risk of (i) administrative sanctions, including fines, suspension of access to US markets, and even withdrawals of banking licences, (ii) criminal proceedings, and (iii) damage to its reputation.

2.1.1.4 Increased competition from banking and non-banking operators could have an adverse effect on the Group’s business and results, both in its French domestic market and internationally.

Due to its international activity, the Group faces intense competition in the international and local markets in which it operates, whether from banking or non-banking actors. As such, the Group is exposed to the risk of not being able to maintain or develop its market share in its various activities. This competition may also lead to pressure on margins, which would be detrimental to the profitability of the Group’s activities.

Consolidation in the financial services industry could result in the competitors benefiting from greater capital, resources and an ability to offer a broader range of financial services. In France and in the other main markets where the Group operates, the presence of major domestic banking and financial actors, as well as new market participants (notably neo-banks and online financial services providers), has increased competition for virtually all products and services offered by the Group. New market participants such as “fintechs” and new services that are automated, scalable and based on new technologies (such as blockchain) are developing rapidly and are fundamentally changing the relationship between consumers and financial services providers, as well as the function of traditional retail bank networks. Competition with these new actors could be exacerbated by the emergence of substitutes for central bank currency (crypto-currencies, digital central bank currency, etc.), which themselves carry risks.

Moreover, competition is also enhanced by the emergence of non-banking actors that, in some cases, may benefit from a regulatory framework that is more flexible and in particular less demanding in terms of equity capital requirements.

To address these challenges, the Group has implemented a strategy, in particular with regard to the development of digital technologies and the establishment of commercial or equity partnerships with these new actors (such as Lumo, the platform offering green investments, or Shine, the neobank for professionals). In this context, additional investments may be necessary for the Group to be able to offer new innovative services and to be competitive with these new actors. This intensification of competition could, however, adversely affect the Group’s business and results, both on the French market and internationally.

2.1.1.5 Environmental, social and governance (ESG) risks, in particular related to climate change, could have an impact on the Group’s activities, results and financial situation in the short-, medium- and long-term.

Environmental, social and governance (ESG) risks are defined as risks stemming from the current or prospective impacts of ESG factors on counterparties or invested assets of financial institutions. ESG risks are seen as aggravating factors to the traditional categories of risks (credit risks, counterparty risks, market risks, structural risks (including liquidity and funding risks), operational risks, reputational risks, compliance risks and risks related to insurance activities) and are likely to impact the Group’s activities, results and financial position in the short, medium and long-term.

The Group is thus exposed to environmental risks, and in particular climate change risks through certain of its financing, investment and service activities. Concerning climate risks, a distinction is made between (i) physical risk, with a direct impact on entities, people and property stemming from climate change and the multiplication of extreme weather events; and (ii) transition risk, which results from the process of transitioning to a low-carbon economy, such as regulatory or technological disruptions or changes in consumer preferences.

The Group could be exposed to physical risk resulting from a deterioration in the credit quality of its counterparties whose activity could be negatively impacted by extreme climatic events or long-term gradual changes in climate, and through a decrease in the value of collateral received (particularly in the context of real estate financing in the absence of guarantee mechanisms provided by specialized financing companies).

Beyond the risks related to climate change, risks more generally related to environmental degradation (such as the risk of loss of biodiversity) are also aggravating factors to the Group’s risks. The Group could notably be exposed to credit risk on a portion of its portfolio, linked to lower profitability of some of its counterparties due, for example, to increasing legal and operating costs (for instance due to the implementation of new environmental standards).

In addition, the Group is exposed to social risks, related for example to non-compliance by some of its counterparties with labour rights or workplace health and safety issues, which may trigger or aggravate reputational and credit risks for the Group.

Similarly, risks relating to governance of the Group’s counterparties and stakeholders (suppliers, service providers, etc.), such as an inadequate management of environmental and social issues, could generate credit and reputational risks for the Group.

Beyond the risks related to its counterparties or invested assets, the Group could also be exposed to risks related to its own activities. Therefore, the Group is exposed to physical climate risk with respect to its ability to maintain its services in geographical areas impacted by extreme events (floods, etc.).

The Group also remains exposed to specific social and governance risks, relating for example to the operational cost of implementation of regulations related to labour laws and the management of its human resources.

All of these risks could have an impact on the Group’s business, results and reputation in the short-, medium- and long-term.

2.1.1.6 The Group is subject to regulations relating to resolution procedures, which could have an adverse effect on its business and the value of its financial instruments.

The BRRD and Regulation (EU) No. 806/2014 of the European Parliament and of the Council of the European Union of 15 July 2014 (the Single Resolution Mechanism, or “SRM”) define a European Union-wide framework for the recovery and resolution of credit institutions and investment firms. The BRRD provides the authorities with a set of tools to intervene early and quickly enough in an institution considered to be failing so as to ensure the continuity of the institution’s essential financial and economic functions while reducing the impact of the failure of an institution on the economy and the financial system (including the exposure of taxpayers to the consequences of the failure). Under the SRM Regulation, a centralized resolution authority is established and entrusted to the SRB and national resolution authorities.

The powers granted to the resolution authority under the BRRD and the SRM Regulations include write-down/conversion powers to ensure that capital instruments and eligible liabilities absorb the Group’s losses and recapitalize it in accordance with an established order of priority (the “Bail-in Tool”). Subject to certain exceptions, losses are borne first by the shareholders and then by the holders of additional Tier 1 and Tier 2 capital instruments, then by the non-preferred senior debt holders and finally by the senior preferred debt holders, all in the order of their claims in a normal insolvency proceeding. The conditions for resolution provided by the French Monetary and Financial Code implementing the BRRD are deemed to be met if: (i) the resolution authority or the competent supervisory authority determines that the institution is failing or likely to fail; (ii) there is no reasonable perspective that any measure other than a resolution measure could prevent the failure within a reasonable timeframe; and (iii) a resolution measure is necessary to achieve the resolutions’ objectives (in particular, ensuring the continuity of critical functions, avoiding a significant negative effect on the financial system, protecting public funds by minimizing the recourse to extraordinary public financial support, and protecting customers’ funds and assets) and the winding up of the institution under normal insolvency proceedings would not meet these objectives to the same extent.

The resolution authority could also, independently of a resolution measure or in combination with a resolution measure, proceed with the write-down or conversion of all or part of the Group’s capital instruments (including subordinated debt instruments) into equity if it determines that the Group will no longer be viable unless it exercises this write-down or conversion power or if the Group requires extraordinary public financial support (except where the extraordinary public financial support is provided in the form defined in Article L. 613-48 III, 3° of the French Monetary and Financial Code).

The Bail-in Tool could result in the write-down or conversion of capital instruments in whole or in part into ordinary shares or other ownership instruments.

In addition to the Bail-in Tool, the BRRD provides the resolution authority with broader powers to implement other resolution measures with respect to institutions that meet the resolution requirements, which may include (without limitation) the sale of the institution’s business segments, the establishment of a bridge institution, the split of assets, the replacement or substitution of the institution as debtor of debt securities, changing the terms of the debt securities (including changing the maturity and/or amount of interest payable and/or the imposition of a temporary suspension of payments), the dismissal of management, the appointment of a provisional administrator and the suspension of the listing and admission to trading of financial instruments.

Before taking any resolution action, including the implementation of the Bail-in Tool, or exercising the power to write down or convert relevant capital instruments, the resolution authority must ensure that a fair, prudent and realistic valuation of the institution’s assets and liabilities is made by a third party independent of any public authority.

The application of any measure under the French implementing provisions of the BRRD or any suggestion of such application to the Group could have a material adverse effect on the Group’s ability to meet its obligations under its financial instrument and, as a result, holders of these securities could lose their entire investment.

In addition, if the Group’s financial condition deteriorates, the existence of the Bail-in Tool or the exercise of write-down or conversion powers or any other resolution tool by the resolution authority (independently of or in combination with a resolution) if it determines that Societe Generale or the Group will no longer be viable could result in a more rapid decline in the value of the Group’s financial instruments than in the absence of such powers.

3 RISK MANAGEMENT ORGANISATION

 

IN BRIEF

This section describes Societe Generale’s risk management approaches and strategies. It describes how the functions in charge of risk management are organised, how these functions guarantee their independence and how they broadcast the risk culture within the Group.

3.1 SUITABILITY OF RISK MANAGEMENT SYSTEMS

The Pillar 3 report, published under the responsibility of Societe Generale Group’s Senior Management, sets out, in accordance with the CRR regulation, the quantitative and qualitative information on Societe Generale’s capital, liquidity and risk management to ensure transparency in respect of the various market players. This information has been prepared in compliance with the internal control procedures approved by the Board of Directors in the course of the validation of the Group Risk Appetite Framework and Group Risk Appetite Statement, and are based, among other things, on the annual review, by General Management in the Group Internal Control Coordination Committee (GICCC) and by the Risk Committee of the Board of Directors, of Societe Generale's Risk division, particularly in its ability to exercise its role as the second line of defense for the entire Group.

3.2 RISK APPETITE

Risk appetite is defined as the level of risk that the Group is prepared to accept to achieve its strategic and financial goals.

The Group’s ambition is to push ahead with sustainable development based on a diversified and balanced banking model with a strong European anchor and a targeted global presence in selected areas of strong business expertise. The Group also wishes to maintain long-term relationships with its clients built on the mutual confidence deserved and to meet the expectations of all of its stakeholders by providing them with responsible and innovative financial solutions.

This is reflected in:

an organisation with 14(1) Business Units offering various products and services to the Group’s clients in different geographic locations;

balanced selective capital allocation between activities:

-

a preponderance of retail banking activities in France and abroad, which currently represent more than 50% of risk weighted assets (“RWA”) of the Group,

-

limitation of Business Unit Global Markets’ share in the RWA of the Group. In accordance with its client-focused development strategy, the Group ceased its trading activities for its own account(2) in 2019, and finalised its project to simplify the products processed in 2021,

-

non-bank services activities, in particular Insurance and operating leasing activities are conducted in line with the business strategy; they demonstrate a disciplined risk profile and thus generate profitability compliant with the Group’s expectations;

a geographically balanced model:

-

in Retail Banking, the Group focuses on international development (excluding Russia) where it benefits from a historical presence, extensive market knowledge and top-tier positions, in Retail Banking activities,

-

as regards Global Banking and Investor Solutions, apart from historical establishments, the Group targets activities for which it can leverage international expertise;

a targeted growth policy, favoring existing areas of expertise, the sound quality business fund and the search for synergies in the diversified banking model;

a positive and sustainable contribution to the transformations of our economies, in particular with regard to the technological revolution, and economic, social and environmental transitions; CSR concerns are therefore at the heart of its strategy and the Group’s relationships with stakeholders (internal and external);

a strong vigilance as regards its reputation, deemed by the Group to be a high-value asset which must be protected.

The Group seeks to achieve sustainable profitability, relying on a robust financial profile consistent with its diversified banking model, by:

aiming for profitable and resilient business development;

maintaining a rating allowing access to financial resources at a cost consistent with the development of the Group’s businesses and its competitive positioning;

calibrating its capital and hybrid debt monitorings to ensure:

-

meeting the minimum regulatory requirements on regulatory capital ratios,

-

compliance with the financial conglomerate ratio which considers the combined solvency of the Group’s banking and insurance activities,

-

one-year coverage of the “internal capital requirement” using available CET1 capital,

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a sufficient level of creditor protection consistent with a debt issuance program that is particularly hybrid consistent with the Group’s objectives in terms of rating and regulatory ratios such as Tier 1, TLAC (“Total Loss Absorbing Capacity”), MREL (“Minimum Required Eligible Liabilities”), and the leverage ratio;

(1)

Fourteen BUs, as CDN and BDDF have merged on 1 January.

(2)

In accordance with French Banking Law, the few residual trading activities of the Group unrelated to clients were isolated in a dedicated subsidiary called Descartes Trading.

ensuring resilience of its liabilities, which are calibrated by taking into account a survival horizon in a liquidity stress ratio, compliance with LCR (Liquidity Coverage Ratio) and NSFR (Net Stable Funding Ratio) regulatory ratios and the level of dependence on short-term fundings and the foreign exchange needs of the Group’s businesses, particularly in dollars;

controlling the leverage ratio.

Credit risk appetite is managed through a system of credit policies, risk limits and pricing policies.

When it takes on credit risk, the Group focuses on medium- and long-term client relationships, targeting both clients with which the Bank has an established relationship of trust and prospects representing profitable business development potential over the mid-term.

Acceptance of any credit commitment is based on in-depth client knowledge and a thorough understanding of the purpose of the transaction.

In particular, concerning the underwriting risk, the Group, mainly through GLBA, makes a “steadfast commitment” to transactions at a guaranteed price as debt financing arranger, prior to syndicating them to other banking syndicates and institutional investors. If market conditions deteriorate or markets close while the placement is under way, these transactions may create a major over-concentration risk (or losses, if the transaction placement requires selling below the initial price).

The Group limits the cumulative amount of approved underwriting or underwriting positions in order to limit its risk in the event of a prolonged closure of the debt markets.

In a credit transaction, risk acceptability is based first on the borrower’s ability to meet its commitments, in particular through the cash flows which will allow the repayment of the debt. For medium and long-term operations, the funding duration must remain compatible with the economic life of the financed asset and the visibility horizon of the borrower’s cash flow.

Security interests are sought to reduce the risk of loss in the event of a counterparty defaulting on its obligations, but may not, except in exceptional cases, constitute the sole justification for taking the risk. Security interests are assessed with prudent value haircuts and paying special attention to their actual enforceability.

Complex transactions or those with a specific risk profile are handled by specialised teams within the Group with the required skills and expertise.

The Group seeks risk diversification by controlling concentration risk and maintaining a risk allocation policy through risk sharing with other financial partners (banks or guarantors).

Counterparty ratings are a key criterion of the credit policy and serve as the basis for the credit approval authority grid used in both the commercial and risk functions. The rating framework relies on internal models. Special attention is paid to timely updating of ratings (which, in any event, are subject to annual review)(1).

The risk measure of the credit portfolio is based primarily on the Basel parameters that are used to calibrate the capital need. As such, the Group relies for the internal rating of counterparties on Balois models allowing the assessment of credit quality, supplemented for “non-retail” counterparties, by expert judgment. These measures are complemented by an internal stress-sized risk assessment, either at the global portfolio level or at the sub-portfolio level, linking risk measures and rating migration to macro-economic variables most often to say expert. In addition, the calculation of expected losses under the provisions of IFRS 9, used to determine the level of impairment on healthy outstandings, provides additional insight into assessing portfolio risk.

In consultation with the Risk Department, the businesses implement, most of the time, pricing policies that are differentiated according to the level of risk of counterparties and transactions. The purpose of pricing a transaction is to ensure acceptable profitability, in line with the objectives of ROE (Return on Equity) of the business or entity, after taking into account the cost of the risk of the transaction in question. The pricing of an operation can nevertheless be adapted in certain cases to take into account the overall profitability and the potential customer relationship development. The intrinsic profitability of products and customer segments is subject to periodic analysis in order to adapt to changes in the economic and competitive environment.

Proactive management of counterparties whose situation has deteriorated is key to containing the risk of final loss in the event of counterparty failure. As such, the Group has put in place rigorous procedures for monitoring non retail counterparties and/or for closer monitoring of retail counterparties whose risk profiles are deteriorating. In addition, the businesses and entities, in conjunction with the Risk and Finance Departments, and through collaborators specialising in recovery and litigation, work together to effectively protect the Bank’s interests in the event of default.

Concerning ESG risks (Environmental, Social & Governance), the assessment and management of the impact of ESG risk factors on credit risk is based in particular on the establishment of exclusion lists, portfolio alignment indicators (oil and gas and electricity production for example) and sensitivity analyses (in particular transition risk via the CCVI or Corporate Climate Vulnerability Index).

In general, credit granting policies must comply with the criteria defined within the framework of the Group’s Social and Environmental Responsibility (CSR) policy, which is broken down through:

the general environmental and social principles and the sectoral and cross-cutting policies appended to them. Sector policies cover sectors considered potentially sensitive from an environmental, social or ethical point of view;

the targets for alignment with the objectives of the Paris agreement, which the Group has set itself, starting with the sectors with the highest CO2 emissions;

commitment to granting sustainable financing classified as Sustainable and Positive Impact Finance and to sustainability linked transactions.

Risks related to climate change (physical and transition risks), which are an aggravating factor in the types of risks facing the Bank must be taken into account in risk assessment processes. An assessment of climate vulnerability (particularly in terms of transition risk) must be provided by the Business Unit for certain specific sectors and may have an impact on the internal rating so that it incorporates the client’s adaptation strategy (See also section 4.13 “Environmental, social and governance risks” of this Universal Registration Document).

(1)

For non-automated processes.

The future value of exposure to a counterparty as well as its credit quality are uncertain and variable over time, both of which are affected by changes in market parameters. Thus, counterparty credit risk management is based on a combination of several types of indicators:

indicators of potential future exposures (potential future exposures, or PFE), aimed at measuring exposure to our counterparties:

-

the Group controls idiosyncratic counterparty credit risks via a set of CVaR(1) limits. The CVaR measures the potential future exposure linked to the replacement risk in the event of default by one of the Group’s counterparties. The CVaR is calculated for a 99% confidence level and different time horizons, from one day until the maturity of the portfolio,

-

in addition to the risk of a counterparty default, the CVA (Credit Valuation Adjustment) measures the adjustment of the value of our portfolio of derivatives and repos account the credit quality of our counterparties;

the abovementioned indicators are supplemented by stress test impacts frameworks or on nominal ones in order to capture risks that are more difficult to measure:

-

the more extreme correlation risks are measured via stress tests at different levels (wrong-way risk, stress monitoring at sector level, risk on collateralised financing activities and agency),

-

the CVA risk is measured via a stress test in which representative market scenarios are applied, notably involving the credit spreads of our counterparties;

exposures to central counterparty clearing houses (CCP) are subject to specific supervision:

-

the amount of collateral posted for each segment of a CCP: the initial posted margins, both for our principal and agency activities, and our contributions to CCP default funds,

-

in addition, a stress test measures the impact linked to (i) the default of an average member on all segments of a CCP and (ii) the failure of a major member on a segment of a CCP;

the Global Stress Test on market activities includes cross market-counterparty risks, it is described in more detail in the “Market risk” section;

besides, a specific framework that has been set up aims to avoid individual concentration related to counterparty risk in market operations.

The Group’s market activities are carried out as part of a business development strategy primarily focused on meeting client requirements through a full range of products and solutions.

Market risk is managed through a set of limits for several indicators (such as stress tests, Value at Risk (VaR) and stressed Value at Risk (SVaR), “Sensitivity” and “Nominal” indicators). These indicators are governed by a series of limits proposed by the business lines and approved by the Risk Division during the course of a discussion-based process.

The choice of limits and their calibration reflect qualitatively and quantitatively the fixing of the Group’s appetite for market risks. A regular review of these frameworks also enables risks to be tightly controlled according to changing market conditions with, for example, a temporary reduction of limits in case of a deterioration. Warning thresholds are also in place to prevent the possible occurrence of overstays.

Limits are set at different sub-levels of the Group, thereby cascading down the Group’s risk appetite from an operational standpoint within its organisation.

Within these limits, the Global Stress Test limits on market activities and the Market Stress Test limits play a pivotal role in determining the Group’s market risk appetite; in fact, these indicators cover all operations and the main market risk factors as well as risks associated with a severe market crisis which helps limit the total amount of risk and takes account of any diversification effects.

Non-financial risks are defined as non-compliance risk, risk of inappropriate conduct, IT risk, cybersecurity risk, other operational risks, including operational risk associated with credit risk, market risk, model risk, liquidity and financing, structural and rate risk. These risks can lead to financial losses.

Governance and a methodology have been put in place for the scope of non-financial risks.

As a general rule, the Group has no appetite for operational risk or for non-compliance risk. Furthermore, the Group maintains a zero-tolerance policy on incidents severe enough to potentially inflict serious harm to its image, jeopardise its results or the trust displayed by customers and employees, disrupt the continuity of critical operations or call into question its strategic focus.

The Group underscores that it has is no or very low tolerance for operational risk involving the following:

internal fraud: the Group does not tolerate unauthorised trading by its employees. The Group’s growth is founded on trust, as much between employees as between the Group and its employees. This implies respecting the Group’s principles at every level, such as exercising loyalty and integrity. The Group’s internal control system must be capable of preventing acts of major fraud;

cybersecurity: the Group has zero tolerance for fraudulent intrusions, disruption of services, compromise of elements of its information system, in particular those which would lead to theft of assets or theft of customer data. The Bank aims to put in place effective means to prevent and detect this risk. It has a barometer that measures the degree of maturity of the cybersecurity controls deployed within its entities and the appropriate organisation to deal with any incidents;

data leaks: trust is the main asset of the Societe Generale Group. Consequently the Group is committed to deploying the necessary resources and implementing controls to prevent, detect and remediate data leaks. It does not tolerate any leaks of its most sensitive information, in particular that of customer data;

(1)

The CVaR economic indicator is built on the samemodeling assumptions as the regulatory Effective Expected Positive Exposure (EEPE) indicator used to calculate RWAs.

business continuity: the Group relies heavily on its information systems to perform its operations and is therefore committed to deploying and maintaining the resilience of its information systems to ensure the continuity of its most essential services. The Group has very low tolerance for the risk of downtime in its information systems that perform essential functions, in particular systems directly accessible to customers or those enabling to conduct business on financial markets;

outsourced services: the Group seeks to achieve a high degree of thoroughness in the control of its activities entrusted to external service providers. As such, the Group adheres to a strict policy of reviewing its providers the frequency of which depends on their level of risk;

managerial continuity: the Group intends to ensure the managerial continuity of its organisation to avoid the risk of a long-term absence of a manager that would question the achievement of its strategic objectives, which might threaten team cohesion or disrupt the Group’s relationships with its stakeholders;

physical security: the Societe Generale Group applies security standards to protect personnel, tangible and intangible assets in all the countries where it operates. The Group Security Department ensures the right level of protection against hazards and threats, in particular through security audits on a list of sites that it defines;

execution errors: the Societe Generale Group has organized its day-to-day transaction processes and activities through procedures designed to promote efficiency and mitigate the risk of errors. Notwithstanding a robust framework of internal control systems, the risk of errors cannot be completely avoided. The Group has a low tolerance for execution errors that would result in very high impacts for the Bank or its clients.

The Group measures and strictly controls structural risks. The mechanism whereby rate risk, foreign exchange risk and the risk on pension/long-service obligations is controlled is based on sensitivity or stress limits which are broken down within the various businesses (entities and business lines).

There are four main types of risk: rate level risk, curve risk book, optional risk (arising from automatic options and behavioral options) and basis risk, related to the impact of relative changes in interest rates indices. The Group’s structural interest rate risk management primarily relies on the sensitivity of Net Present Value (“NPV”) of fixed-rate residual positions (excesses or shortfalls) to interest rate changes according to several interest rate scenarios. The limits are established either by the Board of Directors or by the Finance Committee, at the Business Unit/Service Unit and Group levels. Furthermore, the Group measures and controls the sensitivity of its net interest margin (“NIM”) on different horizons.

The Group’s policy in terms of structural exchange rate risks consists of limiting as much as possible the sensitivity of its CET1 capital ratio to changes in exchange rates, so that the impact on the CET1 ratio of an appreciation or a depreciation of all currencies against the euro does not exceed a certain threshold in terms of bp by summing the absolute values of the impact of each currency.

Regarding risks to pension and long-service obligations, which are the Bank’s long-term obligations towards its employees, the amount of the provision is monitored for risk on the basis of a specific stress test and an attributed limit. The risk management policy has two main objectives: reduce risk by moving from defined-benefit plans to defined-contribution plans and optimise asset risk allocation (between hedge assets and performance assets) where allowed by regulatory and tax constraints.

Controlling liquidity risk is based primarily on:

compliance with regulatory liquidity ratios, with precautionary buffers: LCR (liquidity coverage ratio) ratios that reflect a stress situation and NSFR (net stable funding ratio);

compliance with a minimum survival horizon under combined market and idiosyncratic stress;

framing of transformation and anti-transformation positions (price risk).

Controlling financing risk is based on:

maintaining a liability structure to meet the Group’s regulatory constraints (Tier1, Total Capital, Leverage, TLAC, NSFR, MREL) and complying with rating agencies’ constraints to secure a minimum rating level;

recourse to market financing: annual long-term issuance programs and a stock of moderate structured issues and short-term financing raised by supervised treasuries.

The Group is committed to defining and deploying internal standards to reduce model risk on the basis of key principles, including the creation of three independent lines of defence, the proportionality of due diligence according to each model’s level of risk inherent, the consideration of the models’ entire lifecycle and the appropriateness of the approaches within the Group.

A wrong design, implementation, use or a non rigorous models monitoring can have two mains unfavorable consequences: an under estimation of equity based of models validated by Regulators and/or financial losses.

Risk model appetite is defined for the perimeter of this group of models: credit risk IRB and IFRS 9, market and counterparty risk, market product valuation, ALM, trading model, compliance and granting.

The Group conducts Insurance activities (Life Insurance and Savings, Retirement savings, Property & Casualty Insurance, etc.) which exposes the Group to two major types of risks:

subscription risk related to pricing and fluctuations in the claims ratio;

risks related to financial markets (interest rate, credit and equity) and asset-liability management.

The Group has limited appetite for financial holdings, such as proprietary private equity transactions. The investments allowed are mainly related to:

commercial support for the network through the private equity activity of the Societe Generale and Crédit du Nord network and certain subsidiaries abroad;

taking stakes, either directly or through investment funds, in innovative companies via SG Ventures;

the takeover of stakes in local companies: Euroclear, Crédit Logement, etc., which does not have limit.

The settlement-delivery risk on financial instruments arises when transactions (over-the-counter in cash or forward) give rise to a time lag (usually of a few hours) between the payment and the delivery of the underlying (securities, raw materials, foreign exchange, etc.) during their settlement.

The Group defines a risk appetite for delivery risk in relation to the quality of the counterparty (via its rating) with larger limits granted to counterparties in the investment grade category (IG).

3.3 RISK APPETITE – GENERAL FRAMEWORK

Risk appetite is determined at Group level and attributed to the businesses and subsidiaries. Monitoring of risk appetite is performed according to the principles described in the Risk Appetite Framework governance and implementation mechanism, which are summarised below.

As part of the supervision of risk appetite, the Group relies on the following organisation:

the Board of Directors:

-

approves each year the Group Risk Appetite Statement and the Group Risk Appetite Framework, as well as the Group Risk Appetite Framework,

-

approves in particular the main Group risk appetite indicators (Board of Directors indicators) validated beforehand by General Management,

-

ensures that risk appetite is relevant to the Group’s strategic and financial objectives and its vision of the risks of the macro-economic and financial environment,

-

reviews quarterly the risk appetite dashboards presented to it, and is informed of risk appetite overruns and remediation action plans,

-

sets the compensation of corporate officers, sets out the principles of the remuneration policy applicable in the Group, especially for regulated persons whose activities may have a significant impact on the Group’s risk profile, and ensures that they are in line with risk management objectives.

The Board of Directors relies primarily on the Risk Committee;

General Management:

-

approves the document summarizing the Group’s risk appetite Statement and its Risk Appetite Framework based on the proposal of the Chief Risk Officer and the Chief Financial Officer,

-

regularly ensures that risk appetite is complied with,

-

ensures the effectiveness and integrity of the risk appetite implementation system,

-

ensures that the risk appetite for the Group’s Business Units and eligible subsidiaries/branches is formalised and translated into frameworks consistent with the Group’s risk appetite,

-

ensures internal communication of risk appetite and its transposition in the Universal Registration Document.

In addition, the main mission of the Risk Department is to draw up the document summarizing the Group’s risk appetite, as well as the implementation of a risk management, monitoring and control system.

The Finance Department contributes to setting this risk appetite in the framework of indicators under the responsibility of the Finance Committee (profitability, solvency, liquidity and structural risks).

The Compliance Department is also responsible for instructing the risk appetite setting for indicators falling within its scope.

The risk identification process is a key process of the Group risk-management framework. It is a Group-wide process to identify all risks that are or might be material. The approach is comprehensive and holistic: it covers all risk types(1) and all Group exposures.

In addition to the annual review of the Group’s risk taxonomy yearly reviewed and published in the SG Code, risk identification process is based on two pillars in order to ensure a complete and up-to-date view of all the material risks facing the Group:

risk management governance and key Committees such as CORISQs or COFI (at Group or Business Unit level), COMCO and New Product Committees making it possible to monitor changes in the risk profile for all types of risk (credit, market, operational, etc.). In addition to monitoring well-identified risks, this governance can also generate a debate between risk experts and senior management on emerging risks. This debate is fueled by the latest market news, early warning signals, internal alerts, and more;

(1)

Risks are classified on the basis of the Group’s risk taxonomy, which names and defines risk categories and their possible sub-categories.

a series of exercises aimed at identifying additional risks, for example arising from changes in macroeconomic or sectoral conditions, financial markets, regulatory constraints, competitors or market pressure, business model (concentration effects) and changes in banking organisations. These additional identification exercises are also organised by risk types, but include some identification of cross-risk effects (e.g. credit and market or credit and operational). For a given type of risk, these exercises analyse and segment the Group’s exposure along several axes (Business Unit, activity, customer, product, region, etc.). The underlying risk factors are identified for the perimeters where this risk is assessed as being significant.

When a significant risk is identified, a risk management system, which may include a quantitative risk appetite (risk ceiling or threshold) or a risk policy, is implemented.

In addition, where possible, the risk factors underlying a significant risk are identified and combined in a dedicated scenario, and the associated loss is then quantified by means of a stress test (see also section “Risk quantification and stress test system”).

Within the Group, stress tests, a key attribute of risk management, contribute to the identification, measurement and management of risks, as well as to the assessment of the adequacy of capital and liquidity to the Group’s risk profile.

The purpose of the stress tests is to cover and quantify, resulting from the Risk Identification annual process, all the material risks to which the Group is exposed and to inform key management decisions. They thus assess what the behavior of a portfolio, an activity, an entity or the Group would be in a degraded business context. It is essential in building the forward-looking approach required for strategic/financial planning. In this context, they constitute a privileged measure of the resilience of the Group, its activities and its portfolios, and are an integral part of the process of developing risk appetite.

The Group stress testing framework combines stress tests in line with the stress testing taxonomy set by the EBA. Group-wide stress tests should cover all legal entities in the Group consolidation perimeter, subject to risk materiality.

Stress test categories are:

stress tests based on scenarios: application of historical and/or hypothetical conditions but which must remain plausible and in conjunction with the Economic and Sector Studies department, to a set of risk factors (interest rates, GDP, etc.);

sensitivity stress tests: assessment of the impact of the variation of an isolated risk factor or of a reduced set of risk factors (a shock in rates, credit rating downgrade, equity index shock, etc.);

reverse stress tests: start with a pre-defined adverse outcome, such as a level of a regulatory ratio, and then identifies possible scenarios that could lead to such an adverse outcome.

The stress test system within the Group thus includes:

global stress tests

Global Group stress tests cover all activities and subsidiaries that are part of the Group’s consolidation scope (“Group-wide”), as well as all major risks (including credit risk, market risk, operational risks, liquidity risk). They aim at stressing both the Group P&L and key balance sheet metrics, notably capital and liquidity ratios.

The central stress test is the overall group stress test, which is based on a central scenario and on adverse macroeconomic scenarios modeled by the Economic Research Department, under the independent supervision of the Group Chief Economist. Macro-economic scenarios are supplemented by other parameters such as capital market conditions, including assumptions on funding.

The performance of the overall Group stress test is based on the uniform application of the methodology and assumptions at the level of all entities and at Group level. This means that the risk factors, and in particular the macro-economic assumptions used locally, must be compatible with the macro-economic scenario defined by the Group. Entities must submit macro-economic variables to the Group’s Economic Studies department to check their consistency.

The regulatory stress test conducted periodically by the EBA also covers all entities and risks and is scenario-based. Therefore, its execution globally mirrors the process defined for the internal Group Global Stress Test, with an increased involvement of the Group central teams, except for the scenario design which is defined by the supervisor;

specific stress tests which assess a specific type of risk (market risk, credit risk, liquidity risk, interest rate risk, etc.):

-

credit risk stress tests complement the global analysis with a more granular approach and allow fine-tuning of the identification, assessment and management of risk, including concentration,

-

market stress tests estimate the loss resulting from a severe change in financial market risk factors (equity indexes, interest rates, credit spreads, exotic parameters, etc.). They apply to all Group’s market activities and rely on adverse historical and hypothetical scenarios,

-

the operational risk assessment relies on an analysis of historical losses, factoring in internal and external loss data as well as the internal framework and the external environment. This includes losses incurred by international financial institutions, and hypothetical forward-looking “scenario analyses” for all operational risk categories,

-

liquidity stress tests which include: (i) a market-wide scenario that attempts to capture a crisis in which financial markets would undergo an extreme market liquidity disruption causing systemic stress event, and (ii) an idiosyncratic scenario that attempts to capture a firm-specific crisis potentially triggered by a material loss, reputational damage, litigation, executive departures,

-

stress tests which assess the sensitivity to structural interest rate risk concerning the banking book. The exercise focuses on rate variations by stressing (i) the net present value of the positions or (ii) the interest margin and on exchange rate fluctuations on the residual exchange positions,

-

a stress test on employment benefits which consists of simulating the impact of variations in market risk factors (inflation, interest rates, etc.) on the Group’s net position (dedicated investments minus the corresponding employment benefits),

-

stress tests on the risk linked to insurance activities defined in the risk appetite of the Insurance Business Unit, which puts stress on risk factors specific to financial and insurance activities to measure and control the main risks relating thereto,

-

climate stress tests based on climate risk scenarios at least once a year. These stress tests may encompass both transition and/or physical risk and may cover short term to medium-long term horizons. These annual climate stress tests can be either global (covering all group exposures) or cover only specific portfolio. Historically, on climate risk, the Group voluntarily participated in exploratory climate stress exercises organized  by the ACPR (Prudential Control and Resolution Authority) and the European Banking Authority in 2020. In 2022, the Group also participated in a stress test coordinated by the European Central Bank (ECB) during the first half of the year (see also Chapter 14 “Environmental, social and governance risks” ),

-

reverse stress tests, both as part of the risk appetite and the recovery plan. The impact of these stress tests is typically defined via a breaking point in the solvency ratio or liquidity indicator, which poses a significant threat to the Bank. Hypothetical scenarios leading to this breaking point are then constructed in order to identify new weaknesses.

In addition to internal stress test exercises, the Group is part of the sample of European banks participating in major international stress tests programs conducted by the European Banking Authority (EBA) and the European Central Bank (ECB).

DEFINITION OF THE “CENTRAL” AND “STRESSED” ECONOMIC SCENARIOS

Central scenario

The central scenario is based first of all on a set of observed factors such as recent economic situation and economic policy shifts (budgetary, monetary and exchange-rate policies). From these observed factors, economists calculate the most likely trajectory of economic and financial variables for the desired forecast horizon.

Stressed scenario

The severity of the stressed scenario, which is determined by the deviation of the GDP trajectory from the central scenario, is based on the magnitude of the 2008-2009 crisis, of the eurozone sovereign crisis, and has been adjusted to take into account the impacts – health, economic and financial – of the Covid-19 crisis on the basis of current knowledge. The severity is constantly compared to that of various adverse scenarios produced by reputable institutions such as the ECB, the Bank of England or the Federal Reserve. In 2022, the Group stress test scenario has been set up in order to take into account the risk of a stagflationary shock.

The Group’s risk appetite is formalised in a document (“Risk Appetite Statement”) which sets out:

the strategic profile of the Group;

its profile of profitability and financial soundness;

the frameworks relating to the management of the Group’s main risks (qualitative, through risk policies, and quantitative, through indicators).

Regarding the profile of profitability and financial soundness, the Finance Department proposes each year, upstream of the budgetary procedure, to the General Management, limits at Group level, supplemented by alert thresholds and crisis levels according to a “traffic light” approach. These frameworks on financial indicators allow:

to respect, with a sufficient safety margin, the regulatory obligations to which the Group is subject (in particular the minimum regulatory solvency, leverage and liquidity ratios), by anticipating as best as possible the implementation of new regulations;

to ensure, via a safety margin, sufficient resistance to stress scenarios (stress standardised by regulators or stress defined according to a process internal to the Group).

The frameworks relating to risk management, also represented via a graduated approach (limits, alert thresholds, etc.), result from a process in which the needs expressed by the businesses are confronted with a contradictory opinion independent from the second line defence. The latter is based on:

independent analysis of risk factors;

the use of prospective measures based on stress approaches;

the proposal for a framework.

For the main risks, the frameworks set make it possible to consolidate the achievement of the Group’s financial targets and to orient the Group’s profitability profile.

The allocation of risk appetite in the organisation is based on the strategic and financial plan, and on risk management systems:

based on recommendations by the Finance Department to General Management, the financial targets defined at Group level are broken down into financial frameworks(1) at business line level, as part of financial management;

the breakdown of frameworks and risk policies is based on an understanding of the needs of the businesses and their business prospects and takes into account the profitability and financial strength targets of the Business Unit and/or the entity.

(1)

A Group framework can be broken down into the businesses through a different indicator; for example, the capital ratios are broken down in the business lines into weighted assets: “RWA”.

3.4 RISK MANAGEMENT ORGANISATION

Implementing a high-performance and efficient risk management structure is a critical undertaking for Societe Generale Group in all businesses, markets and regions in which it operates, as is maintaining a balance between strong awareness of risks and promoting innovation. The Group’s risk management, supervised at the highest level, is compliant with the regulations in force, in particular the order of 3 November 2014 revised by the order of 25 February 2021 on the internal control of companies in the banking sector, Payment Services and Investment Services subject to the control of the French Prudential Supervisory and Resolution Authority (Autorité de contrôle prudentiel et de résolution – ACPR) and the final version of European Regulations Basel 3 (CRR/CRD). (See Board’s Expertise, page 89 of the 2023 Universal Registration Document).

Two main high-level bodies govern Group risk management: the Board of Directors and General Management.

General Management presents the main aspects of, and notable changes to, the Group’s risk management strategy to the Board of Directors at least once a year (more often if circumstances so require).

As part of the Board of Directors, the Risk Committee advises the Board on overall strategy and appetite regarding all kinds of risks, both current and future, and assists the Board when the latter verifies that the strategy is being rolled out.

The Board of Directors’ Audit and Internal Control Committee ensures that the risk control systems operate effectively.

Chaired by General Management, the specialised Committees responsible for central oversight of internal control and risk management are as follows:

the Risk Committee (CORISQ), which met 18 times during the 2022 financial year, aims to:

-

validate the main risk management mechanisms (taxonomy, risk identification, stress testing and Risk Appetite Framework),

-

for credit, counterparties, market, operational, model and environmental risks:

validate the Group’s risk appetite prior to its proposal to the Board of Directors for approval,

then define the Group’s main risk policy guidelines in the context of the risk appetite previously approved by the Board of Directors,

respect the Group’s risk appetite as defined and declined.

Along with the Risks Committee, the Major Risks Committee (Comité Grands Risques) is an ad hoc Committee, responsible for approving the sales and marketing strategy and risk-taking with regard to major client groups (Corporates, Insurance Companies and Asset Managers);

the Finance Committee (COFI), chaired by the Chief Executive Officer, is responsible for setting out the Group’s financial strategy and for ensuring the management of scarce resources (capital, liquidity, balance sheet, tax capacity) and the management of structural risks. COFI oversees all aspects of the management of the structural risks of the Group and its main entities, including the management of liquidity and financing risks, as well as the management of banking book market risks: interest rate, credit spread, exchange and shares, financial management of scarce resources (liquidity and capital), the dividend policy, monitoring the rating assigned to Societe Generale by credit rating agencies, the recovery and resolution plans, monitoring of the Group’s tax capacity, financial management of Corporate Centre and intra-group re-invoicing;

the Compliance Committee (COMCO), chaired by the Chief Executive Officer, reviews the risks of non-compliance, the main issues and defines the Group’s compliance principles. It ensures, on an annual basis, the monitoring of the quality of the Embargoes & Sanctions risk management framework. The Committee also reviews the main compliance incidents of the period and the main information related to Supervisor relationships. It reviews and challenges compliance indicators on each area of non-compliance risk. Finally, it validates the compliance risk appetite criteria, the annual roadmap for mandatory Group trainings, the new modules for all employees, and on an ad hoc basis certain Group compliance topics. In addition, twice a year, a session dedicated to the review of the regulatory system is organized. Its objective is to ensure the consistency and effectiveness of the compliance system with banking and financial regulations;

the Digital Transformation Committee (DTCO), is Chaired by the Deputy General Manager. The purpose of this Committee, in line with the decisions of the Group Strategic Committee, is to initiate and monitor the transformations of the information system and the associated operating model which require, by their transversal nature or by the extent of the transformation envisaged, a decision of the General Management;

the Group Internal Control Coordination Committee (GICCC), is chaired by the Chief Executive Officer or, in his absence, by a Deputy Chief Executive Officer or by the Deputy Chief Executive Officer in charge of supervising the area under review. The purpose of the GICCC is to ensure the consistency and effectiveness of the Group’s internal control, in response in particular to the obligation laid down in Art. 16 of the modified French Order of 3 November 2014. The Committee meets approximately 20 times a year to deal with cross-cutting topics as well as the annual review of each BU/SU;

the Non Financial Risks Steering Committee, chaired by the Head of DGLE/PIC assisted as co-sponsors by the CRO and CCO, aims to develop and instruct the orientations taken by the Group Internal Control Coordination Committee (GICCC) and resulting from the Audit and Internal Control Committee (CACI), to ensure the consistency, efficiency and effectiveness of the transformations of non-financial risk control (NFR) frameworks, to set targets with regard to roadmaps, to validate, coordinate and manage the evolution of NFR frameworks throughout the Group, to highlight risks and alerts related to NFR frameworks, to provide resources, prioritize and decide on their allocation, by making any necessary arbitrations;

the Responsible Commitments Committee (CORESP), chaired by the Deputy Chief Executive Officer in charge of overseeing the ESG policy, deals with all matters falling within the Group’s responsibility in Environmental and Social matters, or those having an impact on the Group’s responsibility or reputation and not already covered by an existing Executive Management Committee. The Committee is decision-making and has authority over the entire Group. Its objective is to (i) arbitrate complex transaction/client cases presenting a high reputational risk or non-alignment with the Group’s standards in terms of CSR, Culture & Conduct, ethics or reputation; (ii) examine subjects with very high CSR, ethical or reputational risks; (iii) make new Group commitments or change the Group’s E&S standards (including sectoral policies); (iv) monitor the implementation of the Group’s E&S commitments; (v) examine opportunities for the development of sustainable and positive impact financing or investments, requiring the opinion or validation of the General Management;

the Group Provisions Committee (COPRO), chaired by the Chief Executive Officer, meets quarterly and is tasked with presenting and validating the Group’s net risk expense (provisions for the credit risk) that will be accounted for the quarter in question.

The Group’s Corporate Divisions, which are independent from the core businesses, contribute to the management and internal control of risks.

The Corporate Divisions provide the Group’s General Management with all the information needed to perform its role of managing Group strategy under the authority of the Chief Executive Officer. The Corporate Divisions report directly to General Management:

the Risk Division

The main role of the Risk Division (RISQ) is to support the development of the Group’s activities and profitability by elaborating the Group’s risk appetite (allocated between the Group’s different business lines) in collaboration with DFIN and the BUs/SUs and establishing a risk management and monitoring system as a second line of defence. In performing its work, the RISQ SU reconciles independence from the businesses with a close working relationship with the BUs, which are responsible in the first instance for the transactions they initiate.

Accordingly, the Risk Division:

-

provides hierarchical and functional supervision for the Group’s Risk Management Function

-

addresses the guidance, with the Finance Service Unit, for setting the Group’s risk appetite as submitted to General Management,

-

identifies all Group risks,

-

implements a governance and monitoring framework for these risks, including cross-business risks, and regularly reports on the nature and extent thereof to General Management, the Board of Directors and the banking supervisory authorities,

-

contributes to the definition of risk policies, taking into account the aims of the core businesses and the relevant risk issues,

-

defines or validates methods and procedures for the analysis, assessment, approval and monitoring of risk,

-

implements a second-level control to ensure the correct application of these methods and procedures,

-

assesses and approves transactions and limits proposed by business managers,

-

defines or validates the architecture of the central risk information system, ensures its suitability to business requirements;

the Finance Service Unit (DFIN) coordinates the Finance Management Function and is responsible for the Group’s financial management, oversight and production through several complementary tasks:

-

fuelling General Management’s discussions on strategic and financial aspects. To this end, DFIN takes care to provide a consistent overview of performance indicators and financial information,

-

managing, at consolidated level for Societe Generale SA and for certain subsidiaries, the establishment and analysis of financial, tax and regulatory statements (regulatory indicators regarding scarce resources, regulatory reports, ICAAP and ILAAP documentation) in compliance with applicable standards and obligations,

-

monitoring and overseeing P&L performance, profitability and scarce resources (capital, liquidity, balance sheet) in line with strategic objectives and in accordance with regulatory obligations,

-

supporting the Business Units and Service Units with financial and strategic oversight,

-

managing liquidity, in particular through the implementation of financing and resilience plans, in accordance with the objectives set by the Group and in compliance with the Group’s risk appetite,

-

maintaining financial crisis management plans tailored to the Group’s configuration,

-

ensuring the management and first-level monitoring of structural interest rate, foreign exchange and liquidity risks as defined in Book B Title V Chapter 6. RISQ assuming the role of second line of defence,

-

performing regulatory watch with respect to scarce resources, accounting and finance, and participating in institutional relations and advocacy with its main peers and with banking federations,

-

acting as enterprise architect for all activities performed by the Group’s Finance Divisions;

the Group Compliance Division is responsible for the definition and consistency of the non-compliance risk prevention and control framework, related to banking and financial regulation and for coordinating the framework aimed at preventing, identifying, assessing and controlling non-compliance risk across the entire Group. It ensures that roles and responsibilities are identified with the appropriate level of expertise so that the regulatory watch framework and related normative documentation, including its deployment, are operational. In particular, it takes care to harmonise procedures and optimise (in conjunction with the BU/SUs) international resources in order to ensure the framework’s effectiveness and compliance with its rules. Within this framework, it has hierarchical and functional authority over the compliance teams of Group entities.

The Group Compliance Service Unit is organised around three broad categories of non-compliance risks:

-

financial security: know your customer (KYC); compliance with the rules and regulations on international sanctions and embargoes; countering money laundering and terrorist financing (AML/CTF), including reporting suspicious transactions to the appropriate financial intelligence authority when necessary,

-

regulatory risks: customers protection; integrity of the financial markets; countering bribery and corruption, ethics and good conduct; compliance with regulations related to tax transparency (based on knowledge of clients’ tax profile); compliance with regulations on social and environmental responsibility and the Group’s commitments,

-

protection of data, including personal data and in particular those of customers;

the Corporate Secretary within its fields of expertise, is assigned with the mission of protecting the Bank in order to further its development. Together with the SUs, BUs and other Societe Generale Group entities, it ensures the administrative, legal and tax compliance of the Group’s activities, both in France and abroad. It is in charge of managing legal and tax risks. It also oversees global Group security (together with the RESG SU in respect of IT systems security), designs and implements the risk insurance policy for the entire Group and its staff, and provides assistance in developing insurance products for the Group’s clients. It devises and oversees the development of corporate social responsibility and public affairs and institutional relations/advocacy initiatives within the Societe Generale Group. Lastly, it handles the Group’s central administration and offers support to the Secretary of the Board of Directors as necessary;

the Human Resources is tasked with defining and implementing the general and individual policies designed to enable the Group to develop the skills and talent needed for its strategy to succeed. The Division’s role as partner to the businesses is key to the Group’s adaptation to its environment;

the Corporate Resources and Innovation Department accompanies the digital transformation and promotes operational efficiency for the Group. It supervises the Resource Management Functions (Information Systems, Sourcing and Property);

the Group Internal Audit and General Inspection Department, under the authority of the General Inspector, is in charge of internal audit; finally

the Sustainable Development Department attached to the general Management, the Group Sustainable Development Division (DGLE/RSE) assists the Deputy Chief Executive Officer in charge of the whole ESG policies (Environmental, Social and Governance) (RSE – Corporate Social Responsibility-) and their actual translation in the business lines and functions trajectories. It supports the Group ESG transformation to make it a major competitive advantage, in the business development as well as in the ESG (Environmental & Social) risks management. DGLE/RSE provides an advising mission to the General Management through three main tasks:

-

the definition and strategic steering of the Group’s ESG ambition,

-

the support of the BUs and SUs ESG transformation,

-

the contribution to promoting the Group’s ESG reach. 

According to the last census carried out on 31 December 2022, the full-time equivalent (FTE) workforce of:

the Group’s Risk Department for the second line of defence represents approximately 4,475 FTEs (1,671 within the Group’s Risk Department itself and 2,804 for the rest of the Risk function);

the Compliance Department or the second line of defence represents approximately 2,934 FTEs;

the Information System Security Department totals approximately 549 FTEs.

The Group’s risk measurement systems serve as the basis for the production of internal Management Reports allowing the monitoring of the Group’s main risks (credit risk, counterparty, market, operational, liquidity, structural, settlement/delivery) as well as the monitoring of compliance with the regulatory requirements.

The risk reporting system is an integral part of the Group’s risk management system and is adapted to its organisational structure. The various indicators are thus calculated at the level of the relevant legal entities and Business Units and serve as the basis for the various reportings. Departments established within the Risk, Finance and Compliance sectors are responsible for measuring, analysing and communicating these elements.

Since 2015, the Group has defined architecture principles common to the Finance and Risk functions, the TOM-FIR principles (Target Operating Model for Finance & Risk), in order to guarantee the consistency of the data and indicators used for internal management and regulatory production. The principles revolve around:

Risk and Finance uses, whether at the local level and at the various levels of consolidation subject to an organised system of “golden sources”, with a collection cycle adapted to the uses;

common management rules and language to ensure interoperability;

consistency of Finance and Risk usage data, via strict alignment between accounting data and management data.

The Group produces, via all of its internal reports for internal monitoring purposes by the Business Units and Service Units, a large number of risk metrics constituting a measure of the risks monitored. Some of these metrics are also produced as part of the transmission of regulatory reports or as part of the publication of information to the market.

The Group selects from these metrics a set of major metrics, able to provide a summary of the Group’s risk profile and its evolution at regular intervals. These metrics concern both the Group’s financial rating, its solvency, its profitability and the main risks (credit, market, operational, liquidity and financing, structural, model) and are included in the reports intended for internal management bodies.

They are also subject to a framework defined and broken down in line with the Group’s risk appetite, giving rise to a procedure for reporting information in the event of breaches.

Thus, the risk reports intended for the management bodies are guided in particular by the following principles:

coverage of all significant risks;

combination of a global and holistic view of risks and a more in-depth analysis of the different types of risk;

overview supplemented by focus on certain specific scopes, forward-looking elements (based in particular on the presentation of elements on the evolution of the macro-economic context) and elements on emerging risks;

balance between quantitative data and qualitative comments.

The main Risk reports for management bodies are:

monthly reporting to the Risk Committee of the Board of Directors aims to provide an overview of changes in the risk profile.

This reporting is complemented by dashboard for monitoring the Group’s Risk Appetite Statement indicators is also sent quarterly to the Board of Directors. These indicators are framed and presented using a “traffic light” approach (with distinction between thresholds and limits) in order to visually present monitoring of compliance with risk appetite. In addition, a compliance dashboard and a reputation dashboard are sent to the Risk Committee of the Board of Directors and provide an overview of each non-compliance risk;

monthly reporting to the Group Risk Committee (CORISQ), for the general management, aims to regularly provide this Committee with a risk analysis under its supervision, with a greater level of detail than reporting to the Risk Committee of the Board of Directors. In particular, a summary of the main credit files over the period covered by the reporting is presented;

reporting to the Finance Committee (COFI) for General Management gives rise in particular to the following two reports: a “Scarce resources trajectory” report allowing budget execution to be monitored and a “Structural risk monitoring (ALM)” report making it possible to monitor compliance with the thresholds and limits relating to liquidity risks and structural interest and exchange rate risks;

the quarterly reporting of the Group Compliance Committee (COMCO) to General Management: the COMCO provides via dedicated reporting an overview of the main non-compliance risks, raises points of attention on compliance topics Group, decides on the main orientations and defines the Group principles in terms of compliance;

the quarterly reporting of the Provisions Committee (COPRO) to General Management is intended to provide an overview of changes in the level of provisions at Group level. In particular, it presents the change in the net charge of the cost of risk by pillar, by Business Unit and by stage;

reporting by the Group Internal Control Coordination Committee (GICCC) to General Management: this Committee reviews, on the basis of a standardised dashboard for all Business Units/Service Units, the efficiency and the consistency of the permanent control system implemented within the Group, as well as, within the framework of the Risk Internal Governance Assessment (RIGA) process, the ability of the Risk function to exercise its role as the 2nd line of defence in the whole group. Finally, the Risk Department contributes, as a permanent member, to all GICCC meetings, through position papers on the subjects under review.

Although the above reports are used at Group level to monitor and review the Group’s risk profile in a global manner, other reports are transmitted to the Board of Directors or to the General Management in order to monitor and control certain types specific risks.

Ad hoc reports can also be produced. By way of illustration, the Group had to adapt its risk management system from the start of the Covid-19 crisis in March 2020. Dedicated reports had been set up for the General Management, the Board of Directors or the supervisor, on a regular basis and containing indicators adapted to the context.

Additional information on risk reporting and assessment systems by type of risk is also presented in the following chapters.

INTEREST RATE BENCHMARK REFORM

Presentation of the reform

The interest rate benchmark reform (IBOR: InterBank Offered Rates), initiated by the Financial Stability Board in 2014, aims at replacing these benchmark rates with alternative rates, in particular the Risk-Free Rates (RFR). This reform accelerated on 5 March 2021, when the British Financial Conduct Authority (FCA), the supervisor of LIBOR, announced the official dates for the cessation and loss of representativeness of these benchmarks:

EUR LIBOR and CHF LIBOR (all terms); GBP LIBOR and JPY LIBOR (terms: overnight, one week, two months and twelve months); USD LIBOR (terms: one week and two months): the publication of these benchmark settings has permanently ceased as of 1 January 2022;

GBP LIBOR and JPY LIBOR (terms: one, three and six months): these settings have not been contributed by banks since 1 January 2022 and have been published in a synthetic form; their use is thus restricted to the run-off management of legacy positions. Nonetheless, the FCA has announced the cessation of these synthetic benchmarks as follows:

-

JPY LIBOR (terms: one, three and six months): end December 2022,

-

GBP LIBOR (terms: one and six months): end March 2023,

-

GBP LIBOR (term: three months): end March 2024;

USD LIBOR (terms: overnight, one, three, six and twelve months): the cessation of the publication of these benchmark settings contributed by a panel of banks is scheduled for end June 2023.

In parallel, other indices based on USD LIBOR will be phased out at end June 2023: USD LIBOR ICE SWAP RATE, MIFOR (India), PHIREF (Philippines), SOR (Singapore) and THBFIX (Thailand).

Furthermore, the announced cessation date for the publication of the MosPrime (Russia) is 30 June 2023.

Regarding the major interest rate benchmark indices of the euro area:

EURIBOR: EMMI (European Money Markets Institute), the administrator of the index, does not plan to cease its publication. The EURIBOR will thus be maintained in the coming years;

EONIA: its publication definitively ceased on 3 January 2022. The successor benchmark rate recommended by the European Central Bank working group on the euro area interest rates is the €STR on which the EONIA had been based since end 2019.

Impact of the reform for the Societe Generale Group

The Societe Generale Group supports these reforms and takes an active part in the working groups set up by the central banks of the currencies concerned. The Group is actively preparing for these changes, through a specific transition program set up in the Summer of 2018 and supervised by the Finance Division.

For this purpose, the Group has undertaken active awareness and communication campaigns for its customers, supplemented by a monthly newsletter and a Frequently Asked Questions (FAQ) page on the IBOR transition publicly available on the Societe Generale website. To prepare for the announced cessation dates of LIBOR and other transitioning benchmarks, the public authorities and the working groups set up by the central banks issued recommendations to the banking industry. These recommendations aim at stopping the production of new contracts referencing these indices as well as at migrating the existing contracts referencing said indices to alternative benchmark rates.

To ensure a consistent approach throughout the Societe Generale Group, an internal Committee has been formed. Its role is to issue periodical orientations reflecting the market developments and the recommendations from regulators and their working groups. Several internal guidelines have been issued covering four main themes:

strengthening of the new contracts through the inclusion of fallback clauses and risk warnings;

cessation of the production of new transactions referencing ceasing benchmarks (with some exceptions provided for by regulators) and use of alternative solutions;

fair and homogenous treatment of customers through the involvement of the compliance teams in the renegotiations of contracts;

reporting obligation, and restrictions related to the use of certain interest rates as alternatives to LIBOR.

At this stage, all directives are being applied and widely circulated among the Group’s staff.

In order to build the capacity to deal on products referencing RFRs or some term RFRs and thus ensure the continuity of its business after the phasing out of IBOR, the Societe Generale Group updated its tools and processes in line with the major calculation methods recommended by the relevant working groups or professional associations. Nevertheless, the Group continues monitoring developments in the use of RFRs and other alternative rates in order to implement any new convention and meet its customers’ needs.

GBP LIBOR, CHF LIBOR, EUR LIBOR, JPY LIBOR and EONIA migration

Until the end of 2021, the Group primarily centred its work on renegotiating transactions with its clients and transitioning all the contracts indexed on the benchmarks terminated or not representative anymore at the end of 2021.

Since Q2 2022, the Societe Generale Group has finalised the transition of all the contracts indexed on the above-mentioned benchmarks.

USD LIBOR and USD LIBOR ICE SWAP RATE migration

The Societe Generale Group has initiated the migration of its stock of operations indexed on USD LIBOR and USD LIBOR ICE SWAP RATE aiming to finalise it by June 2023.

To do this, the Group employs interactions with its customers to offer a proactive transition to alternative solutions.

The Group’s customers most concerned by the transition of their contracts are, primarily, customers of the investment banking and Financing and Advisory activities and, to a lesser extent, some of the customers of the Group’s French and International retail networks.

The identification of the contracts concerned and the strategy for transitioning the transactions indexed on USD LIBOR have been finalised for all products:

loans and credit lines are migrated mostly through a bilateral negotiation, and so are the related hedging instruments, in order to maintain their effectiveness;

the migration of interest rate derivatives is scheduled to be implemented in large part in the first half of 2023, in line with the key milestones set by the clearing houses or by the activation of fallback clauses (ISDA Protocol to which Societe Generale has been adhering since 2020, in particular for USD LIBOR). However, some derivatives contracts are renegotiated bilaterally; lastly

current accounts and other similar cash products are migrated through an update of their general conditions.

The operational migration of the contracts referencing the USD LIBOR makes use of the processes and tools already developed for the migration of the contracts referencing IBOR interest rates ending at end 2021, as well as of the experience gained. The clearing houses’ transition plan is known in advance and based on the experience gained from previous migrations.

Other benchmark rates migration (MIFOR, PHIREF, SOR, THBFIX and MosPrime)

For these rates, the identification of the customers and transactions has been completed. The impact is much smaller than for USD LIBOR. At the level of the Societe Generale Group, these benchmark transitions impact only investment banking products.

The migration strategies are nevertheless similar to those applicable to the USD LIBOR as described above.

The Societe Generale Group keeps monitoring the announcements from regulators and administrators in other jurisdictions in order to react proactively and adapt its migration strategy accordingly.

The table below presents an estimate of the exposures, as at 31 December 2022, related to the contracts impacted by the benchmark reform and whose term is scheduled beyond the official cessation dates.

This table has been produced based on the project monitoring data and on the legal status of the contracts migration.

(In EURbn)

 

 

2022

Current interest rate benchmarks(5)

New risk-free rates liable to replace

the current interest rate benchmarks

Cotation

end date

Outstanding principal

Notional(1)

Financial

assets(2)

(excl.

derivatives)

impacted

by the

reform

Financial

liabilities(3)

(excl.

derivatives)

impacted

by the

reform

Derivatives(4)

impacted

by the

reform

EONIA – Euro OverNight Index Average

Euro Short-Term Rate (€STR)

31.12.2021

 

 

 

LIBOR – London Interbank Offered Rate – GBP

Reformed Sterling Overnight Index Average (SONIA)

31.12.2021

 

 

 

LIBOR – London Interbank Offered Rate – CHF

Swiss Average Rate Overnight (SARON)

31.12.2021

 

 

 

LIBOR – London Interbank Offered Rate – JPY

Tokyo OverNight Average (TONA)

31.12.2021

 

 

 

LIBOR – London Interbank Offered Rate – EUR

Euro Short-Term Rate (€STR)

31.12.2021

 

 

 

LIBOR – London Interbank Offered Rate – USD

Secured Overnight Financing Rate (SOFR)

30.06.2023

27

1

1,899

USD LIBOR Ice Swap rate (CMS)

USD SOFR Ice Swap rate (CMS)

30.06.2023

 

12

228

SOR – Singapore Dollar Swap Offer Rate

Singapore Overnight Rate Average (SORA)

30.06.2023

 

 

3

MIFOR (INR)

Modified MIFOR

30.06.2023

 

 

3

PHIREF (PHP)

No alternative rate defined
by regulators

30.06.2023

 

 

 

THBFIX (THB)

THOR

30.06.2023

 

 

 

MOSPRIME (RUB)

RUONIA

30.06.2023

 

 

6

(1)

Notional used in combination with an interest rate benchmark in order to calculate derivative cash flows.

(2)

Including accounts receivable, loans, securities received under repurchase agreements, debt securities bearing interest at variable rates.

(3)

Including deposits, borrowings, transactions on securities delivered under repurchase agreements, debt issued in the form of securities bearing interest at variable rates.

(4)

Including firm instruments (swaps and futures) and conditional instruments.

(5)

Only the major interest rate benchmarks impacted by the IBOR reform are presented in this table.

RISKS ASSOCIATED WITH RATE REFORM

The risks related to the IBOR reform are now mainly limited to USD LIBOR for the period running until June 2023. They are managed and monitored within the governance framework dedicated to the IBOR transition. They have been identified as follows:

program governance and execution risk, liable to cause delays and loss of opportunities, is monitored as part of the work of regular Committees and arbitration bodies;

legal documentation risk, liable to lead to post-transition litigations, is managed through fallback clauses inserted in the contracts depending on the availability of market standards;

market risk, with the creation of a basis risk between the rate curves associated with the different indexes, is closely monitored and supervised;

operational risks in the execution of the migration of transactions depend in particular on the willingness and preparedness of our counterparties, the volume of transactions to be migrated and their spread over time;

regulatory risk is managed according to the Group guidelines in line with the recommendations of the regulators and working groups on the LIBOR transition;

conduct risk, related to the end of LIBOR, is notably managed through:

-

specific guidelines on the appropriate conduct detailed by business line,

-

training of the teams,

-

communications to customers (conferences, events, bilateral discussions in particular with the less informed customers) are organised on the transition-related risks, the alternative solutions that may be implemented, and on how they might be affected.

 

4 INTERNAL CONTROL FRAMEWORK

 

IN BRIEF

This section describes the framework and application of internal control at Societe Generale.

4.1 INTERNAL CONTROL

Internal control is part of a strict regulatory framework applicable to all banking institutions.

In France, the conditions for conducting internal controls in banking institutions are defined in the Order of 3 November 2014 modified by the Order of 25 February 2021. This Order, which applies to all credit institutions and investment companies, defines the concept of internal control, together with a number of specific requirements relating to the assessment and management of the various risks inherent in the activities of the companies in question, and the procedures under which the supervisory body must assess and evaluate how the internal control is carried out.

The Basel Committee has defined four principles – independence, universality, impartiality, and sufficient resources – which underpin the internal control carried out by credit institutions.

The Board of Directors ensures that Societe Generale has a solid governance system and a clear organisation ensuring:

a well-defined, transparent and coherent sharing of responsibilities;

effective procedures for the detection, management, monitoring and reporting of risks to which the Company could be exposed.

The Board tasks the Group’s General Management with rolling out the Group’s strategic guidelines to implement this set-up.

The Audit and Internal Control Committee is a Board of Directors’ Committee that is specifically responsible for preparing the decisions of the Board in respect of internal control supervision.

As such, General Management submits reports to the Audit and Internal Control Committee on the internal control of the Group. The Committee monitors the implementation of remediation plans when it considers the risk level to be justified.

Internal control is based on a body of standards and procedures.

All Societe Generale Group activities are governed by rules and procedures contained in a set of documents referred to collectively as the “Standard Guidelines”, compiled in the Societe Generale Code, which:

set out the rules for action and behavior applicable to Group staff;

define the structures of the businesses and the sharing of roles and responsibilities;

describe the management rules and internal procedures specific to each business and activity.

The Societe Generale Code groups together the standard guidelines which, in particular:

define the governance of the Societe Generale Group, the structures and duties of its Business Units and Services Units, as well as the operating principles of the cross-business systems and processes (Codes of Conduct, charters, etc.);

set out the operating framework of an activity and the management principles and rules applicable to products and services rendered, and also define internal procedures.

The Societe Generale Code has force of law within the Group and falls under the responsibility of the Group Corporate Secretary.

In addition to the Societe Generale Code, operating procedures specific to each Group activity are applied. The rules and procedures in force are designed to follow basic rules of internal control, such as:

segregation of functions;

immediate, irrevocable recording of all transactions;

reconciliation of information from various sources.

Multiple and evolving by nature, risks are present in all business processes. Risk management and control systems are therefore key to the Bank’s ability to meet its targets.

The internal control system is represented by all methods which ensure that the operations carried out and the organisation and procedures implemented comply with:

legal and regulatory provisions;

professional and ethical practices;

the internal rules and guidelines defined by the Company’s management body of the undertaking in its executive function.

Internal control in particular aims to:

prevent malfunctions;

assess the risks involved, and exercise sufficient control to ensure they are managed;

ensure the adequacy and effectiveness of internal processes, particularly those which help safeguard assets;

detect irregularities;

guarantee the reliability, integrity and availability of financial and management information;

check the quality of information and communication systems.

The internal control system is based on five basic principles:

the comprehensive scope of the controls, which cover all risk types and apply to all the Group’s entities;

the individual responsibility of each employee and each manager in managing the risks they take or supervise, and in overseeing the operations they handle or for which they are responsible;

the responsibility of functions, in line with their expertise and independence, in defining normative controls and, for three of them, exercising second-level permanent control;

the proportionality of the controls to the materiality of the risks involved;

the independence of internal auditing.

The internal control framework is based on the “three lines of defence” model, in accordance with the Basel Committee and European Banking Authority guidelines:

the first line of defence comprises all Group employees and operational management, both within the Business Units and the Services Units in respect of their own operations.

Operational management is responsible for risks, their prevention and their management (by putting in place first-level permanent control measures, amongst other things) and for implementing corrective or remedial actions in response to any deficiencies identified by controls and/or process steering;

the second line of defence is provided by the risk and compliance functions.

Within the internal control framework, operational management is responsible for verifying the proper and continuous running of the risk security and management operation functions through the effective application of established standards, defined procedures, methods and requested controls.

Accordingly, these functions must provide the necessary expertise to define in their respective fields the controls and other means of risk management to be implemented by the first line of defence, and to ensure that they are effectively implemented; they conduct second-level permanent control over all of the Group’s risks, based in particular on the controls they have defined, as well as those defined, if necessary, by other expert functions (e.g. sourcing, legal, tax, human resources, information system security, etc.) and by the businesses;

the third line of defence is provided by the Internal Audit Department, which encompasses the General Inspection and Internal Audit functions. This department performs periodic internal audits that are strictly independent of the business lines and the permanent control function;

internal control coordination, which falls under the responsibility of the Chief Executive Officer, is also provided at Group level and is rolled out in each of the departments and core businesses.

The Chief Executive Officer is responsible for ensuring the overall consistency and effectiveness of the internal control system.

The purpose of the Group Internal Control Coordination Committee (GICCC) is to ensure the consistency and effectiveness of the Group’s internal control, in response in particular to the obligation laid down in Art. 16 of the modified French Order of 3 November 2014.

The Committee is chaired by the Chief Executive Officer, or in his absence, by a Deputy General Manager or by the Deputy Chief Executive Officer tasked with supervising the area under review. When it meets, the CCCIG convenes the Manager responsible for Coordinating the Internal Control function, the Permanent Control function, the Managers of the second line of defence (CPLE and RISQ), the Representatives appointed by the Heads of DFIN and RESG (including the Global CISO), the Manager of the third line of defence (IGAD) and as observers, the Head of Operational Risks, as well as the Heads of the level 2 permanent control central teams (RISQ/CTL, CPLE/CTL, DFIN/CTL).

The Committee meets approximately 20 times a year to deal with cross-cutting topics as well as the annual review of each BU/SU.

Its objectives are:

to give a consolidated view of the Group’s internal control to the General Management;

to evaluate the Group’s permanent control system in terms of effectiveness, consistency and completeness;

to evaluate the functioning of the Group’s permanent control framework based on the review of the Group’s quarterly dashboard of permanent controls, supplemented by cross-cutting thematic reviews and by the independent review of RISQ and CPLE in the exercise of their role as the second line of defence for the Group;

to examine and validate the Group’s annual internal control report (ICR);

to define the roles and responsibilities of the stakeholders of the permanent control and of the GICCC and CCCI and to validate the operational principles of permanent control and governance;

to validate the sections dealing with internal control in the SG Code (in particular, Title IV of Book A);

to validate the decisions of the Committee in terms of permanent control framework;

to review and challenge the permanent control framework of BU/SU;

to review other cross-cutting topics related to the permanent control of the Group.

It is chaired by the Chief Executive Officer, or, in his absence, by a Deputy Chief Executive Officer or by the Deputy General Manager in charge of supervising the area under review, the Group Internal Control Coordination Committee brings together the Head of the Coordination of Internal Control and the Permanent Control Framework, the Heads of the second line of defence (see A.305, CPLE, RISQ), the Representatives designated by the Head of DFIN and RESG (including the Global CISO), the Head of the third line of Defence (IGAD) and, as observers, the Head of Operational Risks, as well as the Heads of the level 2 permanent control central teams (RISQ/CTL, CPLE/CTL, DFIN/CTL).

The Group’s permanent control system comprises:

the first-level permanent control, which is the basis of the Group’s permanent control, is performed by the businesses. Its purpose is to ensure the security, quality, regularity and validity of transactions completed at operational level;

the second-level permanent control, which is independent of the businesses and concerns three departments, i.e. the Compliance, Risk and Finance Departments.

In 2018, General Management initiated a transformation programme of the Group’s permanent control system, which is under its direct supervision. Through a set of actions focusing on areas such as standards, methods, tools, procedures and training, the programme served to consolidate the control culture and optimise risk control, and thus helps to improve the quality and the reliability of services provided to our customers and partners. In 2021, this programme has been finalised and closed, and the transfer of the long-term activities to operating teams has been completed.

Permanent Level 1 controls, carried out on operations performed by BUs and the SUs, ensure the security and quality of transactions and the operations. These controls are defined as a set of provisions constantly implemented to ensure the regularity, validity, and security of the operations carried out at operational level.

The permanent Level 1 controls consist of:

any combination of actions and/or devices that may limit the likelihood of a risk occurring or reduce the consequences for the Company: these include controls carried out on a regular and permanent basis by the businesses or by automated systems during the processing of transactions, automated or non-automated security rules and controls that are part of transaction processing, or controls included in operational procedures. Also falling into this category are the organisational arrangements (e.g., segregation of duties) or governance, training actions, when they directly contribute to controlling certain risks;

controls performed by managers: line managers control the correct functioning of the devices for which they are responsible. As such, they must apply formal procedures on a regular basis to ensure that employees comply with rules and procedures, and that Level 1 controls are carried out effectively.

Defined by a Group entity within its scope, Level 1 controls include controls (automated or manual) that are integrated into the processing of operations, proximity controls included in operating procedures, safety rules, etc. They are carried out in the course of their daily activities by agents directly in charge of an activity or by their managers. These controls aim to:

ensure the proper enforcement of existing procedures and control of all risks related to processes, transactions and/or accounts;

alert management in the event of identified anomalies or malfunctions.

Permanent Level 1 controls are set by management and avoid, as far as possible, situations of self-assessment. They are defined in the procedures and must be traced without necessarily being formalised, e.g. preventive automated controls that reject transactions that do not comply with system-programmed rules.

In order to coordinate the operational risk management system and the permanent Level 1 control system, the BUs/SUs deploy a specific department called CORO (Controls & Operational Risks Office Department).

The permanent Level 2 control ensures that the Level 1 control works properly:

the scope includes all permanent Level 1 checks, including managerial supervision checks and checks carried out by dedicated teams;

this review and these audits aim to give an opinion on (i) the effectiveness of Level 1 controls, (ii) the quality of their implementation, (iii) their relevance (including, in terms of risk prevention), (iv) the definition of their modus operandi, (v) the relevance of remediation plans implemented following the detection of anomalies, and the quality of their follow-up, and thus contribute to the evaluation of the effectiveness of Level 1 controls.

The permanent level 2 control, control of the controls, is carried out by teams independent of the operational.

These controls are performed centrally by dedicated teams within Risk Service Unit (RISQ/CTL), Compliance Service Unit (CPLE/CTL) and Finance Service Unit (DFIN/CTL) and locally by the second-level control teams within the BU/SUs or entities.

The Group’s Internal Audit function is delivered by the Service Unit Inspection and Internal Audit (“IGAD”), which brings together the Group’s Inspection and Internal Audit Departments. The Group’s Head of Inspection and Audit has a Group-wide responsibility for the internal audit function.

The Internal Audit function is part of the Group’s internal control set-up. It provides the third and last line of defense and performs periodical controls. The third line of defense is strictly independent from the businesses and other lines of control.

The internal audit mandate delivered by IGAD, defined in line with the IIA Standards (Institute of Internal Auditors), is an independent and objective activity that provides the Group with an assurance as to how effectively it is controlling its risks and operations, advises on improvements and contributes to the creation of added value. By carrying out this mandate, Inspection and Internal Audit help the Group to achieve its targets by evaluating systematically and methodically its processes for risk management, control and corporate governance and making recommendations to increase their efficiency.

IGAD’s internal audit mandate covers Societe Generale SA and all of the Group’s entities and business activities. All businesses, operations and processes without exceptions can be subject to an audit carried out by either Inspection or Internal Audit. This being said, entities within which the Group holds a minority stake are excluded, even if the Group has a significant influence, except in cases where such situation is likely to have a significant impact for the Group on its risk management.

Outsourced activities are also included in the scope of the mandate of IGAD as the Group’s internal audit function.

The Group Head of Inspection and Audit reports directly to the Group Chief Executive Officer.

He meets on a regular basis with the Chair of the Board of Directors. As mentioned in the Internal Rules of the Board, updated in August 2022, the Group Head of Inspection and Audit reports on the execution of the internal audit mandate to the Board of Directors on the basis of presentations made to the Group’s Audit and Internal Control Committee. He presents the Group’s audit and inspection plan, approved by the Chief Executive Officer, to the Board of Directors following its examination by the Group’s Audit and Internal Control Committee.

The Group Head of Inspection and Audit attends all meetings of the Board’s Audit and Internal Control Committee and provides the Committee on regular basis with a presentation of the activity of Internal Audit and General Inspection as well as on the status of implementation of recommendations issued both by IGAD and by supervisors (ECB and ACPR). He also attends all meetings of the Board’s Risk Committee. Both the Audit and Internal Control Committee and the Risk Committee hear the Group Head of Inspection and Audit, possibly at his request.

As foreseen in the Internal Rules of the Board, if necessary, in the event of changes in the risks affecting or likely to affect the Company, the Group Head of Inspection and Audit may report to the Board of Directors, directly or through the Audit and Internal Committee, without referring to the Effective Senior Managers.

To fulfill its mandate, the Group’s IGAD Service Unit has adequate resources from a qualitative and quantitative point of view. The Group’s Inspection and Audit Service Unit has about 1,000 employees located at Head Office and within affiliates and branches (France and overseas).

The Service Unit IGAD operates as a hierarchically integrated division. General Inspection, based at Head Office, has a Group-wide mandate. The various Audit Departments are each in charge of a defined scope of businesses or risks. Whether they are based at Head Office or within entities (affiliates or branches), Audit Departments are all reporting to the IGAD Service Unit. A matrix organisation allows to cover important transversal topics at Group level. Depending on resources and skills required, an audit mission can bring together auditors from different departments. IGAD may decide to send any audit team to carry out a mission within the Group.

General Inspection and Audit carry out their mandate on the basis of missions. Beyond audit missions defined in the yearly plan, General Inspection can be called to perform analysis and study missions or contribute to due diligence work in cases of acquisitions or divestments of Group entities or activities. A specific framework is in place to monitor such work and ensure there are no conflict of interest.

General Inspection and Audit define their respective workplans on a risk-based approach. Internal Audit combines this approach with the requirement to comply with a five-year audit cycle and determines the frequency of review based on the risk level of the audited entities.

In 2022 General Inspection and Internal Audit continued to perform an independent follow-up on recommendations issued by supervisors (ECB, ACPR) with regular status updates presented - in coordination with the Group’s General Secretariat - to General management and the Board’s Audit and Internal Control Committee.

As required by international auditing standards, IGAD is subject to an external quality assessment. IGAD’s certification was maintained following a second certification by the certification institute of the IFACI (Institut Français de l’Audit et du Contrôle Interne – French branch of the IIA) completed in 2022.

The context in 2022 allowed IGAD to resume business travel and on-site missions to a larger extent whilst maintaining remote auditing methods developed during the sanitary crisis. Audit missions carried out in 2022 were split on all categories of risks. Changes made to the audit plan during the year remained limited (reduction of 8% of man-days on audit missions with a total of 586 audit missions carried out this year), reflecting mainly the impact of a higher level of turnover in certain geographies and a shift in a number of projects initially planned to be subject to an audit. Such tensions also led to reschedule a few Inspection missions this year.

In 2022 IGAD initiated works required in response to recommendations issued by the European Central bank and IFACI on the internal audit function. Such work pertained mainly to (i) governance, being IGAD’s internal governance, the set-up with regards to the interactions between the internal Audit function and the Group’s governance at General management and Board level and the governance for the audit function at local level; (ii) the redesign, to be completed by end of 2024, of its independent risk assessment exercise and (iii) the establishment of a multi-year audit plan. The implementation of these action plans will remain a priority over 2023 and 2024 for the internal audit function. In addition, the restructuring of the audit recommendations issuance and monitoring process was initiated: all Business Units and Service Units will be engaged in the process, which will enable IGAD to focus its work on the most important risks in line with a strategic goal to optimize the layering of controls within the Group’s internal control framework.

On the operational side, internal audit departments (i) further developed their ability to provide independent assurance on the performance of permanent control departments; (ii) reinforced their auditing methods on topics such as “conduct” or “ESG” and (iii) increased the use of data analytics in the audit missions.

4.2 CONTROL OF THE PRODUCTION AND PUBLICATION OF FINANCIAL MANAGEMENT INFORMATION

There are many participants in the production of financial data:

the Board of Directors, and more specifically its Audit and Internal Control Committee, has the task of examining the draft financial statements which are to be submitted to the Board, as well as verifying the conditions under which they were prepared and ensuring not only the relevance but also the consistency of the accounting principles and methods applied. The Audit and Internal Control Committee’s remit also is to monitor the independence of the Statutory Auditors, and the effectiveness of the internal control, measurement, supervision and control systems for risk related to the accounting and financial processes. The Statutory Auditors meet with the Audit and Internal Control Committee during the course of their assignment;

the Group Finance Department gathers the accounting and management data compiled by the subsidiaries and the Business Units/Services Units in a set of standardised reports. It consolidates and verifies this information so that it can be used in the overall management of the Group and disclosed to third parties (supervisory bodies, investors, etc.). It also has a team in charge of the preparation of the Group regulatory reports.

In the framework of these missions, it is in charge of:

-

monitoring the financial aspects of the Group’s capital transactions and its financial structure,

-

managing its assets and liabilities, and consequently defining, managing and controlling the Group’s financial position and structural risks,

-

ensuring that the regulatory financial ratios are respected,

-

defining accounting and regulatory standards, frameworks, principles and procedures for the Group, and ensuring that they are observed,

-

verifying the accuracy of all financial and accounting data published by the Group;

the Finance Departments of subsidiaries and Business Units/Services Units carry out certification of the accounting data and entries booked by the back offices and of the management data submitted by the front offices. They are accountable for the financial statements and regulatory information required at the local level and submit reports (accounting data, finance control, regulatory reports, etc.) to the Group Finance Department. They can perform these activities on their own or else delegate their tasks to Shared Service Centers operating in finance and placed under Group Finance Department governance;

the Risk Department consolidates the risk monitoring data from the Group’s Business Units/Services Units and subsidiaries in order to control credit, market and operational risks. This information is used in Group communications to the Group’s governing bodies and to third parties. Furthermore, it ensures in collaboration with the Group Finance Department, its expert role on the dimensions of credit risk, structural liquidity risks, rates, exchange rates, on the issues of recovery and resolution and the responsibility of certain closing processes, notably the production of solvency ratios;

the Back offices are responsible for all support functions to front offices and ensure contractual settlements and deliveries. Among other responsibilities, they check that financial transactions are economically justified, book transactions and manage means of payment.

Local financial statements are drawn up in accordance with local accounting standards, and the consolidated Group financial statements are prepared in accordance with the standards defined by the Group Finance Department, which are based on IFRS as adopted by the European Union.

The applicable standards on solvency and liquidity, promulgated by the Basel Committee, were translated into European law by a directive (CRD4) and a regulation (CRR). They were rounded out by the Regulation CRR2 and the Directive CRD5 which entered into force on 28 June 2019. These texts are supplemented by several delegated acts and implementation technical standards. As the Societe Generale Group is identified as a “financial conglomerate”, it is subjected to additional supervision.

The Group Finance Department has dedicated teams that monitor the applicable standards and draft new internal standards to comply with any changes in the accounting and regulatory framework.

Each entity in the consolidation scope of the Group prepares its own accounting and management statements on a monthly basis. This information is then consolidated each month at Group level and published for the markets on a quarterly basis. Data reported are subject to analytical reviews and consistency checks performed by Finance Department or delegated to financial shared service centers acting under their responsibility and sent to the Group Finance Department. The Group Finance Department forwards the consolidated financial statements, Management Reports and regulatory statements to General Management and any interested third parties.

Accounting data are compiled independently of the front offices and the sales teams.

The quality and objectivity of the accounting and management data are ensured by the separation of sales functions and all the functions of operational processing and follow-up of the operations: back offices and middle offices integrated into Resources Department and teams in charge of result production integrated into Finance Department. These teams carry out a series of controls defined by Group procedures on financial and accounting data, in particular:

verification of the economic justification of all information reported;

reconciliation of accounting and management data, using specific procedures, respecting the specified deadlines;

for market activities, reconciliation between the accounting result, produced by the Finance Department and the economic result, produced by a dedicated expert department in the Risk Department.

Given the increasing complexity of the Group’s financial activities and organisation, staff training and IT tools are regularly upgraded to ensure that the production and verification of accounting and management data are effective and reliable.

In practice, the internal control procedures implemented in the Group’s businesses are designed to guarantee the quality of financial and accounting information, and notably to:

ensure that the transactions entered in the Group’s accounts are exhaustive and accurate;

validate the valuation methods used for certain transactions;

ensure that transactions are correctly assigned to the corresponding fiscal period and recorded in the accounts in accordance with the applicable accounting regulations, and that the accounting aggregates used to prepare the Group financial statements are compliant with the regulations in force;

ensure the inclusion of all entities that must be consolidated in accordance with Group regulations;

check that the operational risks associated with the production and transmission of accounting data through the IT system are correctly controlled, that the necessary adjustments are accurately performed, that the reconciliation of accounting and management data is satisfactory, and that the flows of cash payments and other items generated by transactions are exhaustive and adequate.

The Finance Department of each subsidiary checks the accuracy and consistency of the financial statements with respect to the relevant accounting frameworks (local standards and IFRS for subsidiaries, as well as French standards for branches). It performs checks to guarantee the accuracy of the information disclosed.

The data received for consolidation from each subsidiary are drawn from corporate accounting data by the subsidiaries after they have been locally brought into compliance with Group accounting principles.

Each subsidiary must be able to explain the transition from the Company financial statements to the financial statements reported through the consolidation tool.

The Finance Departments of the Business Units/Services Units have a dedicated department for financial management and control.

The Finance Departments also rely on shared service centers that perform level 1 controls necessary to ensure the reliability of accounting, tax and regulatory information on the financial statements they produce in accordance with local and IFRS standards and notably data quality and consistency checks (equity, securities, foreign exchange, financial aggregates from the balance sheet and income statement, deviations from standards), justification and certification of the financial statements under their responsibility, intercompany reconciliation of the financial statements, regulatory statement checks and verification of evidence of tax charges and balances (current, deferred and duties).

These controls are declared as part of the managerial supervision and Group accounting certification processes.

These controls allow the Shared Services Centers to provide all necessary information to the Finance Departments of Business Units/Services Units and the Group Finance and Accounting Department to ensure the reliability and consistency of the accounts prepared.

These shared service centers are located in Paris, Bangalore and Bucharest.

The operational staff monitor their activity via a permanent supervision process under the direct responsibility of their management teams, repeatedly verifying the quality of the controls carried out on completeness of accounting data and the associated accounting treatment.

Once the financial statements prepared by the entities have been restated according to Group standards, they are entered into a central database and processed to produce the consolidated statements.

The service in charge of consolidation in the Group Accounting Officer Department checks that the consolidation scope complies with the applicable accounting standards and performs multiple checks on data received for consolidation purposes. These checks include:

confirmation that the data collected are properly aggregated;

verification of recurring and non-recurring consolidation entries;

exhaustive treatment of critical points in the consolidation process;

treatment of any residual differences in reciprocal or intercompany statements.

Last, this service ensures that the overall consolidation process has been conducted properly by performing analytical reviews of the summary data and verifying the consistency of the main aggregates of the financial statements. These verifications are complemented by transversals analysis such as analysis of changes in shareholders’ equity, goodwill, provisions and consolidated deferred taxes.

A team in this department is in charge of managing and coordinating the Group accounting certification framework to certify first-level controls on a quarterly basis (internal control certification).

The Group Finance Department has also a dedicated team, it which is responsible for ensuring second-level permanent controls on all Finance processes and for implementing the framework within the Group. Its mission is to ensure the effectiveness, quality and relevance of the Level 1 control framework by assessing it through process or activity reviews, testing controls and quarterly certifications. The team, reporting directly to the Group Finance Department, also reports to the Head of Permanent & Internal Control Division of Societe Generale Group.

Internal Audit and the General Inspection define their audits and inspections using a risk-based approach and define an annual work program (Inspection and Audit plan schedule – plan de tournée). As part of their assignments, teams may verify the quality of the control environment contributing to the quality of the accounting and management data produced by the audited entities. They may check a certain number of accounts and assess the reconciliations between accounting and management data, as well as the quality of the permanent supervision procedures for the production and control of accounting data. They also assess the performance of IT tools and the accuracy of manual processing.

The department in charge of auditing the Group’s Central Departments is responsible for auditing the Group Finance Department. Within that department, a distinct team, placed under the responsibility of a dedicated Audit Business Correspondent monitors and animates audit work related to accounting and financial matters on a Group-wide basis. The team provides expertise in identifying the Group’s main accounting risks and develops training sessions and methodologies to help share expertise in the auditing of accounting risks.

Audit missions pertaining to accounting matters are carried out by that team, for the subjects considered as the most material for the accuracy of the Group’s accounting information, as well as by Audit Departments based in the Group’s entities.

Based on their findings, these teams issue recommendations to the parties involved in the production and control of accounting, financial and management data. Departments being assigned these recommendations are responsible for their implementation. A monitoring is performed by IGAD.

 

5 CAPITAL MANAGEMENT AND ADEQUACY

 

IN BRIEF

This section provides details on capital resources, regulatory requirements and the composition of the leverage ratio.

Evolution of CET1 capital

-€1.2bn*

(between 2021 and 2022)

Evolution of total regulatory capital

+€1.2bn*

CET1 ratio at end 2022

13.5%*

* Figures taking into account the phasing under IFRS 9 (CET1 ratio of 13.34% at end-2022 without phasing, a phasing effect of +17 bp) and the effects of the transitional Covid-19 measures taken by the ECB and ending on 31 December 2022.

5.1 REGULATORY FRAMEWORK

Since January 2014, Societe Generale has applied the Basel III regulations implemented in the European Union through a regulation and a directive (CRR and CRD4 respectively).

The general framework defined by Basel III is structured around three pillars:

Pillar 1 sets the minimum solvency, leverage and liquidity requirements and defines the rules that banks must use to measure risks and calculate the related capital requirements, according to standard or more advanced methods;

Pillar 2 concerns the discretionary supervision implemented by the competent authority, which allows them – based on a constant dialogue with supervised credit institutions – to assess the adequacy of capital requirements as calculated under Pillar 1, and to calibrate additional capital requirements taking into account all the risks to which these institutions are exposed;

Pillar 3 encourages market discipline by developing a set of qualitative or quantitative disclosure requirements which will allow market participants to better assess a given institution’s capital, risk exposure, risk assessment processes and, accordingly, capital adequacy.

Several amendments to European regulatory standards were adopted in May 2019 (CRR2/CRD5). The majority of these provisions entered into force in June 2021.

The amendments include:

NSFR: The text introduces the regulatory requirements for the NSFR ratio. A ratio of 100% is respected since June 2021;

Leverage ratio: the minimum requirement of 3% to which is added, since January 2023, 50% of the buffer required as a systemic institution;

Derivatives counterparty risk (SA-CCR): the “SA-CCR” method is the Basel method replacing the “CEM” method for determining prudential exposure to derivatives in a standard approach;

Large Risks: the main change is the calculation of the regulatory limit (25%) on Tier 1 (instead of total own funds), as well as the introduction of a specific cross-limit on systemic institutions (15%);

TLAC: The ratio requirement for G-SIBs is introduced in CRR. In accordance with the Basel text, G SIBs must respect an amount of own funds and eligible debt equal to the highest between 18%+risk-weighted buffers and 6.75% leverage since 2022.

With regard to the implementation of the market risk reform (FRTB), after the publication of the first revised standard in January 2016 and of the consultation in March 2018 on this subject, the Basel Committee published in January 2019 its final text: BCBS457. In March 2020, the Basel Committee announced a one-year delay in the implementation of FRTB (1 January 2023 instead of 1 January 2022 as originally planned in the January 2019 text).

The European FRTB calendar would be as follows:

regarding reporting requirements:

-

the Standardised Approach (SA) has been effective since Q3 2021,

-

for the Internal Model Approach (IMA), for the approved banks, reporting should start three years after the publication in the Official Journal of the European Union (OJEU) of three technical standards (RTS) of the EBA, which entered in force on the 15th of November 2022;

capital requirements for FRTB: Expected by 1 January 2025 at this stage, which would make the IMA reporting obsolete; a 2-year delay (i.e. 1 January 2027) could be applied in the event of unlevel playing field with other major jurisdictions In December 2017, the Group of Central Bank Governors and Heads of Supervision (GHOS), the Basel Committee’s oversight body, endorsed the regulatory reforms aiming to complete Basel 3.

In December 2017, the Group of Central Bank Governors and Heads of Supervision (GHOS), the Basel Committee’s oversight body, endorsed the regulatory reforms aiming to complete Basel 3.

A first version of the transposition text was published by the European Commission on 27 October 2021 (“CRR3 – CRD6”) and will serve as support for the European Trialogue where this version will be combined with the Council text published in November 2022 and the Parliament text. The trialogue is expected to be finalized in the summer of 2023. It will then have to be voted by Parliament to become applicable.

These new rules, which were to take effect from 2022, have been postponed to January 2025 with an overall output floor: the risk-weighted assets (RWA) will be floored to a percentage of the standard method (credit, market and operational). The output floor level will increase gradually, from 50% in 2025 to 72.5% in 2030.

Throughout 2022, Societe Generale complied with the minimum ratiorequirements applicable to its activities.

5.2 CAPITAL MANAGEMENT

As part of its capital management, the Group (under the managment of the Finance Department and the supervision of Risk Department) ensures that its solvency level is always compatible with the following objectives:

maintaining its financial strength and respecting the risk appetite;

preserving its financial flexibility to finance organic growth and growth through acquisitions;

allocating adequate capital to the various businesses, according to the Group’s strategic objectives;

maintaining the Group’s resilience in the event of stress scenarios;

meeting the expectations of its various stakeholders: supervisors, debt and equity investors, rating agencies, and shareholders.

The Group determines its internal solvency targets in accordance with these objectives and regulatory thresholds.

The Group has an internal process for assessing the adequacy of its capital that measures and explains the evolution of the Group’s capital ratios over time, taking into account any future regulatory constraints and changes in the scope. 

This process is based on a selection of key metrics that are relevant to the Group in terms of risk and capital measurement, such as CET1, Tier 1 and Total Capital ratios. These regulatory indicators are supplemented by an assessment of the coverage of internal capital needs by available CET1 capital and an economic perspective, thus confirming the relevance of the targets set in the risk appetite. Besides, this assessment takes into account the constraints arising from the other metrics of the risk appetite, such as rating, MREL and TLAC or leverage ratio.

All of these indicators are measured on a forward-looking basis in relation to their target on a quarterly or even monthly basis for the current year. During the preparation of the financial plan, they are also assessed on an annual basis over a minimum of three-year horizon according to at least a baseline and adverse scenarios, in order to demonstrate the resilience of the bank’s business model against adverse macroeconomic and financial uncertain environments. Capital adequacy is continuously monitored by the Executive Management and by the Board of Directors as part of the Group’s corporate governance process and is reviewed in depth during the preparation of the financial plan. It ensures that the bank always complies with its financial target and that its capital level is above the “Maximum Distributable Amount” (MDA) threshold.

Besides, the Group maintains a balanced capital allocation among its three strategic core businesses:

French Retail Banking;

International Retail Banking and Financial Services;

Global Banking and Investor Solutions.

Each of the Group’s core businesses accounts for around a third of total Risk-Weighted Assets (RWA), with a predominance of credit risk (83% of total Group RWA, including counterparty credit risk).

At 31 December 2022, Group RWA were down 1% to EUR 360 billion, compared with EUR 363 billion at end-December 2021.

The evolution of the business lines’ RWA lies at the core of the operational management of the Group’s capital trajectory based on a detailed understanding of the vectors of variations. Where appropriate, the General Management may decide, upon a proposal from the Finance Department, to implement managerial actions to increase or reduce the share of the business lines, for instance by validating the execution of synthetic securitisation or of disposals of performing or non-performing portfolios.

5.3 SCOPE OF APPLICATION – PRUDENTIAL SCOPE

The Group’s prudential reporting scope includes all fully consolidated entities, with the exception of insurance entities, which are subject to separate capital supervision.

All regulated entities of the Group comply with their prudential commitments on an individual basis.

Non-regulated entities outside of the scope of prudential consolidation are subject to periodic reviews, at least annually.

The following table provides the main differences between the accounting scope (consolidated Group) and the prudential scope (Banking Regulation requirements).

Type of entity

Accounting treatment

Prudential treatment

Entities with a finance activity

Full consolidation

Full consolidation

Entities with an Insurance activity

Full consolidation

Equity method

Holdings with a finance activity by nature

Equity method

Equity method

Joint ventures with a finance activity by nature

Equity method

Proportional consolidation

The following table provides a reconciliation between the consolidated balance sheet and the accounting balance sheet within the prudential scope.The amounts presented are accounting data, not a measure of RWA, EAD or prudential capital. Prudential filters related to entities and holdings notassociated with an insurance activity are grouped together on account of their non-material weight (< 0.1%).

ASSETS at 31.12.2022

(In EURm)

Balance sheet as

in published

financial

statements

Prudential

restatements

linked to

insurance(1)

Prudential

restatements

linked to

consolidation

methods

Balance sheet

under regulatory

scope of

consolidation

Reference to

table 14 (CC1)

Cash, due from banks

207,013

(0)

0

207,012

 

Financial assets at fair value through profit or loss

329,437

11,135

(0)

340,571

 

Hedging derivatives

32,850

10

-

32,860

 

Financial assets at fair value through other comprehensive income

37,463

(0)

-

37,463

 

Securities at amortised cost

21,430

(0)

-

21,430

 

Due from banks at amortised cost

66,903

1

51

66,955

1

o.w. subordinated loans to credit institutions

238

(0)

-

238

 

Customer loans at amortised cost

506,529

1,524

(11)

508,041

 

Revaluation differences on portfilios hedged against interest rate risk

(2,262)

-

-

(2,262)

 

Investment of insurance activities

158,415

(158,415)

-

-

 

Tax assets

4,697

(406)

0

4,292

 

o.w. deferred tax assets that rely on future profitability excluding those arising from temporary differences

1,662

-

(594)

1,069

2

o.w. deferred tax assets arising from temporary differences

2,215

-

325

2,540

 

Other assets

86,247

(4,003)

155

82,399

 

o.w. defined-benefit pension fund assets

47

-

-

47

3

Non-current assets held for sale

1,081

-

-

1,081

 

Investments accounted for using the equity method

146

3,438

(42)

3,541

 

Tangible and intangible assets

33,089

(64)

0

33,025

 

o.w. intangible assets exclusive of leasing rights

2,881

-

(41)

2,840

4

Goodwill

3,781

(325)

-

3,456

4

TOTAL ASSETS

1,486,818

(147,106)

152

1,339,864

 

(1)

Restatement of entities excluded from the prudential scope and reconsolidation of intra-group transactions relating to these entities.

LIABILITIES at 31.12.2022

(In EURm)

Balance sheet as

in published

financial

statements

Prudential

restatements

linked to

insurance(1)

Prudential

restatements

linked to

consolidation

methods

Balance sheet

under regulatory

scope of

consolidation

Reference to

table 14 (CC1)

Due to central banks

8,361

-

-

8,361

 

Financial liabilities at fair value through profit or loss

300,618

2,473

-

303,091

 

Hedging derivatives

46,164

19

-

46,183

 

Debt securities issued 

133,176

336

-

133,512

 

Due to banks

132,988

(2,187)

19

130,820

 

Customer deposits

530,764

913

(123)

531,553

 

Revaluation differences on portfolios hedged against interest rate risk

(9,659)

-

-

(9,659)

 

Tax liabilities

1,637

(168)

0

1,470

 

Other Liabilities

107,552

(5,766)

256

102,042

 

Non-current liabilities held for sale

220

-

-

220

 

Liabilities related to insurance activities contracts

141,688

(141,688)

-

-

 

Provisions

4,579

(21)

-

4,558

 

Subordinated debts

15,946

40

-

15,986

 

o.w. redeemable subordinated notes including revaluation differences on hedging items

15,521

42

-

15,563

5

TOTAL DEBTS

1,414,036

(146,049)

152

1,268,139

 

Subtotal Equity, Group share

66,451

(202)

(0)

66,249

6

Issued common stocks, equity instruments and capital reserves

30,384

1

-

30,384

 

Retained earnings

34,267

(203)

(0)

34,065

 

Net income

2,018

(0)

-

2,018

 

Unrealised or deferred capital gains and losses

(218)

0

(0)

(218)

 

Minority interests

6,331

(855)

-

5,476

7

TOTAL EQUITY

72,782

(1,057)

(0)

71,725

 

TOTAL LIABILITIES

1,486,818

(147,106)

152

1,339,864

 

(1)

Restatement of entities excluded from the prudential scope and reconsolidation of intra-group transactions relating to these entities.

ASSETS at 31.12.2021

(In EURm)

Balance sheet as

in published

financial

statements

Prudential

restatements

linked to

insurance(1)

Prudential

restatements

linked to

consolidation

methods

Balance sheet

under regulatory

scope of

consolidation

Reference to

table 14 (CC1)

Cash, due from banks

179,969

(0)

0

179,969

 

Financial assets at fair value through profit or loss

342,714

11,128

(0)

353,842

 

Hedging derivatives

13,239

30

-

13,269

 

Financial assets at fair value through other comprehensive income

43,450

(0)

-

43,450

 

Securities at amortised cost

19,371

(0)

-

19,371

 

Due from banks at amortised cost

55,972

(0)

90

56,062

1

o.w. subordinated loans to credit institutions

99

(0)

-

99

 

Customer loans at amortised cost

497,164

1,575

(6)

498,733

 

Revaluation differences on portfilios hedged against interest rate risk

131

-

-

131

 

Investment of insurance activities

178,898

(178,898)

-

-

 

Tax assets

4,812

(195)

0

4,617

 

o.w. deferred tax assets that rely on future profitability excluding those arising from temporary differences

1,719

-

(622)

1,096

2

o.w. deferred tax assets arising from temporary differences

2,111

-

378

2,489

 

Other assets

92,898

(2,654)

114

90,357

 

o.w. defined-benefit pension fund assets

85

-

-

85

3

Non-current assets held for sale

27

-

-

27

 

Investments accounted for using the equity method

95

4,629

(76)

4,649

 

Tangible and intangible assets

31,968

(163)

0

31,805

 

o.w. intangible assets exclusive of leasing rights

2,733

-

(134)

2,599

4

Goodwill

3,741

(325)

-

3,416

4

TOTAL ASSETS

1,464,449

(164,873)

121

1,299,698

 

(1)

Restatement of entities excluded from the prudential scope and reconsolidation of intra-group transactions relating to these entities.

LIABILITIES at 31.12.2021

(In EURm)

Balance sheet as

in published

financial

statements

Prudential

restatements

linked to

insurance(1)

Prudential

restatements

linked to

consolidation

methods

Balance sheet

under regulatory

scope of

consolidation

Reference to

table 14 (CC1)

Due to central banks

5,152

-

-

5,152

 

Financial liabilities at fair value through profit or loss

307,563

1,854

-

309,418

 

Hedging derivatives

10,425

4

-

10,429

 

Debt securities issued 

135,324

432

-

135,757

 

Due to banks

139,177

(2,574)

49

136,652

 

Customer deposits

509,133

1,002

(121)

510,013

 

Revaluation differences on portfolios hedged against interest rate risk

2,832

-

-

2,832

 

Tax liabilities

1,577

(299)

0

1,279

 

Other Liabilities

106,305

(8,962)

193

97,536

 

Non-current liabilities held for sale

1

-

-

1

 

Liabilities related to insurance activities contracts

155,288

(155,288)

-

-

 

Provisions

4,850

(23)

-

4,827

 

Subordinated debts

15,959

40

-

15,999

 

o.w. redeemable subordinated notes including revaluation differences on hedging items

15,519

42

-

15,561

5

TOTAL DEBTS

1,393,586

(163,813)

122

1,229,894

 

Subtotal Equity, Group share

65,067

(202)

(0)

64,865

6

Issued common stocks, equity instruments and capital reserves

29,447

1

-

29,448

 

Retained earnings

30,631

(203)

(0)

30,428

 

Net income

5,641

0

-

5,641

 

Unrealised or deferred capital gains and losses

(652)

0

(0)

(653)

 

Minority interests

5,796

(858)

-

4,939

7

TOTAL EQUITY

70,863

(1,060)

(0)

69,804

 

TOTAL LIABILITIES

1,464,449

(164,873)

121

1,299,698

 

(1)

Restatement of entities excluded from the prudential scope and reconsolidation of intra-group transactions relating to these entities.

The main Group companies outside the prudential reporting scope are as follows:

Company

Activity

Country

Antarius

Insurance

France

ALD RE Designated Activity Company

Insurance

Ireland

Catalyst RE International LTD

Insurance

Bermuda

Sogelife

Insurance

Luxembourg

Sogecap

Insurance

France

Komercni Pojstovna A.S.

Insurance

Czech Republic

La Marocaine Vie

Insurance

Morocco

Oradea Vie

Insurance

France

SGL RE

Insurance

Luxembourg

Société Générale RE SA

Insurance

Luxembourg

Sogessur

Insurance

France

Banque Pouyanne

Bank

France

Generally, all regulated Group undertakings are subject to solvency requirements set by their respective supervisory authorities. Regulated financial entities and affiliates outside of Societe Generale’s prudential consolidation scope are all in compliance with their respective solvency requirements. As a general principle, all banks should be under a double supervision, on a standalone basis and on a consolidated basis but the CRR allows, under specific conditions, waivers from the requirements on an individual basis granted by the competent authorities.

The supervisory authority accepted that some Group entities may be exempted from the application of prudential requirements on an individual basis or, where applicable, on a sub-consolidated basis. Terms and conditions of waiver of requirements granted by supervisors include a commitment to provide these subsidiaries with the Group’s support to ensure their overall solvency and liquidity, as well as a commitment to ensure that they are managed prudently according to the applicable banking regulations.

The conditions for applying waivers regarding monitoring on an individual basis for a Parent Institution, as far as solvency and large exposure ratios are concerned, are defined by the CRR, which stipulates that two conditions have to be met:

there is no significant obstacle, in law or in fact, current or anticipated, to the prompt transfer of equity capital or the rapid repayment of liabilities to the Parent Institution in a Member State;

the risk assessment, measurement and control procedures that are useful for the purposes of supervision on a consolidated basis cover the Parent Institution in a Member State.

Accordingly, for instance, Societe Generale SA is not subject to prudential requirements on an individual basis.

Any transfer of equity or repayment of liabilities between the parent company and its entities is carried out in compliance with capital and liquidity requirements that are locally applicable. The obligation to comply with such requirements may affect the capacity of subsidiaries to transfer funds to the parent company. Every year, in compliance with local capital and liquidity regulatory requirements, the Group reviews the capitalization of its subsidiaries (direct and indirect) and proposals for appropriation of their allocating their net income (payment of dividends, retained earnings, etc.). In addition, the Group studies requests from its subsidiaries relating to changes in their equity or eligible liabilities (capital increases or decrease, distributions of exceptional dividends, loan issues or repayments). These reviews and studies show that, as long as subsidiaries comply with their regulatory constraints, there is no significant obstacle to transfer funds from Societe Generale to them or vice versa.

The financing process of subsidiaries within the Group allows rapid repayments of loans between the parent company and its subsidiaries. In 2022, the embargo on Russia was a significant to the rapid repatriation of the funds generated by the sale of Rosbank, which could nevertheless be repatriated. Moreover, the war in Ukraine is disrupting remittances, but the Group is not significantly affected.

The outline of the differences in the scopes of consolidation (entity byentity) is available on the website www.societegenerale.com, section“Universal Registration Document, Pillar 3” This informationcorresponds to table LI3 of EBA instructions (EBA/ITS/2020/04).

5.4 REGULATORY CAPITAL

Reported in accordance with International Financial Reporting Standards (IFRS), Societe Generale’s regulatory capital consists of the following components.

According to the applicable regulations, Common Equity Tier 1 capital is made up primarily of the following:

ordinary shares (net of repurchased shares and treasury shares) and related share premium accounts;

retained earnings;

components of other comprehensive income;

other reserves;

minority interests limited by CRR/CRD.

Deductions from Common Equity Tier 1 capital essentially involve the following:

estimated dividend payments;

goodwill and intangible assets, net of associated deferred tax liabilities;

unrealised capital gains and losses on cash flow hedging;

income on own credit risk;

deferred tax assets on tax loss carryforwards;

deferred tax assets resulting from temporary differences beyond a threshold;

assets from defined benefit pension funds, net of deferred taxes;

any positive difference between expected losses on customer loans and receivables managed under the internal ratings-based (IRB) approach, and the sum of related value adjustments and collective impairment losses;

expected losses on equity portfolio exposures;

value adjustments resulting from the requirements of prudent valuation;

securitisation exposures weighted at 1,250%, when these positions are excluded from the calculation of RWA.

According to CRR/CRD regulations, Additional Tier 1 capital is made up of deeply subordinated notes that are issued directly by the Bank, and have the following features:

these instruments are perpetual and constitute unsecured, deeply subordinated obligations. They rank junior to all other obligations of the Bank, including undated and dated subordinated debt, and senior only to common stock shareholders;

Societe Generale may elect, on a discretionary basis, not to pay the interest and coupons linked to these instruments. This compensation is paid out of distributable items;

they include neither a step-up in compensation nor any other incentive to redeem;

they must have a loss-absorbing capacity;

they might be haircut or converted when in resolution or independently of a resolution measurement;

subject to the prior approval of the European Central Bank, Societe Generale has the option to redeem these instruments at certain dates, but no earlier than five years after their issuance date.

Deductions of Additional Tier 1 capital essentially apply to the following:

AT1 treasury shares;

holding of AT1 hybrid shares issued by financial sector entities;

minority interests beyond the minimum T1 requirement in the entities concerned.

Tier 2 capital includes:

subordinated notes;

any positive difference between the sum of value adjustments and impairment losses on customer loans and receivables exposures managed under the IRB approach and expected losses, up to 0.6% of total credit RWA under the IRB approach;

value adjustments for credit risk related to collective impairment losses on customer loans and receivables exposures managed under the standardised approach, up to 1.25% of total credit RWA.

Deductions of Tier 2 capital essentially apply to the following:

Tier 2 treasury shares;

holding of Tier 2 shares issued by financial sector entities;

minority interests beyond the minimum capital requirement in the entities concerned.

All capital instruments and their features are detailed online (www.societegenerale.com/en/measuring-our-performance/information-and-publications/registration-documents).

Issuance

Date

Currency

Issue amount

(in currency m)

First call

date

Yield before the call

date and frequency

Yield after the call date

and frequency

Book value

(EURm) at

31.12.2022

Book value

(EURm) at

31.12.2021

18.12.2013

USD

1 750 M

18.12.2023

7.875% annually

Mid Swap Rate USD
5 years +4.979%

1,641

1,545

29.09.2015

USD

1 250 M

29.09.2025

8.000% annually

Mid Swap Rate USD
5 years +5.873%

1,172

1,104

06.04.2018

USD

1250 M

06.04.2028

6.750% annually

Mid Swap Rate USD
5 years +3.929%

1,172

1,104

04.10.2018

USD

1250 M

04.10.2023

7.375% annually

Mid Swap Rate USD
5 years +4.302%

1,172

1,104

16.04.2019

SGD

750 M

16.04.2024

6.125% annually

Swap Offer Rate SGD
5 years +4.207%

524

491

12.09.2019

AUD

700 M

12.09.2024

4.875% annually

Mid Swap S/Q AUD
5 years +4.036%

446

448

18.11.2020

USD

1 500 M

18.11.2030

5.375% annually

5y U.S. Treasury Rate
+4.514%

1,406

1,324

26.05.2021

USD

1 000 M

26.05.2026

4.750% annually

5y U.S. Treasury Rate
+3.931%

938

883

15.07.2022

SGD

200 M

15/07/2027

8.25% par an

Swap Offer Rate SGD
5 ans majoré de 5.6%

140

-

22.11.2022

USD

1 500 M

22/11/2027

9.375% par an

U.S. Treasury Rate
5 ans majoré de 5.385%

1,406

-

TOTAL

 

 

 

 

 

10,017

8,003

(In EURm)

31.12.2021

Issues

Redemptions

Prudential

supervision

valuation

haircut

Others

31.12.2022

Debt instruments eligible for Tier 1 

8,003

1,546

-

-

 468

10,017

Debt instruments eligible for Tier 2 

11,820

2,450

(157)

(1,815)

 251

12,549

TOTAL ELIGIBLE DEBT INSTRUMENTS 

19,823

3,996

(157)

(1,815)

 719

22,566

The solvency ratios are set by comparing the Group’s equity (Common Equity Tier 1 (CET1), Tier 1 (T1) or Total Capital (TC)) with the sum of risk-weighted exposures for credit risk and the capital requirement multiplied by 12.5 for market and operational risks.

Each quarter, the ratios are calculated following the accounting closing and then compared to the supervisory requirements.

The Pillar 1 regulatory minimum capital requirement is set at 4.5% for CET1, 6% for T1 and 8% for TC. This minimum remains stable over time.

The minimum Pillar 2 requirement (P2R) is set by the supervisor following the Supervisory Review and Evaluation Process (SREP). It has been standing at 2.12% until 31 December 2022, this level will stand at 2.14% including the additional requirement regarding Pillar 2 prudential expectations on the provisioning of non-performing loans granted before 26 April 2019.

In addition to these requirements comes the overall buffer requirement which is the sum of:

the mean of the countercyclical buffer rates of each country, weighted by the relevant credit risk exposures in these countries. As of 1 January 2023, Societe Generale’s countercyclical buffer is equal to 0.19%;

the conservation buffer in force since 1 January 2016 with a maximum level standing at 2.50% since 1 January 2019;

the Group’s G-SIB buffer imposed by the Financial Stability Board (FSB), which is equal to 1%.

As at 31 December 2022, taking into account the combined regulatory buffers, the phased-in CET1 ratio level that would trigger the Maximum Distributable Amount (MDA) mechanism stands at 9.35%. It will stand at 9.39% from 1 January 2023.

 

31.12.2022

01.03.2022

01.01.2022

Minimum requirement for Pillar 1

4.50%

4.50%

4.50%

Minimum requirement for Pillar 2 (P2R)(1)

1.19%

1.19%

0.98%

Minimum requirement for countercyclical buffer

0.16%

0.04%

0.04%

Minimum requirement for conservation buffer

2.50%

2.50%

2.50%

Minimum requirement for systemic buffer

1.00%

1.00%

1.00%

Minimum requirement for CET1 ratio

9.35%

9.23%

9.02%

(1)

According to Article 104 bis of the CRDV Directive, banks must now meet a minimum of 56% P2R with CET1 capital (as opposed to 100% previously) and 75% with Tier 1 capital.

(In EURm)

31.12.2022

31.12.2021

Shareholders’ equity (IFRS), Group share

66,451

65,067

Deeply subordinated notes

(10,017)

(8,003)

Perpetual subordinated notes

(0)

(0)

Group consolidated shareholders’ equity net of deeply subordinated and perpetual subordinated notes

56,434

57,064

Non-controlling interests

5,207

4,762

Intangible assets

(2,161)

(1,828)

Goodwill

(3,478)

(3,408)

Dividends proposed (to the General Meeting) and interest expenses on deeply subordinated and perpetual subordinated notes

(1,879)

(2,345)

Deductions and regulatory adjustments

(5,484)

(4,410)

COMMON EQUITY TIER 1 CAPITAL

48,639

49,835

Deeply subordinated notes and preferred shares

10,017

8,003

Other additional Tier 1 capital

209

206

Additional Tier 1 deductions

(138)

(137)

TOTAL TIER 1 CAPITAL

58,727

57,907

Tier 2 instruments

12,549

11,820

Other Tier 2 capital

238

287

Tier 2 deductions

(1,790)

(1,527)

Total regulatory capital

69,724

68,487

TOTAL RISK-WEIGHTED ASSETS

360,464

363,371

Credit and counterparty credit risk-weighted assets

300,694

304,922

Market risk-weighted assets

13,747

11,643

Operational risk-weighted assets

46,023

46,806

Solvency ratios

 

 

Common Equity Tier 1 ratio

13.49%

13.71%

Tier 1 ratio

16.29%

15.94%

Total capital ratio

19.34%

18.85%

(1)

Ratios set in accordance with CRR2/CRD5 rules as published in June 2019, including Danish compromise for insurance, and taking into account the IFRS 9 phasing (fully-loaded CET1 ratio of 13.34% as at 31 December 2022, the phasing effect being +17 bps) and the effects of the ECB’s Covid-19 transitional measures ending on 31 December 2022.

The solvency ratio as at 31 December 2022 stood at 13.5% in Common Equity Tier 1 (13.7% at 31 December 2021) and 16.3% in Tier 1 (15.9% at 31 December 2021) for a total ratio of 19.3% (18.8% at 31 December 2021).

Group shareholders’ equity at 31 December 2022 totalled EUR 66.4 billion (compared with EUR 65.1 billion at 31 December 2021).

After taking into account non-controlling interests and regulatory adjustments, CET1 regulatory capital was EUR 48.6 billion at 31 December 2022, vs. EUR 49.8 billion at 31 December 2021. The Additional Tier One deductions mainly regard authorisations to buy back own Additional Tier 1 capital instruments as well as subordinated bank and insurance loans.

(In EURm)

31.12.2022

31.12.2021

Unrecognised minority interests

(3,326)

(2,860)

Deferred tax assets

(1,068)

(1,096)

Prudent Valuation Adjustment

(852)

(911)

Adjustments related to changes in the value of own liabilities

(245)

254

Other

 7

203

TOTAL CET1 REGULATORY DEDUCTIONS AND ADJUSTMENTS

(5,484)

(4,410)

The prudential deductions and restatements included in the “Other” category essentially involve the following:

any positive difference between expected losses on customer loans and receivables managed under the internal ratings-based (IRB) approach, and the sum of related value adjustments and impairment losses;

expected losses on equity portfolio exposures;

unrealised gains and losses on cash flow hedges;

assets from defined benefit pension funds, net of deferred taxes;

securitisation exposures weighted at 1,250%, when these positions are excluded from the calculation of RWA.

5.5 RISK-WEIGHTED ASSETS AND CAPITAL REQUIREMENTS

The Basel III Accord has established the rules for calculating minimum capital requirements in order to more accurately assess the risks to which banks are exposed, taking into account the risk profile of transactions via two approaches intended for determining RWA: a standardised approach and an advanced one based on internal methods modelling the counterparties’ risk profiles.

 

Risk-weighted

assets

Total own funds

requirements

(In EURm)

31.12.2022

30.09.2022

31.12.2021

31.12.2022

Credit risk (excluding counterparty credit risk)

269,084

271,963

271,012

21,527

o.w. standardised approach

94,083

95,360

103,323

7,527

o.w. Foundation IRB (FIRB) approach

4,190

4,213

4,121

335

o.w. slotting approach

667

720

752

53

o.w. equities under the simple risk-weighted approach

2,753

3,404

3,515

220

o.w. other equities under IRB approach

13,864

14,716

18,189

1,109

o.w. Advanced IRB (AIRB) approach

153,528

153,551

141,111

12,282

Counterparty credit risk – CCR

23,803

31,160

27,478

1,904

o.w. standardised approach(1)

6,649

8,102

9,304

532

o.w. internal model method (IMM)

12,381

17,145

13,088

990

o.w. exposures to a CCP

918

1,084

1,273

73

o.w. credit valuation adjustment – CVA

2,805

3,521

2,807

224

o.w. other CCR

1,050

1,308

1,007

84

Settlement risk

6

12

63

1

Securitisation exposures in the non-trading book (after the cap)

7,801

7,562

6,368

624

o.w. SEC-IRBA approach

2,706

2,764

2,082

216

o.w. SEC-ERBA incL IAA

4,023

3,881

3,978

322

o.w. SEC-SA approach

1,072

916

308

86

o.w. 1,250%/deductions

-

-

-

-

Position, foreign exchange and commodities risks (Market risk)

13,747

15,324

11,643

1,100

o.w. standardised approach

1,932

2,528

1,419

155

o.w. IMA

11,816

12,796

10,225

945

Large exposures

-

-

-

-

Operational risk

46,023

45,626

46,806

3,682

o.w. basic indicator approach

-

-

-

-

o.w. standardised approach

1,290

1,232

2,412

103

o.w. advanced measurement approach

44,733

44,394

44,394

3,579

Amounts (included in the “credit risk” section above)
below the thresholds for deduction (subject to 250% risk weight)

7,319

7,835

7,344

586

TOTAL

360,465

371,645

363,371

28,837

(1)

The amounts of RWA at 31 December 2021 correspond to the new SA-CCR approach following the application of Regulation (EU) No. 2019/876 (CRR2).

(In EURbn)

Credit and

counterparty credit

Market

Operational

Total

31.12.2022

Total

31.12.2021

French Retail Banking

101.0

0.0

5.1

106.1

95.5

International Retail Banking and Financial Services

105.6

0.2

4.6

110.4

117.7

Global Banking and Investor Solutions

82.1

12.6

29.0

123.7

131.2

Corporate Centre

12.1

0.9

7.4

20.3

19.0

Group

300.7

13.7

46.0

360.5

363.4

As at 31 December 2022, RWA (EUR 360.5 billion) were distributed as follows:

credit and counterparty credit risks accounted for 83% of RWA (of which 35% for International Retail Banking and Financial Services);

market risk accounted for 4% of RWA (of which 92% for Global Banking and Investor Solutions);

operational risk accounted for 13% of RWA (of which 63% for Global Banking and Investor Solutions).

(In EURm)

Crédit du Nord

Boursorama

Komerčni Banka

IRB

Standard

IRB

Standard

IRB

Standard

Credit and counterparty credit risks

18,737

3,150

606

1,697

13,962

2,346

Sovereign

-

-

1

26

34

Financial institutions

83

3

4

10

813

246

Corporate

10,119

1,043

15

9,179

1,449

Retail

6,985

943

546

1,403

3,755

84

Equity investments

1,426

123

55

-

188

-

Other non-credit obligation assets

1,038

268

533

Securitisation

123

Market risk

28

-

-

70

-

Operational risk

578

-

112

-

758

-

TOTAL 2022

22,493

-

2,414

-

17,066

-

TOTAL 2021

21,120

-

-

-

15,251

-

5.6 TLAC AND MREL RATIOS

The Total Loss Absorbing Capacity (TLAC) requirement which applies to Societe Generale is 18 % of RWA since 1 January 2022, to which the conservation buffer of 2.5%, the G-SIB buffer of 1% and the countercyclical buffer must be added. As at 31 December 2022, the global TLAC requirement thus stood at 21.66% of Group RWA.

The TLAC rule also provides for a minimum ratio of 6.75% of the leverage exposure January 2022.

As at 31 December 2022, Societe Generale reached a phased-in TLAC ratio of 30.5% excluding senior preferred debts. The phased-in ratio stands at 33.6% of RWA when considering the possibility to account for senior preferred debts up to 3.5% of RWA and 9% of leverage exposure.

Quantitative information on the TLAC ratio can be found in Chapter 1 (summary) and Section 5.10 (detail).

The Minimum Requirement for own funds and Eligible Liabilities (MREL) has applied to credit institutions and investment firms within the European Union since 2016.

Contrary to the TLAC ratio, the MREL is tailored to each institution and regularly revised by the resolution authority.

Throughout 2022, Societe Generale complied with its MREL requirement.

5.7 LEVERAGE RATIO

The Group calculates its leverage ratio according to the CRR2 rules applicable since June 2021.

Managing the leverage ratio means both calibrating the amount of Tier 1 capital (the numerator of the ratio) and controlling the Group’s leverage exposure (the denominator of the ratio) to achieve the target ratio levels that the Group sets for itself. To this end, the leverage exposure of the different businesses is monitored by the Finance Division.

The Group aims to maintain a consolidated leverage ratio that is significantly higher than the 3.5% minimum set in the Basel Committee’s recommendations, transposed in Europe via CRR2, including a fraction of the systemic buffer which is applicable to the Group.

As at 31 December 2022, the leverage ratio of Societe Generale stood at 4.37% considering a Tier 1 capital amount of EUR 58.7 billion compared with a leverage exposure of EUR 1,345 billion (versus 4.87% as at 31 December 2021, with EUR 57.9 billion and EUR 1,190 billion, respectively).

(In EURm)

31.12.2022

31.12.2021

Tier 1 capital(2)

58,727

57,907

Total assets in prudential balance sheet(3)

1,339,864

1,299,698

Adjustments for derivative financial instruments

(7,197)

8,619

Adjustments for securities financing transactions(4)

15,156

14,896

Off-balance sheet exposure (loan and guarantee commitments)

123,022

118,263

Technical and prudential adjustments

(125,976)

(252,223)

o.w. central banks exemption(5)

-

(117,664)

Leverage ratio exposure

1,344,870

1,189,253

Leverage ratio

4.37%

4.87%

(1)

Ratio set in accordance with CRR2 rules and taking into account the IFRS 9 phasing (leverage ratio of 4.32% without phasing at 31 December 2022, the phasing effect being -5 bps).

(2)

The capital overview is available in table 3.

(3)

The prudential balance sheet corresponds to the IFRS balance sheet less entities accounted for through the equity method (mainly insurance subsidiaries).

(4)

Securities financing transactions: repurchase transactions, securities lending or borrowing transactions and other similar transactions.

(5)

Change to the opening terminal.

5.8 LARGE EXPOSURES RATIO

The CRR incorporates the provisions regulating large exposures. As such, Societe Generale must not have any exposure towards a single beneficiary which exceeds 25% of the Group’s capital.

The final rules of the Basel Committee on large exposures, transposed in Europe via CRR2, have been applicable since June 2021. The main changes compared with CRR reside in the calculation of the regulatory limit (25%), henceforth expressed as a proportion of Tier 1 (instead of cumulated Tier 1 and Tier 2), and in the introduction of a cross-specific limit on systemic institutions (15%).

5.9 FINANCIAL CONGLOMERATE RATIO

The Societe Generale group, also identified as a “Financial conglomerate”, is subject to additional supervision from the ECB.

At 31 December 2022, Societe Generale’s financial conglomerate equity covered the solvency requirements for both banking and insurance activities.

At 30 June 2022, the financial conglomerate ratio was 140%, consisting of a numerator “Own funds of the Financial Conglomerate” of EUR 74.1billion, and a denominator “Regulatory requirement of the Financial Conglomerate” of EUR 52.9 billion.

As at 31 December 2021, the financial conglomerate ratio was 150%, consisting of a numerator “Own funds of the Financial Conglomerate”of EUR 76.1 billion, and a denominator “Regulatory requirement of the Financial Conglomerate” of EUR 50.9 billion.

(In EURm)

31.12.2022

Supplementary own fund requirements of the financial conglomerate (amount) 

21,236

Capital adequacy ratio of the financial conglomerate (%)

140%

5.10 ADDITIONAL QUANTITATIVE INFORMATION ON OWN FUNDS AND CAPITAL ADEQUACY

(In EURm)

31.12.2022

30.09.2022

30.06.2022

31.03.2022

31.12.2021

AVAILABLE CAPITAL (AMOUNTS)

1

Common Equity Tier 1 (CET1) capital

48,639

47,614

47,254

48,211

49,835

2

Common Equity Tier 1 (CET1) capital as if IFRS 9 or analogous ECLs transitional arrangements had not been applied

48,011

47,043

46,906

47,728

49,223

3

Tier 1 capital

58,727

57,053

56,024

56,443

57,907

4

Tier 1 capital as if IFRS 9 or analogous ECLs transitional arrangements had not been applied

58,100

56,482

55,676

55,960

57,295

5

Total capital

69,724

69,444

67,835

66,990

68,487

6

Total capital as if IFRS 9 or analogous ECLs transitional arrangements had not been applied 

69,096

68,873

67,486

66,507

67,875

RISK-WEIGHTED ASSETS (AMOUNTS)

7

Total risk-weighted assets

360,465

371,645

367,637

376,636

363,371

8

Total risk-weighted assets as if IFRS 9 or analogous ECLs transitional arrangements had not been applied

360,435

371,645

367,610

376,482

363,216

RISK-WEIGHTED ASSETS (AMOUNTS)

9

Common Equity Tier 1 (as a percentage of RWA)

13.49%

12.81%

12.85%

12.80%

13.71%

10

Common Equity Tier 1 (as a percentage of RWA) as if IFRS 9 or analogous ECLs transitional arrangements had not been applied

13.32%

12.66%

12.76%

12.68%

13.55%

11

Tier 1 (as a percentage of RWA)

16.29%

15.35%

15.24%

14.99%

15.94%

12

Tier 1 (as a percentage of RWA) as if IFRS 9 or analogous ECLs transitional arrangements had not been applied

16.12%

15.20%

15.15%

14.86%

15.77%

13

Total capital (as a percentage of RWA)

19.34%

18.69%

18.45%

17.79%

18.85%

14

Total capital (as a percentage of RWA) as if IFRS 9 or analogous ECLs transitional arrangements had not been applied

19.17%

18.53%

18.36%

17.67%

18.69%

LEVERAGE RATIO

15

Leverage ratio total exposure measure(1)

1,344,870

1,392,918

1,382,334

1,319,813

1,189,253

16

Leverage ratio

4.37%

4.10%

4.05%

4.28%

4.87%

17

Leverage ratio as if IFRS 9 or analogous ECLs transitional arrangements had not been applied 

4.32%

4.06%

4.03%

4.24%

4.82%

(1)

Leverage ratio total exposure measure taking into account the IFRS 9 transitional provisions over the whole historical period considered, as well as the option to exempt some central bank exposures until 31 March 2022 included.

(In EURm)

31.12.2022

Exposure value

RWA amount

Own fund instruments held in insurance or re-insurance undertakings or insurance holding company not deducted from own funds

3,464

12,820

OWN FUNDS DETAILS

(In EURm)

31.12.2022

30.06.2022

Amounts

Source based on

reference

numbers of the

balance sheet

under the

regulatory

scope of

consolidation

Amounts

Source based on

reference

numbers of the

balance sheet

under the

regulatory

scope of

consolidation

COMMON EQUITY TIER 1 (CET1) CAPITAL: INSTRUMENTS AND RESERVES

1

Capital instruments and the related share premium accounts 

20,776

6

20,540

6

 

of which fully paid up capital instruments

1,062

 

1,046

 

 

of which share premium

19,713

 

19,494

 

2

Retained earnings 

30,771

6

34,954

6

3

Accumulated other comprehensive income (and other reserves)

3,858

6

1,277

6

EU-3a

Funds for general banking risk

-

 

-

 

4

Amount of qualifying items referred to in Article 484 (3) and the related share premium accounts subject to phase out from CET1 

-

 

-

 

5

Minority interests (amount allowed in consolidated CET1)

1,881

7

1,893

7

EU-5a

Independently reviewed interim profits net of any foreseeable charge or dividend 

139

6

-

6

6

Common Equity Tier 1 (CET1) capital before regulatory adjustments

57,424

0

58,665

 

COMMON EQUITY TIER 1 (CET1) CAPITAL: REGULATORY ADJUSTMENTS

7

Additional value adjustments (negative amount)

(852)

 

(912)

 

8

Intangible assets (net of related tax liability) (negative amount)

(5,639)

4

(5,267)

4

10

Deferred tax assets that rely on future profitability excluding those arising from temporary differences (net of related tax liability where the conditions in Article 38 (3) are met) (negative amount)

(1,068)

2

(1,177)

2

11

Fair value reserves related to gains or losses on cash flow hedges of financial instruments that are not valued at fair value

294

 

181

 

12

Negative amounts resulting from the calculation of expected loss amounts 

-

 

-

 

13

Any increase in equity that results from securitised assets (negative amount)

-

 

-

 

14

Gains or losses on liabilities valued at fair value resulting from changes in own credit standing

(241)

 

(697)

 

15

Defined-benefit pension fund assets (negative amount)

(71)

3

(167)

3

16

Direct and indirect holdings by an institution of own CET1 instruments (negative amount)

(937)

 

(986)

 

17

Direct, indirect and synthetic holdings of the CET 1 instruments of financial sector entities where those entities have reciprocal cross holdings with the institution designed to inflate artificially the own funds of the institution (negative amount)

-

 

-

 

18

Direct, indirect and synthetic holdings by the institution of the CET1 instruments of financial sector entities where the institution does not have a significant investment in those entities (amount above 10% threshold and net of eligible short positions) (negative amount)

(0)

 

(0)

 

19

Direct, indirect and synthetic holdings by the institution of the CET1 instruments of financial sector entities where the institution has a significant investment in those entities (amount above 10% threshold and net of eligible short positions) (negative amount)

0

 

(0)

 

EU-20a

Exposure amount of the following items which qualify for a RW of 1,250%, where the institution opts for the deduction alternative

(70)

 

(40)

 

EU-20b

of which qualifying holdings outside the financial sector (negative amount)

-

 

-

 

EU-20c

of which securitisation positions (negative amount)

(70)

 

(40)

 

EU-20d

of which free deliveries (negative amount)

-

 

-

 

21

Deferred tax assets arising from temporary differences (amount above 10% threshold, net of related tax liability where the conditions in Article 38 (3) are met) (negative amount)

(0)

 

0

 

22

Amount exceeding the 17,65% threshold (negative amount)

0

 

0

 

23

of which direct, indirect and synthetic holdings by the institution of the CET1 instruments of financial sector entities where the institution has a significant investment in those entities

-

 

-

 

25

of which deferred tax assets arising from temporary differences

-

 

-

 

EU-25a

Losses for the current financial year (negative amount)

-

 

(1,897)

 

EU-25b

Foreseeable tax charges relating to CET1 items except where the institution suitably adjusts the amount of CET1 items insofar as such tax charges reduce the amount up to which those items may be used to cover risks or losses (negative amount)

-

 

-

 

27

Qualifying AT1 deductions that exceed the AT1 items of the institution (negative amount)

-

 

-

 

27a

Other regulatory adjusments

(202)

 

(449)

 

28

Total regulatory adjustments to Common Equity Tier 1 (CET1)

(8,786)

 

(11,411)

 

29

Common Equity Tier 1 (CET1) capital 

48,639

 

47,254

 

ADDITIONAL TIER 1 (AT1) CAPITAL: INSTRUMENTS

30

Capital instruments and the related share premium accounts 

7,205

 

5,795

 

31

of which classified as equity under applicable accounting standards

10,017

6

8,683

6

32

of which classified as liabilities under applicable accounting standards

-

 

-

 

33

Amount of qualifying items referred to in Article 484 (4) and the related share premium accounts subject to phase out from AT1 as described in Article 486(3) of CRR

-

 

-

 

EU-33a

Amount of qualifying items referred to in Article 494a(1) subject to phase out from AT1

-

 

-

 

EU-33b

Amount of qualifying items referred to in Article 494b(1) subject to phase out from AT1

2,813

 

2,888

 

34

Qualifying Tier 1 capital included in consolidated AT1 capital (including minority interests not included in row 5) issued by subsidiaries and held by third parties 

209

7

225

7

35

of which instruments issued by subsidiaries subject to phase out 

-

 

-

 

36

Additional Tier 1 (AT1) capital before regulatory adjustments

10,226

 

8,908

 

ADDITIONAL TIER 1 (AT1) CAPITAL: REGULATORY ADJUSTMENTS

37

Direct and indirect holdings by an institution of own AT1 instruments (negative amount)

(125)

 

(125)

 

38

Direct, indirect and synthetic holdings of the AT1 instruments of financial sector entities where those entities have reciprocal cross holdings with the institution designed to inflate artificially the own funds of the institution (negative amount)

-

 

-

 

39

Direct, indirect and synthetic holdings of the AT1 instruments of financial sector entities where the institution does not have a significant investment in those entities (amount above 10% threshold and net of eligible short positions) (negative amount)

-

 

-

 

40

Direct, indirect and synthetic holdings by the institution of the AT1 instruments of financial sector entities where the institution has a significant investment in those entities (net of eligible short positions) (negative amount)

(13)

1

(13)

1

42

Qualifying T2 deductions that exceed the T2 items of the institution (negative amount)

-

 

-

 

42a

Other regulatory adjustments to AT1 capital

-

 

-

 

43

Total regulatory adjustments to Additional Tier 1 (AT1) capital

(138)

 

(138)

 

44

Additional Tier 1 (AT1) capital 

10,089

 

8,770

 

45

Tier 1 capital (T1 = CET1 + AT1)

58,727

 

56,024

 

TIER 2 (T2) CAPITAL: INSTRUMENTS

46

Capital instruments and the related share premium accounts

8,174

5

7,805

5

47

Amount of qualifying items referred to in Article 484 (5) and the related share premium accounts subject to phase out from T2 as described in Article 486 (4) CRR

-

 

-

 

EU-47a

Amount of qualifying items referred to in Article 494a (2) subject to phase out from T2

-

 

-

 

EU-47b

Amount of qualifying items referred to in Article 494b (2) subject to phase out from T2

4,375

5

5,311

5

48

Qualifying own funds instruments included in consolidated T2 capital
(including minority interests and AT1 instruments not included in rows 5 or 34) issued by subsidiaries and held by third parties 

238

7

291

7

49

of which instruments issued by subsidiaries subject to phase out

-

 

-

 

50

Credit risk adjustments

94

 

296

 

51

Tier 2 (T2) capital before regulatory adjustments

12,881

 

13,703

 

TIER 2 (T2) CAPITAL: REGULATORY ADJUSTMENTS

52

Direct and indirect holdings by an institution of own T2 instruments and subordinated loans (negative amount)

(150)

 

(150)

 

53

Direct, indirect and synthetic holdings of the T2 instruments and subordinated loans of financial sector entities where those entities have reciprocal cross holdings with the institution designed to inflate artificially the own funds of the institution (negative amount)

-

 

-

 

54

Direct and indirect holdings of the T2 instruments and subordinated loans of financial sector entities where the institution does not have a significant investment in those entities (amount above 10% threshold and net of eligible short positions) (negative amount)

0

 

-

 

55

Direct and indirect holdings by the institution of the T2 instruments and subordinated loans of financial sector entities where the institution has a significant investment in those entities (net of eligible short positions) (negative amount)

(1,735)

1

(1,743)

1

EU-56a

Qualifying eligible liabilities deductions that exceed the eligible liabilities items of the institution (negative amount)

-

 

-

 

56b

Other regulatory adjusments to T2 capital

-

 

-

 

57

Total regulatory adjustments to Tier 2 (T2) capital

(1,885)

 

(1,893)

 

58

Tier 2 (T2) capital 

10,997

 

11,810

 

59

Total capital (TC = T1 + T2)

69,724

 

67,835

 

60

Total RWA

360,465

 

367,637

 

CAPITAL RATIOS AND REQUIREMENTS INCLUDING BUFFERS 

61

Common Equity Tier 1 (as a percentage of RWA)

13.49%

 

12.85%

 

62

Tier 1 (as a percentage of RWA)

16.29%

 

15.24%

 

63

Total capital (as a percentage of total RWA)

19.34%

 

18.45%

 

64

Institution CET1 overall capital requirement (CET1 requirement in accordance with Article 92 (1) CRR, plus additional CET1 requirement which the institution is required to hold in accordance with point (a) of Article 104(1) CRD, plus combined buffer requirement in accordance with Article 128(6) CRD) expressed as a percentage of RWA)

9.35%

 

9.24%

 

65

of which capital conservation buffer requirement 

2.50%

 

2.50%

 

66

of which countercyclical buffer requirement 

0.16%

 

0.05%

 

67

of which systemic risk buffer requirement 

-

 

-

 

EU-67a

of which Global Systemically Important Institution (G-SII) or Other Systemically Important Institution (O-SII) buffer

1.00%

 

1.00%

 

EU-67b

of which additional own funds requirements to address the risks other than the risk of excessive leverage

1.19%

 

1.19%

 

68

Common Equity Tier 1 available to meet buffer (as a percentage of RWA)

7.80%

 

7.16%

 

AMOUNTS BELOW THE THRESHOLDS FOR DEDUCTION (BEFORE RISK WEIGHTING)

72

Direct and indirect holdings of own funds and eligible liabilities of financial sector entities where the institution does not have a significant investment in those entities (amount below 10% threshold and net of eligible short positions) 

3,545

 

2,638

 

73

Direct and indirect holdings by the institution of the CET1 3 instruments of financial sector entities where the institution has a significant investment in those entities (amount below 17.65% thresholds
and net of eligible short positions) 

389

 

436

 

75

Deferred tax assets arising from temporary differences (amount below 17.65% threshold, net of related tax liability where the conditions in Article 38 (3) are met)

2,539

 

2,598

 

APPLICABLE CAPS ON THE INCLUSION OF PROVISIONS IN TIER 2

76

Credit risk adjustments included in T2 in respect of exposures subject to standardised approach (prior to the application of the cap)

-

 

-

 

77

Cap on inclusion of credit risk adjustments in T2 under standardised approach

1,219

 

1,278

 

78

Credit risk adjustments included in T2 in respect of exposures subject to internal ratings-based approach (prior to the application of the cap)

94

 

296

 

79

Cap for inclusion of credit risk adjustments in T2 under internal ratings-based approach

1,150

 

1,173

 

CAPITAL INSTRUMENTS SUBJECT TO PHASE-OUT ARRANGEMENTS (ONLY APPLICABLE BETWEEN 1 JANUARY 2014 AND 1 JANUARY 2022)

80

Current cap on CET1 instruments subject to phase out arrangements

-

 

-

 

81

Amount excluded from CET1 due to cap (excess over cap after redemptions and maturities)

-

 

-

 

82

Current cap on AT1 instruments subject to phase out arrangements

-

 

-

 

83

Amount excluded from AT1 due to cap
(excess over cap after redemptions and maturities)

-

 

-

 

84

Current cap on T2 instruments subject to phase out arrangements

-

 

-

 

85

Amount excluded from T2 due to cap
(excess over cap after redemptions and maturities)

-

 

-

 

The regulatory own funds items are used as a starting point to describe differences between balance sheet items used to calculate own funds and regulatory own funds.

I

Common Equity Tier 1 (CET1): Instruments and reserves

1.

difference due to deduction for holdings of own CET1 instruments;

2.

difference linked to a limited recognition of minority interests.

II

Common Equity Tier 1: Regulatory adjustments

3.

other comprehensive income from changes in the fair value through equity of financial assets are not deducted from regulatory own funds, except gains and losses on derivatives held as cash flow hedges;

4.

the differences between the amounts of the balance sheet under the prudential scope and under regulatory capital are related to taxes deferred on OCA and DVA;

5.

goodwill and other intangible assets net of related deferred tax liabilities are fully deducted from regulatory own funds;

6.

gains or losses on liabilities valued at fair value and recognised in the income statement resulting from changes in own credit spread (OCA) as well as gains or losses resulting from changes in credit spread on own liability derivatives (DVA) are deducted from Common Equity Tier 1 instruments.

III

Additional Tier 1 (AT1) capital: Instruments

7.

differences between balance sheet items used to calculate own funds and regulatory own funds are referring to the translation differences associated with these instruments;

8.

minority interests recognised in Additional Tier 1 instruments receive the same accounting treatment as described in Note 2.

IV

Additional Tier 1 (AT1) capital: Regulatory adjustments

9.

discrepancy due to the exclusion of insurance subordinated loans in the consolidated balance sheet.

V

Tier 2 (T2) capital: Instruments and provisions

10.

difference due to instruments ineligible to a classification as regulatory own funds;

11.

minority interests recognised in Tier 2 instruments receive the same accounting treatment as described in Note 2.

6 CREDIT RISK

 

IN BRIEF

Credit risk corresponds to the risk of losses arising from the inability of the Group’s customers, issuers or other counterparties to meet their financial commitments. This risk includes the risk linked to securitisation activities and may be further amplified by individual, country and sector concentration risk.

Credit risk RWA at end 2022

€276.9bn

(Credit risk RWA at end 2021: €277.4bn)

EAD calculated in IRB

(% of total credit risk):

86%

Credit risk corresponds to the risk of losses arising from the inability of the Group’s customers, issuers or other counterparties to meet their financial commitments. This risk includes the risk related to securitisation activities, and may be further amplified by individual, country and sector concentration risk. It also concerns the risk linked to syndication activity. It also includes underwriting risk which is the risk of loss arising from debt syndication activities where the bank fails to meet its final take target due to market conditions, inaccurate reading of investor demand, miscalculated credit profile of the borrower or credit deterioration of the borrower during the syndication phase of the loan/the bond.

6.1 CREDIT RISK MONITORING AND SURVEILLANCE SYSTEM

General principles

The risk approval process is based on the following main principles:

the analysis and the validation of the files fall respectively and independently to the sector of commercial follow-up of the client and to the dedicated risk units within the risk management function. In order to guarantee a consistent approach to Group risk-taking, this commercial monitoring sector and this risk unit examine all authorisation requests relating to a given client or category of clients. This commercial monitoring sector and this risk unit must be independent of each other;

the internal rating of counterparties is a key criterion in the granting policy. These ratings are proposed by the commercial monitoring sector and validated by the dedicated risk unit;

a system of delegation of competence, largely based on the internal rating of the counterparties, confers decision-making capacities to the risk units on the one hand and the commercial monitoring sectors on the other.

The business line assumes the burden of provisions and losses related to its credit decisions as the first line of defence. The Risk Department submits recommendations to CORISQ on the evolution of the granting policy, with limits on credit portfolios, for the countries, geographic areas, sectors, products or types of customers presenting high concentration risks.

Governance

The main mission of the Risk Department is to draw up the document formalizing and defining with the Finance Department the Group’s risk appetite, a mechanism aimed at defining the acceptable level of risk given the Group’s strategic objectives.

The Risk Department is responsible for implementing the system to manage and monitor risks, including cross-Group risks. The Risk Department exercises hierarchical and functional oversight of the Risk management function in charge of Group credit risk giving it a comprehensive view of all the Group’s credit risks.

The Risk Department helps define risk policies in light of each core business targets and the associated risk issues. It defines or approves the methods and procedures used to analyse, measure, approve and monitor risks and the risk IT system and makes sure these are appropriate to the core businesses’ needs. As second line of defence, various Risk Departments (for Retail Banking, Corporate and Investment Banking and Market activities) are also in charge of credit risk and as such responsible for the independent control as second line of defence. These consist in independently reviewing and comparing any credit application that exceeds the authority delegated to core businesses or local Risk Department teams. The Risk Department also assesses the quality of first-level credit reviews and takes any corrective action necessary.

The Risk Department also approves transactions and limits proposed by core business lines in respect of credit risk.

Finally, as part of its responsibilities for second line of defence, the Risk Department carries out permanent controls of credit risks. As such, the Risk Department provides independent control as a second line of defence on the detection and monitoring of the overshoot resolution.

The monthly Risk Monitoring Report presented to CORISQ by the Risk Department comments among others on the evolution of the Group’s credit portfolio and ensures compliance with the guidelines. Changes in the credit portfolio, changes in credit policy validated by CORISQ and respect for the Group’s risk appetite are presented at least quarterly to the Risk Committee of the Board of Directors.

As part of the quarterly reporting to the Board of Directors and to the Risk Committee of the Board of Directors, an overview of the main credit risk metrics supplemented by details of the thresholds and limits where applicable is presented. The following metrics are in particular the subject of a presentation with a quarterly history: net cost of risk, NPL rate (non-performing loans), coverage rate, average credit quality of portfolios, outstanding corporates placed under surveillance (watchlist), supervision of corporate exposures by sector of activity, Grands Risques Réglementaires (major regulatory risk exposures), environmental indicators of portfolio alignment, etc.

A monthly version of the reporting intended for the Risk Committee of the Board of Directors also provides additional information at a Business Unit level or on certain financing activities. A summary of the thematic CORISQs is also presented.

As part of the monthly CORISQ reporting to General Management, a summary of the main credit files is presented. Thematic presentations also provide recurring clarifications on certain perimeters and activities: personal real estate loans, consumer credit, non-retail credit risk, sector limits, country risks, major regulatory risks (Grands Risques Réglementaires), environmental indicators of portfolio alignment, etc.

Specificities of retail portfolios

Individual and professional portfolio (retail portfolio) have specific features in terms of risk management. This management is based on a statistical approach and on the use of tools and methods in the industrialisation of processes.

STATISTICAL APPROACH

The retail portfolio is made up of a sum of exposures of low unit amounts, validated in a partially automated manner, which together constitute significant outstandings at Group level and therefore a high level of risk.

Given the high number and standardisation of retail clients commitments, aggregate monitoring is necessary at all levels of the Risk function in charge of credit risk. This mass monitoring of retail customer exposure is based on the use of a statistical risk approach and monitoring by homogeneous risk class.

In these circumstances, the risk monitoring system for the Retail portfolio cannot rely on the same procedures or the same tools as for corporates.

For instance, any change in marketing policy (cut to probationary period for loyalty, delegation of lending decisions to brokers, increase in margins, etc.) can have a rapid and massive impact and must therefore be tracked by a system that allows all actors (i) to identify as quickly as possible where any deterioration in exposures is coming from and (ii) to take remedial action.

Even if the IFRS 9 standard authorises a collective approach and if the Group has a statistical approach on retail customers for the evaluation of the expected loss, the increase in risk for the purposes of the classification into stages is identified on an individual basis for this clientele. The available parameters (operating accounts and late payments) allow the assessment of the significant increase in credit risk at the level of individual exposures. The collective approach is currently only used in a very small number of instances within the Group.

The Risk management function must support Business Units and subsidiary managers in managing their risks with an eye to:

the effectiveness of lending policies;

the quality of the portfolio and its development over the lifetime of exposures (from grant to recovery).

Risk Department structures its supervision around the following four processes:

granting: this decision-making process can be more or less automated depending on the nature and complexity of the transactions, and hence the associated risk;

monitoring: different entities use different systems for granting and managing retail risks systems (scoring, expert systems, rules, etc.) and an appropriate monitoring system must be in place for each to assess the appropriateness of the grant rules applied (notably via monitoring);

recovery: recovery is an essential stage in the life cycle of Retail portfolio credits and makes a decisive contribution to our control of cost of risk. Whatever the organisation adopted (outsourcing, in-house collection, etc.), the establishment of an effective collection process is an essential element of good risk management. It makes a decisive contribution to controlling the cost of risk and limiting the level of our non-performing loans. If recovery is outsourced, it must conform to the Group’s regulations governing outsourcing;

provisioning: provisions against the Retail portfolio are decided at local level. They are calculated using the methodologies and governance methods defined and approved by the Risk Department.

Monitoring individual concentration

Societe Generale complies with regulations governing large exposures (major regulatory risks exposure cap of 25% of equity). A more restrictive internal limit of 10% delegated by General Management (which can occasionally or permanently amend it) has been put in place. Since 1 July 2018, the High Council for Financial Stability has imposed to financial institutions an exposure limit on most indebted companies established in France at a maximum level of 5% of eligible equity.

Internal systems are implemented to identify and manage the risks of individual concentrations, particularly at granting of credit. For example, concentration thresholds, based on the internal rating of counterparties, are set by CORISQ and define the governance for validating the limits on individual concentrations. Exposures to groups of clients deemed significant by the Group are reviewed by the Large Exposure Committee chaired by the General Management. As part of the identification of its risks, the Group also carries out loss simulations by type of customer (on significant individual exposures that the Group could have).

The Group uses credit derivatives to reduce some exposures considered to be overly significant. Furthermore, the Group systematically seeks to mutualise risks with other banking partners, at origination or through secondary sales, to avoid keeping an excessive share in operations of large-scale companies.

Monitoring country risk

Country risk arises when an exposure (loan, security, guarantee or derivative) becomes susceptible to negative impact of the country for example from changing regulatory, political, economic, social and financial conditions.

Stricto sensu, the notion of country risk refers to political and non-transfer risk which covers the risk of non-payment resulting from either actions or measures taken by local government authorities (decision to prohibit the debtor from meeting its commitments, nationalisation, expropriation, non-convertibility, etc.), domestic events (riots, civil war, etc.) or external events (war, terrorism, etc.).

More broadly, a deterioration of the credit quality of the Country, the Sovereign, or the conditions of activity in the country may result in a commercial risk, with in particular a deterioration of the credit quality of all counterparties in a given country due to a national economic or financial crisis, independently of each counterparty’s individual financial situation. This could be a macroeconomic shock (sharp slowdown in activity, systemic banking crisis, etc.), currency depreciation, or sovereign default on external debt potentially entailing other defaults.

Overall limits (except for SUIG – Sovereign Upper Investment Grade countries) and/or monitoring of exposures have been established for countries based on their internal ratings and governance indicators. The supervision is strengthened depending on the level of the country’s risk.

Country limits (and in some cases thresholds by country) are approved annually by General Management (or Risk division in specific situations). They can be revised downward at any time if the country’s situation deteriorates or is expected to deteriorate.

All Group exposures (securities, derivatives, loans and guarantees) are taken into account by this monitoring. The Country Risk methodology determines an initial risk country and a final risk country (after any guarantee-related effects), which is supervised using country limits or threshold (except for SUIG countries).

The procedure for putting a country on watch list is triggered in the event of deterioration in the country risk or anticipation of such a deterioration by the Risk Department.

Sector monitoring

The Group regularly reviews its entire credit portfolio through analyses by business sector. To do this, it relies on industry sector studies (including a one-year anticipation of sectoral risk) and on sectoral concentration analyses.

In addition, the Group periodically reviews its exposures to the portfolio segments presenting a specific risk profile, within the framework of CORISQs at Group level or at Business Unit level. These identified sectors or sub-portfolios are, where appropriate, subject to specific supervision through portfolio exposure limits and specific granting criteria. The limits are monitored either at General Management level or at Business Unit management level depending on the materiality and the level of risk of the portfolios.

As a complement, more targeted sector-based research and business portfolio analysis, may be conducted by General Management, the Risk Department or Bank Departments, depending on current issues. In that respect, certain sectors weakened in 2022 by the Russian-Ukrainian crisis and its effects have been subject to dedicated monitoring (for example the electricity and gas supplier sector in Europe).

Portfolios specifically monitored by the Group CORISQ include:

individual and professional credit portfolio (retail) in metropolitan France and in International Retail Banking in Europe. The Group defines in particular a risk appetite target concerning the minimum share covered by Crédit Logement guarantee for real estate loans granted to individuals;

oil and gas sectors, on which the Group has defined a credit policy adapted to the different types of activity of sector players. This policy distinguishes financing guaranteed by oil reserves, project financing, short-term trade finance transactions, and takes into account regional characteristics;

commercial real estate scope, on which the Group has defined a framework for origination and monitoring of exposures and limits according to the different types of financing, geographical areas and/or activities;

leveraged finance, for which the Group applies the definition of the scope and the management guidelines recommended by the ECB in 2017 (Guidance on leveraged transactions). The Group continues to pay a particular attention to the Leverage Buy-Out (LBO) sub-portfolio, as well as to the highly-leveraged transactions segment;

exposures on hedge funds is subject to a specific attention. The Group incurs risk on hedge funds through derivative transactions and its financing activity guaranteed by shares in funds. Risks related to hedge funds are governed by individual limits and global limits on market risks and wrong way risks;

exposures on shadow banking are managed and monitored in accordance with the EBA guidelines published in 2015 which specifies expectations regarding the internal framework for identifying, controlling and managing identified risks. CORISQ has set a global exposure threshold for shadow banking.

Credit stress tests

With the aim of identifying, monitoring and managing credit risk, the Risk Department works with the businesses to conduct a set of specific stress tests relating to a country, subsidiary or activity. These specific stress tests combine both recurring stress tests, conducted on those portfolios identified as structurally carrying risk, and ad hoc stress tests, designed to recognise emerging risks. Some of these stress tests are presented to CORISQ and used to determine how to frame the corresponding the activities concerned.

Credit risk stress tests complement the global analysis with a more granular approach and allow fine-tuning of the identification, assessment and operational management of risk, including concentration. They allow to calculate the expected credit losses on exposures which have undergone an event of default and on exposures which have not undergone an event of default, in accordance with the method prescribed in the standard IFRS 9. The perimeter covered may include counterparty credit risk on market activities when relevant.

6.2 CREDIT RISK HEDGING

Guarantees and collateral

The Group uses credit risk mitigation techniques for both market and commercial banking activities. These techniques provide partial or full protection against the risk of debtor insolvency.

There are two main categories:

personal guarantees are commitments made by a third party to replace the primary debtor in the event of the latter’s default. These guarantees encompass the protection commitments and mechanisms provided by banks and similar credit institutions, specialised institutions such as mortgage guarantors, monoline or multiline insurers, export credit agencies, States in the context of the health crisis linked to Covid-19 and consequences of Ukraine conflict, etc. By extension, credit insurance and credit derivatives (purchase of protection) also belong to this category;

collateral can consist of physical assets in the form of personal or real property, commodities or precious metals, as well as financial instruments such as cash, high-quality investments and securities, and also insurance policies.

Appropriate haircuts are applied to the value of collateral, reflecting its quality and liquidity.

In order to reduce its risk-taking, the Group is pursuing active management of its securities, in particular by diversifying them: physical collateral, personal guarantees and others (including Credit Default Swaps).

For information, the mortgage loans of retail customers in France benefit overwhelmingly from a guarantee provided by the financing company Crédit Logement, ensuring the payment of the mortgage to the Bank in the event of default by the borrower (under conditions of compliance with the terms of collateral call defined by Crédit Logement).

During the credit approval process, an assessment is performed on the value of guarantees and collateral, their legal enforceability and the guarantor’s ability to meet its obligations. This process also ensures that the collateral or guarantee successfully meets the criteria set forth in the Capital Requirements Directive (CRD) and in the Capital Requirements Regulation (CRR).

The guarantors are subject to an internal rating updated at least annually. Regarding collateral, regular revaluations are made on the basis of an estimated disposal value composed of the market value of the asset and a discount. The market value corresponds to the value at which the good should be exchanged on the date of the valuation under conditions of normal competition. It is preferably obtained on the basis of comparable assets, failing this by any other method deemed relevant (example: value in use). This value is subject to haircuts depending on the quality of the collateral and the liquidity conditions.

Regarding collateral used for credit risk mitigation and eligible for the RWA calculation, it should be noted that 95% of guarantors are investment grade. These guarantees are mainly provided by Crédit Logement, export credit agencies, the French State (within the Prêts Garantis par l’État framework of the loans guaranteed by the French State) and insurance companies.

In accordance with the requirements of European Regulation No. 575/2013 (CRR), the Group applies minimum collateralisation frequencies for all collateral held in the context of commitments granted (financial collateral, commercial real estate, residential real estate, other security interests, leasing guarantees).

Closer valuations must be carried out in the event of a significant change in the market concerned, the default or litigation of the counterparty or at the request of the risk management function.

In addition, the effectiveness of credit risk hedging policies is monitored as part of the LGD.

It is the responsibility of the risk management function to validate the operational procedures put in place by the business lines for the periodic valuation of collateral (guarantees and collateral), whether automatic valuations or on an expert opinion and whether during the credit decision for a new competition or during the annual renewal of the credit file.

The amount of guarantees and collateral is capped at the amount of outstanding loans less provisions, i.e. EUR 388.5 billion as at 31 December 2022 (compared with EUR 373 billion as at 31 December 2021), of which EUR 159.5 billion for retail customers and EUR 229.1 billion for other types of counterparties (compared with EUR 175 billion and EUR 198 billion as at 31 December 2021, respectively).

The outstanding loans covered by these guarantees and collateral correspond mainly to loans and receivables at amortised cost, which amounted to EUR 304.8 billion as at 31 December 2022, and to off-balance sheet commitments, which amounted to EUR 75.2 billion (compared with EUR 294 billion and EUR 68 billion as at 31 December 2021 respectively).

The amounts of guarantees and collateral received for performing outstanding loans (Stage 1) and under-performing loans (Stage 2) with payments past due amounted to EUR 2.3 billion as at 31 December 2022 (EUR 2.4 billion as at 31 December 2021), including EUR 0.89 billion on retail customers and EUR 1.4 billion on other types of counterparties (versus EUR 1.5 billion and EUR 0.9 billion as at 31 December 2021 respectively).

The amount of guarantees and collateral received for non-performing outstanding loans as at 31 December 2022 amounted to EUR 5.8 billion (compared with EUR 5.2 billion as at 31 December 2021), of which EUR 1.4 billion on retail customers and EUR 3.8 billion on other types of counterparties (compared with EUR 1.8 billion and EUR 3.4 billion respectively as at 31 December 2021). These amounts are capped at the amount of outstanding.

Use of credit derivatives to manage Corporate concentration risk

The Group may use credit derivatives for in the management of its Corporate credit portfolio, primarily to reduce individual, sector and geographic concentrations and to implement a proactive risk and capital management approach.

Housed in Corporate and Investment Banking, the Performance & Scarce Resources management (PSR) team works in close conjunction with the Risk Department and the businesses to reduce excessive portfolio concentrations, react quickly to any deterioration in the creditworthiness of a particular counterparty and recommend actions to improve the capital allocation. PSR is part of the department responsible for defining and effectively deploying the strategy, for monitoring performance and managing the scarce resources in the credit and loan portfolio.

Total outstanding purchases of protection through Corporate credit derivatives is slightly down at EUR 2.3 billion in nominal terms and a corresponding fair value of EUR +3.6 million at the end of December 2022 (compared to EUR 2.5 billion nominal value and a corresponding fair value of EUR -10.3 million at the end of December 2021). New operations have mainly been performed to approve capital allocation (EUR 1.7 billion) and to a lower extend reduce concentration risk (EUR 0.6 billion).

Over 2022, the credit default swaps (CDS) spreads of European investment grade issues (Itraxx index) experienced a significant change around an annual average of 94 bps (compared to 50 bps in 2021). The overall sensitivity of the portfolio (Price Value of a Basis Point) is falling due to the reduction in the average maturity of the protections.

The protection purchases (99% of outstanding as 31 December 2022) are mostly made against European clearing houses, and all against counterparties with “Investment Grade” ratings (rating at least equal to BBB-).

Moreover, the amounts recognised as assets (EUR 1.8 billion as at 31 December 2022 versus EUR 0.9 billion as at 31 December 2021) and liabilities (EUR 1.4 billion as at 31 December 2022 versus EUR 1.2 billion as at 31 December 2021) correspond to the fair value of credit derivatives mainly held under a transaction activity.

As part of LCR stress tests, Article 30(2) of Delegated Act 2015/61 provides for a specific additional flow associated with a three-notch downgrade of the bank’s rating. In this regard, the impact in terms of additional cash collateral in case of a three-notch downgrade of the Group’s rating is estimated at EUR 3 billion as at 31 December 2022.

Credit insurance

The Group has developed relationships with private insurers over the last several years in order to hedge some of its loans against commercial and political non-payment risks.

This activity is performed within a risk framework and monitoring system approved by the Group’s General Management. The system is based on an overall limit for the activity, along with sub-limits by maturity, and individual limits for each insurance counterparty, the latter being furthermore required to meet strict eligibility criteria. There is also a limit for insured transactions in Non Investment Grade countries.

6.3 IMPAIRMENT

The information relating to impairment can be found in Note 3.8 to the consolidated financial statements, which is part of Chapter 6 of the 2023 Universal Registration Document.

6.4 RISK MEASUREMENT AND INTERNAL RATINGS

General framework of the internal approach

Since 2007, Societe Generale has been authorised by its supervisory authorities to apply, for the majority of its exposures, the internal method (IRB method, Internal Rating Based) to calculate the capital required for credit risk.

The remaining exposures subject to the Standard approach mainly concern the portfolios of retail customers and SMEs (Small and Medium Enterprises) of the International Retail Banking activities. For exposures processed under the standard method excluding retail customers, which does not use the external note, the Group mainly uses external ratings from the Standard & Poor’s, Moody’s and Fitch rating agencies and the Banque de France. In the event that several Ratings are available for a third party, the second best Rating is retained.

The rating model monitoring framework is operational, in accordance with regulatory requirements, and detailed below in this section 6.4 “Risk measurement and internal ratings”.

In accordance with the texts published by the EBA as part of the “IRB Repair” program and following the review missions carried out by the ECB (TRIM – Targeted Review of Internal Models), the Group is reviewing its internal model system credit risk, so as to comply with these new requirements. A program (“Haussmann”) was launched in this direction within the Group, and deals with aspects such as:

the simplification of the architecture of the models, and the improvement of its auditability: either by ex nihilo development of new models based on the New Definition of Default (NDoD), and natively integrating the expectations of the EBA and ECB, or by bringing certain existing models up to the new standards;

improving the quality of data and its traceability throughout the chain;

the review of the roles and responsibilities of the teams, particularly with regard to the construction and monitoring (“back test”) of the system;

the review of certain IT application bricks, and their rationalization;

the establishment of a more complete normative base, and a more consistent relationship with the supervisor.

The roll-out plan also incorporates the changes decided as part of the Haussmann remediation program of the IRB Group system.

Following the TRIMs and as part of compliance with IRB Repair, evolutions to the rating systems and models have been and will be submitted for validation to the ECB.

To calculate its capital requirements under the IRB method, Societe Generale estimates the Risk-Weighted Assets (RWA) and the Expected Loss (EL) that may be incurred in light of the nature of the transaction, the quality of the counterparty (via internal rating) and all measures taken to mitigate risk.

The calculation of RWA is based on the Basel parameters, which are estimated using the internal risk measurement system:

the Exposure at Default (EAD) value is defined as the Group’s exposure in the event that the counterparty should default. The EAD includes exposures recorded on the balance sheet (such as loans, receivables, accrued income, etc.), and a proportion of off-balance sheet exposures calculated using internal or regulatory Credit Conversion Factors (CCF);

the Probability of Default (PD): the probability that a counterparty will default within one year;

the Loss Given Default (LGD): the ratio between the loss on an exposure in the event a counterparty defaults and the amount of the exposure at the time of the default.

The estimation of these parameters is based on a quantitative evaluation system which is sometimes supplemented by expert or business judgment.

In addition, a set of procedures sets out the rules relating to ratings (scope, frequency of review, grade approval procedure, etc.) as well as those for supervision, backtesting and the validation of models. These procedures allow, among other things, to facilitate critical human judgment, an essential complement to the models for non-retail portfolios.

The Group also takes into account:

the impact of guarantees and credit derivatives, by substituting the PD, the LGD and the risk-weighting calculation of the guarantor for that of the obligor (the exposure is considered to be a direct exposure to the guarantor) in the event that the guarantor’s risk weighting is more favorable than that of the obligor;

collateral used as guarantees (physical or financial). This impact is taken into account via the LGD level.

To a very limited extent, Societe Generale also applies an IRB Foundation approach (where only the probability of default is estimated by the Bank, while the LGD and CCF parameters are determined directly by regulation) to a portfolio of specialised lending exposures, including those granted to the subsidiaries Franfinance Entreprises, Sogelease and Star Lease.

Moreover, the Group has authorisation from the regulator to use the IAA (Internal Assessment Approach) method to calculate the regulatory capital requirement for ABCP (Asset-Backed Commercial Paper) securitisation.

In addition to the capital requirement calculation objectives under the IRBA method, the Group’s credit risk measurement models contribute to the management of the Group’s operational activities. They also constitute tools to structure, price and approve transactions and contribute to the setting of approval limits granted to business lines and the Risk function.

In case of capital requirement calculation in standard method, should an external rating be available, the corresponding exposure is assigned a risk weight according to the mapping tables provided in CRR (Articles 120-121-122) or more precisely to the tables published by the French supervisor ACPR (link: https://acpr.banque-france.fr/sites/default/files/media/2021/07/08/20210707_notice_crdiv_college_clean.pdf).

TABLE 35: CREDIT RATING AGENCIES USED IN STANDARDISED APPROACH

 

MOODY’S

FITCH

S&P

Sovereigns

Institutions

Corporates

TABLE 36: SCOPE OF THE USE OF IRB AND SA APPROACHES (CR6-A)

(In EURm)

31.12.2022

Exposure

value as

defined in

Article 166

CRR for

exposures

subject

to IRB

approach

Total

exposure

value for

exposures

subject

to the

Standardised

approach

and to

the IRB

approach

Percentage

of total

exposure

value

subject

to the

permanent

partial use

of the SA

(%)

Percentage

of total

exposure

value

subject to a

roll-out plan

(%)

Percentage

of total

exposure

value

subject

to IRB

approach

(%)

of which

percentage

subject

to AIRB

approach

(%)

Central governments or central banks

252,471

260,328

2.58%

-

97.42%

97.15%

of which regional governments or local authorities

 

805

19.01%

-

80.99%

80.99%

of which public sector entities

 

67

91.66%

-

8.34%

8.33%

Institutions

38,589

44,930

7.54%

0.93%

91.54%

91.53%

Corporates

287,105

331,166

8.11%

1.71%

90.18%

88.40%

of which Corporates – Specialised lending, excluding slotting approach

 

72,490

1.52%

-

98.48%

98.48%

of which Corporates – Specialised lending under slotting approach

 

1,255

-

-

100.00%

100.00%

Retail

193,661

238,959

15.30%

4.33%

80.38%

80.38%

of which Retail – Secured by real estate SMEs

 

6,263

13.74%

0.09%

86.17%

86.17%

of which Retail – Secured by real estate non-SMEs

 

140,400

9.30%

0.15%

90.55%

90.55%

of which Retail Qualifying revolving

 

5,598

17.57%

24.04%

58.38%

58.38%

of which Retail Other SMEs

 

36,089

22.70%

13.70%

63.60%

63.60%

of which Retail Other non-SMEs

 

50,609

26.61%

7.57%

65.82%

65.82%

Equity

5,104

6,335

19.44%

-

80.56%

80.56%

Other non-credit obligation assets

752

39,569

98.10%

-

1.90%

1.90%

TOTAL

777,682

921,287

12.33%

1.78%

85.89%

85.17%

TABLE 37: SCOPE OF APPLICATION OF THE IRB AND STANDARD APPROACHES FOR THE GROUP

 

IRB approach

Standard approach

French Retail Banking and Private Banking

Majority of French Retail Banking (including Boursorama) and Private Banking portfolios

Some specific client or product types for which the modeling is currently not adapted SG Kleinwort Hambros subsidiary

International Retail Banking and Financial Services

Subsidiaries KB (Czech Republic), CGI, Fiditalia, GEFA, SG Leasing SPA and Fraer Leasing SPA,
SGEF Italy

Other international subsidiaries (in particular BRD,
SG Maroc, Hanseatik)

Car Leasing (ALD)

Global Banking and Investor Solutions

Majority of Corporate and Investment Banking portfolios

SGIL subsidiary, as well as specific client or product types for which the modeling is currently not adapted

Credit risk measurement for wholesale clients

For Corporate (including specialised financing), Banking and Sovereign portfolios, the Group has implemented the following system.

RATING SYSTEM AND ASSOCIATED PROBABILITY OF DEFAULT

The rating system consists of assigning a score to each counterparty according to a specific internal scale per rating system (set of counterparties treated homogeneously whether in terms of granting, rating tool or recovery process). For perimeters on which an internal scale reviewed according to EBA IRB Repair standards has not yet been validated by the supervisor, each grade corresponds to a probability of default determined using historical series observed by Standard & Poor’s for over more than twenty years.

The following table presents the indicative corresponding scales of the main external credit rating agencies and the corresponding average probabilities of default, as well as the Group’s internal rating scale.

The rating assigned to a counterparty is generally proposed by a model, and possibly adjusted by a credit analyst, who then submits it for validation to the Risk Management function.

The counterparty rating models are structured in particular according to the type of counterparty (companies, financial institutions, public entities, etc.), geographic region and size of the Company (usually assessed through its annual revenue).

The Company rating models are underpinned by statistical models (regression methods) based on client default observations. They combine quantitative parameters derived from financial data that evaluate the sustainability and solvency of companies and qualitative parameters that evaluate economic and strategic dimensions.

TABLE 38: SOCIETE GENERALE’S INTERNAL RATING SCALE AND INDICATIVE CORRESPONDING SCALES OF RATING AGENCIES(1)

Investment grade/

Non-investment grade

Probability of

default range

Counterparty

internal rating

Indicative

equivalent

Standard &

Poor’s

Indicative

equivalent

Fitch

Indicative

equivalent

Moody’s

1 year internal

probality

of default

(average)

Investment grade

0.00 to < 0.10

1

AAA

AAA

Aaa

0.009%

2+

AA+

AA+

Aa1

0.014%

2

AA

AA

Aa2

0.020%

2-

AA-

AA-

Aa3

0.026%

3+

A+

A+

A1

0.032%

3

A

A

A2

0.036%

3-

A-

A-

A3

0.061%

0.10 to < 0.15

4+

BBB+

BBB+

Baa1

0.130%

0.15 to < 0.25

 

 

 

 

 

0.25 to < 0.50

4

BBB

BBB

Baa2

0.257%

0.50 to < 0.75

4-

BBB-

BBB-

Baa3

0.501%

Non-investment grade

0.75 to < 1.75

5+

BB+

BB+

Ba1

1.100%

1.75 to < 2.5

5

BB

BB

Ba2

2.125%

2.5 to < 5

5-

BB-

BB-

Ba3

3.260%

6+

B+

B+

B1

4.612%

5 to < 10

6

B

B

B2

7.761%

10 to < 20

6-

B-

B-

B3

11.420%

7+

CCC+

CCC+

Caa1

14.328%

20 to < 30

7

CCC

CCC

Caa2

20.441%

7-

C/CC/CCC-

CCC-

Caa3

27.247%

30 to < 100

 

 

 

 

 

(1)

The Group is in the process of implementing a multi-scale approach differentiated by rating system.

LGD MODELS

The Loss Given Default (LGD) is an economic loss that is measured by taking into account all parameters pertaining to the transaction, as well as the fees incurred for recovering the receivable in the event of a counterparty default.

The models used to estimate the Loss Given Default (LGD) excluding retail clients are applied by regulatory sub-portfolios, type of asset, size and location of the transaction or of the counterparty, depending on whether or not collateral has been posted, and the nature thereof if applicable. This makes it possible to define homogeneous risk pools, particularly in terms of recovery, procedures and the legal environment.

These estimates are founded on statistics when the number of loans in default is sufficient. In such circumstances, they are based on recovery data observed over a long period. When the number of defaults is insufficient, the estimate is revised or determined by an expert.

For its off-balance sheet exposures, the Group is authorised to use the internal approach for “Term loan with drawing period” products and revolving credit lines.

TABLE 39: MAIN CHARACTERISTICS OF MODELS AND METHODS – WHOLESALE CLIENTS

Parameter

modeled

Portfolio/

Category

of Basel assets

Number of methods, models

Methodology

Number of years default/loss

Wholesale clients

 

Sovereigns

1 method.

Econometric method. Low default portfolio.

 

Public sector entities

4 models according to geographic region.

Statistical (regression)/expert methods for the rating process, based on the combination of financial ratios and a qualitative questionnaire. Low default portfolio.

Probability
of Default (PD)

Financial institutions

11 models according to type of counterparty: banks, insurance, funds, financial intermediaries, funds of funds.

Expert models based on a qualitative questionnaire. Low default portfolio.

Specialised financing

3 models according to type of transaction.

Expert models based on a qualitative questionnaire. Low default portfolio.

 

Large corporates

9 models according to geographic region.

Mainly statistical models (regression) for the rating process, based on the combination of financial ratios and a qualitative questionnaire. Defaults observed over a period of 8 to 10 years.

 

Small- and medium-sized companies

21 models according to the size of the Company and the geographic region.

Mainly statistical models (regression) for the rating process, based on the combination of financial ratios and a qualitative questionnaire, behavioral score. Defaults observed over a period of 8 to 10 years.

 

Public sector entities – Sovereigns

6 models according to type of counterparty.

Calibration based on historical data and expert judgments. Losses observed over a period of more than 10 years.

 

Large corporates – Flat-rate Approach

25 models Flat-rate approach according to type of collateral.

Calibration based on historical data adjusted by expert judgments. Losses observed over a period of more than 10 years.

 

Large corporates – Discount Approach

16 models Discount approach according to type of recoverable collateral.

Statistical calibration based on historical market data adjusted by expert judgments. Losses observed over a period of more than 10 years.

Loss Given
Default (LGD)

Small- and medium-sized companies

17 models Flat-rate approach according to type of collateral or unsecured.

Statistical calibration based on historical data adjusted by expert judgments. Losses observed over a period of more than 10 years.

 

Project financing

9 models Flat-rate approach according to project type.

Statistical calibration based on historical data adjusted by expert judgments. Losses observed over a period of more than 10 years.

 

Financial institutions

5 models Flat-rate approach according to type of counterparty: banks, insurance, funds, etc. and the nature of the collateral.

Statistical calibration based on historical data adjusted by expert judgments. Losses observed over a period of more than 10 years.

 

Other specific portfolios

6 models: factoring, leasing with option to purchase and other specific cases.

Statistical calibration based on historical data adjusted by expert judgments. Losses observed over a period of more than 10 years.

Credit Conversion Factor (CCF)

Large corporates

5 models: term loans with drawing period, revolving credits, Czech Corporates.

Models calibrated by segment. Defaults observed over a period of more than 10 years.

Expected Loss (EL)

Real estate transactions

2 models by slotting.

Statistical model based on expert judgments and a qualitative questionnaire. Low default portfolio.

MONITORING THE PERFORMANCE OF INTERNAL MODELS

The performance level of the entire wholesale client credit system is measured by backtests that compare, by portfolio, the PD, LGD and CCF estimates with actual results, thus making it possible to measure the prudence of the risk parameters used in the IRB approach.

The backtest results and remediation plans are presented to the Expert Committee for discussion and approval (see section “Governance of the modelling of credit risk”). These results may justify the implementation of remediation plans if the system is deemed to be insufficiently prudent. The discriminating power of the models and the change of the composition of the portfolio are also measured.

The results presented above cover the entire Group portfolios. Backtests compare the estimated probability of default (arithmetic mean weighted by debtors) with the observed results (the historical annual default rate). The historical default rate was calculated on the basis of performing exposures over the period from 2008 to 2021.

The historic default rate remains stable across all the exposure classes. The estimated probability of default is higher than the historical default rates for all Basel portfolios and for most of the ratings. It should be noted that new internal models are being developed to comply with new regulatory requirements.

TABLE 40: COMPARISON OF RISK PARAMETERS : ESTIMATED AND ACTUAL LGD WHOLESALE CLIENTS

Basel Portfolio

31.12.2021

LGD IRBA(1)

Estimated losses

excluding margin of

prudence

Large corporates

37%

32%

Small and medium sized companies

39%

26%

(1)

LGD senior unsecured

The “observed EAD/IRBA EAD” ratio calculation method is being revised.

Credit risk measurements of retail clients

The Group has implemented the following system for the retail portfolio made up of individual customers, SCIs (real estate investment companies – Sociétés civiles immobilières) and professional customers.

RATING SYSTEM AND ASSOCIATED PROBABILITY OF DEFAULT

The modeling of the probability of default of retail client counterparties is carried out specifically by each of the Group’s subsidiaries using the IRBA method in consumer finance activities, equipment finance or in the Czech Republic. For French retail network, modelling is centralized within Group Risk Division. The models incorporate data on the account behavior of counterparties. They are segmented by type of customer and distinguish between retail customers, professional customers, very small businesses and real estate investment companies (Sociétés civiles immobilières).

The counterparties of each segment are classified automatically, using statistical models, into homogeneous risk pools, each of which is assigned a probability of default. These estimates are adjusted by a safety margin to estimate as best as possible a complete default cycle, using a through-the-cycle (TTC) approach.

LGD MODELS

The models for estimating the Loss Given Default (LGD) of retail customers are specifically applied by business line portfolio and by product, according to the existence or not of collateral.

The expected losses are estimated using internal long-term historical recovery data for exposures that have defaulted. These estimates are adjusted by safety margins in order to reflect the possible impact of a downturn.

CCF MODELS

For its off-balance sheet exposures, Societe Generale applies its estimates for revolving loans and overdrafts on current accounts held by retail and professional customers.

TABLE 41: MAIN CHARACTERISTICS OF MODELS AND METHODS USED – RETAIL CLIENTS

Parameter

modeled

Portfolio/

Category

of Basel assets

Number of models

Methodology

Number of years of default/loss

Retail clients

 

Residential real estate

7 models according to entity, type of guarantee (security, mortgage), type of counterparty: individuals or professionals/VSB, real estate investment company (SCI).

Statistical model (regression), behavioral score. Defaults observed over a period of more than five years.

Probability
of Default (PD)

Other loans to individual customers

15 models according to entity and to the nature and object of the loan: personal loan, consumer loan, car loan, etc.

Statistical model (regression), behavioral score. Defaults observed over a period of more than five years.

Renewable exposures

4 models according to entity and nature of the loan: overdraft on current account, revolving credit or consumer loan.

Statistical model (regression), behavioral score. Defaults observed over a period of more than five years.

 

Professionals
and very small businesses (VSB)

10 models according to entity, nature of the loan (medium- and long-term investment credits, short-term credit, car loans), and type of counterparty (individual or real estate investment company (SCI)).

Statistical model (regression or segmentation), behavioral score. Defaults observed over a period of more than five years.

 

Residential real estate

10 models according to entity, type of guarantee (security, mortgage), and type of counterparty: individuals or professionals/VSB, real estate investment company (SCI).

Statistical model of expected recoverable flows based on the current flows. Losses and recoverable flows observed over a period of more than 10 years.

Loss Given
Default (LGD)

Other loans to individual customers

18 models according to entity and to the nature and object of the loan: personal loan, consumer loan, car loan, etc.

Statistical model of expected recoverable flows based on the current flows. Model adjusted by expert opinions if necessary. Losses and recoverable flows observed over a period of more than 10 years.

Renewable exposures

7 models according to entity and nature of the loan: overdraft on current account, revolving credit or consumer loan.

Statistical model of expected recoverable flows based on the current flows. Model adjusted by expert opinions if necessary. Losses and recoverable flows observed over a period of more than 10 years.

 

Professionals
and very small businesses

12 models according to entity, nature of the loan (medium- and long-term investment credits, short-term credit, car loans), and type of counterparty (individual or real estate investment company (SCI)).

Statistical model of expected recoverable flows based on the current flows. Model adjusted by expert opinions if necessary. Losses and recoverable flows observed over a period of more than 10 years.

Credit Conversion Factor (CCF)

Renewable exposures

12 calibrations by entity for revolving products and personal overdrafts.

Models calibrated by segment over a period of observation of defaults of more than five years.

Residential real estate

4 calibrations by entity for real estate.

CCF flat rate of 100%. Relevance of this flat rate CCF is confirmed through the draw-down rate observed over a period of more than five years.

MONITORING THE PERFORMANCE OF INTERNAL MODELS

The performance level of the entire retail client credit system is measured by backtests, which check the performance of PD, LGD and CCF models and compare estimates with actual results.

Each year, the average long-term default rates observed by homogeneous risk class are compared to the PDs.

The results presented below cover all of the Group’s portfolios. Backtests compare the estimated probability of default (arithmetic average weighted by the debtors) to the observed results (the historical annual default rate). The historical default rate was calculated on the basis of healthy outstandings over the period from 2010 to 2021. Creditors are included in accordance with the revised instructions of the EBA publication of 14 December 2016 (EBA/GL/2016/11).

After a year in 2021 marked by the end of the health crisis and a historically low level of risk, the economic situation deteriorated in 2022. The impact of the war in Ukraine (energy crisis, inflation, commodity prices, etc.) is weighing on companies already weakened by the health crisis and which have taken out EMPs. Increasing costs to professionals are impacting their cash flow and leading to a deterioration in risk profiles. We see both a degradation of risk classes - corresponding to a renormalization effect in relation to the COVID period in which counterparties had received government aid - and a revival of defaults, in particular on PRO clients with a PGE.

The private market is more resilient, especially in the real estate portfolio. Nevertheless, a rise in risk was observed on consumer credit over the year-end, but it did not reach pre-crisis levels. Indeed, this rise follows a year in 2021, when indicators reached record-low levels.

It should be noted that new internal models, the development of which is finalised or planned, will make it possible to comply with the latest regulatory requirements.

Quantitative information on internal rating models

TABLE 42: INTERNAL APPROACH – BACKTESTING OF PD PER EXPOSURE CLASS (FIXED PD SCALE) (CR9) – AIRB

 

 

31.12.2022

Number of obligors

at the end of the year

Observed

average default

rate (%)

 31.12.2022

Exposures

weighted

average PD (%)

31.12.2021

Average PD (%)

Average

historical

annual default

rate (%) 

Exposure class

PD scale

 

of which number

of obligors

which defaulted

during the year

Central governments and central banks

0.00 to < 0.15

329

-

-

0.01%

0.02%

0.05%

0.00 to < 0.10

322

-

-

0.01%

0.02%

0.04%

0.10 to < 0.15

7

-

-

0.15%

0.13%

0.54%

0.15 to < 0.25

-

-

-

-

-

-

0.25 to < 0.50

8

-

-

0.26%

0.26%

0.16%

0.50 to < 0.75

9

-

-

0.51%

0.50%

-

0.75 to < 2.50

9

-

-

1.59%

1.67%

0.31%

0.75 to < 1.75

4

-

-

1.10%

1.10%

0.63%

1.75 to < 2.50

5

-

-

2.12%

2.12%

-

2.50 to < 10.00

49

3

6.12%

5.03%

4.69%

0.69%

2.50 to < 5.00

37

-

-

4.11%

3.67%

0.41%

5.00 to < 10.00

12

3

25.00%

7.76%

7.76%

1.38%

10.00 to < 100.00

17

-

-

15.27%

14.08%

3.07%

10.00 to < 20.00

15

-

-

11.05%

12.78%

1.06%

20.00 to < 30.00

2

-

-

20.46%

23.84%

12.66%

30.00 to < 100.00

-

-

-

-

-

-

 

100.00 (default)

8

8

-

100.00%

100.00%

-

Institutions

0.00 to < 0.15

2,430

-

-

0.03%

0.05%

0.18%

0.00 to < 0.10

2,039

-

-

0.03%

0.04%

0.18%

0.10 to < 0.15

391

-

-

0.13%

0.13%

0.25%

0.15 to < 0.25

-

-

-

-

-

-

0.25 to < 0.50

371

1

0.27%

0.26%

0.26%

0.08%

0.50 to < 0.75

163

-

-

0.50%

0.50%

0.24%

0.75 to < 2.50

103

5

4.85%

1.56%

1.57%

0.57%

0.75 to < 1.75

57

3

5.26%

1.10%

1.10%

0.55%

1.75 to < 2.50

46

2

4.35%

1.96%

2.12%

0.63%

2.50 to < 10.00

291

2

0.69%

4.97%

3.90%

0.80%

2.50 to < 5.00

259

1

0.39%

4.24%

3.43%

0.64%

5.00 to < 10.00

32

1

3.12%

7.76%

7.76%

1.30%

10.00 to < 100.00

69

-

-

15.01%

16.87%

4.08%

10.00 to < 20.00

41

-

-

12.03%

12.77%

1.91%

20.00 to < 30.00

28

-

-

22.51%

22.87%

9.61%

30.00 to < 100.00

-

-

-

-

-

-

100.00 (default)

13

13

-

100.00%

100.00%

-

Corporate – SME

0.00 to < 0.15

3,137

2

0.06%

0.14%

0.11%

0.31%

0.00 to < 0.10

883

-

-

0.08%

0.06%

0.29%

0.10 to < 0.15

2,254

2

0.09%

0.16%

0.13%

0.30%

0.15 to < 0.25

2,555

3

0.12%

0.16%

0.18%

0.30%

0.25 to < 0.50

5,994

12

0.20%

0.37%

0.30%

0.45%

0.50 to < 0.75

6,185

16

0.26%

0.68%

0.54%

0.67%

0.75 to < 2.50

15,214

76

0.50%

1.95%

1.53%

1.53%

0.75 to < 1.75

9,507

48

0.50%

1.26%

1.17%

1.18%

1.75 to < 2.50

5,707

28

0.49%

2.58%

2.12%

1.91%

2.50 to < 10.00

20,708

403

1.95%

5.10%

4.62%

4.18%

2.50 to < 5.00

15,167

246

1.62%

4.28%

3.62%

3.49%

5.00 to < 10.00

5,541

157

2.83%

8.36%

7.37%

6.39%

10.00 to < 100.00

7,211

654

9.07%

18.70%

17.58%

14.78%

10.00 to < 20.00

4,609

310

6.73%

13.60%

13.08%

11.76%

20.00 to < 30.00

2,176

255

11.72%

25.37%

24.54%

19.71%

30.00 to < 100.00

426

89

20.89%

35.64%

33.00%

24.53%

100.00 (default)

5,263

5,263

-

100.00%

100.00%

-

Corporate – Specialised lending

0.00 to < 0.15

194

-

-

0.10%

0.08%

0.29%

0.00 to < 0.10

118

-

-

0.07%

0.04%

0.25%

0.10 to < 0.15

76

-

-

0.14%

0.13%

0.41%

0.15 to < 0.25

-

-

-

-

-

-

0.25 to < 0.50

158

-

-

0.27%

0.27%

0.24%

0.50 to < 0.75

356

-

-

0.58%

0.53%

0.45%

0.75 to < 2.50

911

24

2.63%

1.69%

1.66%

0.99%

0.75 to < 1.75

438

20

4.57%

1.27%

1.13%

0.70%

1.75 to < 2.50

473

4

0.85%

2.32%

2.15%

1.30%

2.50 to < 10.00

675

8

1.19%

4.33%

4.36%

2.64%

2.50 to < 5.00

566

7

1.24%

4.05%

3.75%

1.93%

5.00 to < 10.00

109

1

0.92%

6.81%

7.52%

5.25%

10.00 to < 100.00

113

7

6.19%

15.45%

16.50%

11.20%

10.00 to < 20.00

73

3

4.11%

14.03%

12.25%

9.01%

20.00 to < 30.00

40

4

10.00%

22.20%

24.25%

18.37%

30.00 to < 100.00

-

-

-

36.21%

-

-

100.00 (default)

85

85

-

100.00%

100.00%

-

Corporate – Other

0.00 to < 0.15

3,362

1

0.03%

0.08%

0.08%

0.15%

0.00 to < 0.10

1,909

-

-

0.05%

0.04%

0.14%

0.10 to < 0.15

1,453

1

0.07%

0.14%

0.13%

0.15%

0.15 to < 0.25

88

-

-

0.16%

0.16%

-

0.25 to < 0.50

1,650

4

0.24%

0.28%

0.26%

0.24%

0.50 to < 0.75

2,584

5

0.19%

0.55%

0.52%

0.41%

0.75 to < 2.50

5,570

38

0.68%

1.67%

1.56%

1.14%

0.75 to < 1.75

3,175

27

0.85%

1.18%

1.14%

0.87%

1.75 to < 2.50

2,395

11

0.46%

2.19%

2.13%

1.44%

2.50 to < 10.00

9,351

121

1.29%

4.57%

4.42%

3.02%

2.50 to < 5.00

7,415

83

1.12%

3.84%

3.63%

2.68%

5.00 to < 10.00

1,936

38

1.96%

7.86%

7.51%

4.32%

10.00 to < 100.00

2,714

153

5.64%

14.75%

16.72%

10.54%

10.00 to < 20.00

1,771

74

4.18%

12.35%

12.70%

8.46%

20.00 to < 30.00

891

62

6.96%

22.39%

24.17%

14.97%

30.00 to < 100.00

52

17

32.69%

34.51%

33.42%

3.38%

100.00 (default)

1,371

1,371

-

100.00%

100.00%

-

Retail – Secured by real estate SME

0.00 to < 0.15

130

1

0.77%

0.08%

0.04%

0.44%

0.00 to < 0.10

130

1

0.77%

0.05%

0.04%

0.44%

0.10 to < 0.15

-

-

-

0.10%

-

-

0.15 to < 0.25

15

-

-

0.19%

0.23%

0.21%

0.25 to < 0.50

4,495

13

0.29%

0.27%

0.27%

0.28%

0.50 to < 0.75

12,559

53

0.42%

0.62%

0.62%

0.38%

0.75 to < 2.50

10,947

106

0.97%

0.37%

1.01%

0.96%

0.75 to < 1.75

10,941

106

0.97%

0.01%

1.01%

0.93%

1.75 to < 2.50

6

-

-

2.07%

2.12%

1.77%

2.50 to < 10.00

2,568

50

1.95%

2.84%

2.88%

2.45%

2.50 to < 5.00

2,384

43

1.80%

2.56%

2.57%

2.22%

5.00 to < 10.00

184

7

3.80%

6.94%

6.90%

4.99%

10.00 to < 100.00

1,142

136

11.91%

15.30%

15.36%

14.45%

10.00 to < 20.00

1,074

135

12.57%

14.48%

14.64%

14.06%

20.00 to < 30.00

68

1

1.47%

26.52%

26.83%

18.04%

30.00 to < 100.00

-

-

-

-

-

-

100.00 (default)

964

964

-

100.00%

100.00%

-

Retail – Secured by real estate non-SME

0.00 to < 0.15

394,763

135

0.03%

0.07%

0.07%

0.07%

0.00 to < 0.10

394,763

135

0.03%

0.06%

0.07%

0.07%

0.10 to < 0.15

-

-

-

0.10%

-

-

0.15 to < 0.25

311,274

255

0.08%

0.19%

0.21%

0.12%

0.25 to < 0.50

115,771

178

0.15%

0.40%

0.41%

0.21%

0.50 to < 0.75

137,497

221

0.16%

0.56%

0.61%

0.35%

0.75 to < 2.50

140,813

686

0.49%

1.31%

1.50%

0.61%

0.75 to < 1.75

74,432

235

0.32%

0.94%

0.97%

0.50%

1.75 to < 2.50

66,381

451

0.68%

2.21%

2.07%

1.19%

2.50 to < 10.00

52,116

914

1.75%

5.03%

4.86%

2.62%

2.50 to < 5.00

31,049

378

1.22%

3.87%

3.28%

1.79%

5.00 to < 10.00

21,067

536

2.54%

8.10%

6.99%

4.54%

10.00 to < 100.00

8,469

715

8.44%

23.10%

18.77%

14.33%

10.00 to < 20.00

6,820

489

7.17%

13.63%

16.03%

12.74%

20.00 to < 30.00

1,253

121

9.66%

26.07%

23.92%

16.80%

30.00 to < 100.00

396

105

26.52%

58.96%

49.81%

37.23%

100.00 (default)

10,782

10,782

-

100.00%

100.00%

-

Retail – Qualifying revolving

0.00 to < 0.15

1,863,871

1,053

0.06%

0.07%

0.08%

0.08%

0.00 to < 0.10

1,406,176

762

0.05%

0.05%

0.07%

0.02%

0.10 to < 0.15

457,695

291

0.06%

0.11%

0.12%

0.08%

0.15 to < 0.25

38,674

68

0.18%

0.19%

0.23%

0.14%

0.25 to < 0.50

1,319,229

2,466

0.19%

0.37%

0.46%

0.39%

0.50 to < 0.75

114,190

546

0.48%

0.64%

0.62%

0.36%

0.75 to < 2.50

950,664

6,315

0.66%

1.37%

1.20%

0.86%

0.75 to < 1.75

856,855

5,237

0.61%

0.97%

1.13%

0.90%

1.75 to < 2.50

93,809

1,078

1.15%

2.33%

1.96%

0.82%

2.50 to < 10.00

976,332

31,712

3.25%

5.77%

4.39%

3.02%

2.50 to < 5.00

561,753

11,608

2.07%

4.06%

2.89%

2.18%

5.00 to < 10.00

414,579

20,104

4.85%

7.98%

6.41%

4.24%

10.00 to < 100.00

319,768

43,317

13.55%

23.10%

22.28%

15.00%

10.00 to < 20.00

216,291

24,589

11.37%

12.72%

15.49%

9.80%

20.00 to < 30.00

10,884

2,077

19.08%

26.92%

25.09%

14.96%

30.00 to < 100.00

92,593

16,651

17.98%

41.24%

37.37%

52.89%

100.00 (default)

155,144

155,144

-

100.00%

100.00%

-

Retail – Other SME

0.00 to < 0.15

357

2

0.56%

0.08%

0.06%

0.09%

0.00 to < 0.10

347

1

0.29%

0.05%

0.06%

0.07%

0.10 to < 0.15

10

1

10.00%

0.11%

0.13%

-

0.15 to < 0.25

6,337

41

0.65%

0.19%

0.21%

0.45%

0.25 to < 0.50

171,094

578

0.34%

0.38%

0.35%

0.23%

0.50 to < 0.75

38,945

552

1.42%

0.59%

0.57%

0.62%

0.75 to < 2.50

189,564

2,570

1.36%

1.51%

1.47%

1.20%

0.75 to < 1.75

149,293

1,990

1.33%

1.33%

1.24%

1.02%

1.75 to < 2.50

40,271

580

1.44%

2.28%

2.03%

1.59%

2.50 to < 10.00

105,007

4,519

4.30%

5.08%

4.94%

4.06%

2.50 to < 5.00

49,603

1,886

3.80%

3.97%

3.76%

3.56%

5.00 to < 10.00

55,404

2,633

4.75%

6.88%

6.25%

4.87%

10.00 to < 100.00

41,782

6,981

16.71%

18.81%

18.28%

13.54%

10.00 to < 20.00

29,258

3,600

12.30%

13.06%

12.40%

8.91%

20.00 to < 30.00

8,484

1,866

21.99%

25.53%

23.58%

14.69%

30.00 to < 100.00

4,040

1,515

37.50%

41.37%

40.62%

35.01%

100.00 (default)

32,663

32,663

-

100.00%

100.00%

-

Retail – Other non-SME

0.00 to < 0.15

32,474

24

0.07%

0.08%

0.09%

0.07%

0.00 to < 0.10

24,287

19

0.08%

0.05%

0.09%

0.08%

0.10 to < 0.15

8,187

5

0.06%

0.10%

0.11%

0.07%

0.15 to < 0.25

234,369

130

0.06%

0.18%

0.20%

0.16%

0.25 to < 0.50

366,399

905

0.25%

0.43%

0.35%

0.31%

0.50 to < 0.75

211,435

958

0.45%

0.73%

0.66%

0.46%

0.75 to < 2.50

505,530

3,786

0.75%

1.38%

1.46%

0.93%

0.75 to < 1.75

386,569

2,667

0.69%

1.19%

1.23%

0.78%

1.75 to < 2.50

118,961

1,119

0.94%

2.31%

2.12%

1.39%

2.50 to < 10.00

391,296

12,965

3.31%

4.42%

4.62%

3.12%

2.50 to < 5.00

258,066

5,220

2.02%

3.49%

3.35%

2.12%

5.00 to < 10.00

133,230

7,745

5.81%

6.86%

7.03%

4.68%

10.00 to < 100.00

119,429

21,980

18.40%

23.80%

27.37%

20.33%

10.00 to < 20.00

43,505

4,097

9.42%

13.30%

12.85%

9.84%

20.00 to < 30.00

29,387

5,262

17.91%

27.80%

23.77%

16.47%

30.00 to < 100.00

46,537

12,621

27.12%

43.77%

42.36%

33.37%

100.00 (default)

143,331

143,331

-

100.00%

100.00%

-

TABLE 43: INTERNAL APPROACH – BACKTESTING OF PD PER EXPOSURE CLASS (FIXED PD SCALE) (CR9) – FIRB

 

 

31.12.2022

Number of obligors

at the end of the year

Observed

average default

rate (%)

31.12.2022

Exposures

weighted

average PD (%)

31.12.2021

Average PD (%)

Average

historical

annual default

rate (%) 

Exposure class

PD scale

 

of which number

of obligors

which defaulted

during the year

Central governments and central banks

0.00 to < 0.15

10

-

-

0.01%

0.01%

-

0.00 to < 0.10

10

-

-

0.01%

0.01%

-

0.10 to < 0.15

-

-

-

-

-

-

0.15 to < 0.25

-

-

-

-

-

-

0.25 to < 0.50

-

-

-

-

-

-

0.50 to < 0.75

-

-

-

-

-

-

0.75 to < 2.50

-

-

-

-

-

-

0.75 to < 1.75

-

-

-

-

-

-

1.75 to < 2.50

-

-

-

-

-

-

2.50 to < 10.00

1

-

-

2.67%

3.26%

-

2.50 to < 5.00

1

-

-

3.26%

3.26%

-

5.00 to < 10.00

-

-

-

-

-

-

10.00 to < 100.00

-

-

-

-

-

-

10.00 to < 20.00

-

-

-

-

-

-

20.00 to < 30.00

-

-

-

-

-

-

30.00 to < 100.00

-

-

-

-

-

-

 

100.00 (default)

-

-

-

-

-

-

Institutions

0.00 to < 0.15

12

-

-

0.04%

0.06%

0.05%

0.00 to < 0.10

9

-

-

0.03%

0.03%

0.06%

0.10 to < 0.15

3

-

-

0.13%

0.13%

-

0.15 to < 0.25

-

-

-

-

-

-

0.25 to < 0.50

2

-

-

-

0.26%

-

0.50 to < 0.75

1

-

-

0.50%

0.50%

-

0.75 to < 2.50

1

-

-

1.19%

2.12%

-

0.75 to < 1.75

-

-

-

1.10%

-

-

1.75 to < 2.50

1

-

-

2.12%

2.12%

-

2.50 to < 10.00

2

-

-

3.76%

5.51%

0.79%

2.50 to < 5.00

1

-

-

3.26%

3.26%

0.97%

5.00 to < 10.00

1

-

-

7.76%

7.76%

-

10.00 to < 100.00

-

-

-

11.42%

-

5.90%

10.00 to < 20.00

-

-

-

11.42%

-

2.29%

20.00 to < 30.00

-

-

-

-

-

6.55%

30.00 to < 100.00

-

-

-

-

-

-

100.00 (default)

-

-

-

-

-

-

Corporate – SME

0.00 to < 0.15

257

-

-

0.21%

0.13%

0.27%

0.00 to < 0.10

10

-

-

0.27%

0.04%

0.12%

0.10 to < 0.15

247

-

-

0.21%

0.13%

0.35%

0.15 to < 0.25

466

-

-

0.16%

0.16%

0.01%

0.25 to < 0.50

602

3

0.50%

0.41%

0.29%

0.45%

0.50 to < 0.75

1,290

-

-

0.69%

0.56%

0.58%

0.75 to < 2.50

2,758

20

0.73%

1.86%

1.50%

1.57%

0.75 to < 1.75

1,892

11

0.58%

1.33%

1.22%

1.13%

1.75 to < 2.50

866

9

1.04%

2.60%

2.12%

2.13%

2.50 to < 10.00

5,043

104

2.06%

5.06%

4.37%

4.82%

2.50 to < 5.00

3,809

62

1.63%

4.36%

3.50%

4.07%

5.00 to < 10.00

1,234

42

3.40%

8.42%

7.11%

7.50%

10.00 to < 100.00

1,555

150

9.65%

17.87%

17.62%

15.63%

10.00 to < 20.00

1,032

80

7.75%

13.86%

13.20%

11.73%

20.00 to < 30.00

410

45

10.98%

24.81%

24.52%

21.68%

30.00 to < 100.00

113

25

22.12%

35.91%

33.35%

3.37%

100.00 (default)

872

872

-

100.00%

100.00%

-

Corporate – Other

0.00 to < 0.15

534

-

-

0.06%

0.09%

0.09%

0.00 to < 0.10

286

-

-

0.05%

0.05%

0.07%

0.10 to < 0.15

248

-

-

0.13%

0.13%

0.11%

0.15 to < 0.25

36

-

-

0.16%

0.16%

-

0.25 to < 0.50

345

3

0.87%

0.26%

0.27%

0.25%

0.50 to < 0.75

549

-

-

0.52%

0.53%

0.34%

0.75 to < 2.50

1,304

16

1.23%

1.37%

1.54%

1.01%

0.75 to < 1.75

798

11

1.38%

0.84%

1.17%

0.73%

1.75 to < 2.50

506

5

0.99%

2.21%

2.12%

1.37%

2.50 to < 10.00

2,762

46

1.67%

4.18%

4.24%

3.37%

2.50 to < 5.00

2,245

33

1.47%

3.75%

3.54%

2.89%

5.00 to < 10.00

517

13

2.51%

7.77%

7.36%

5.36%

10.00 to < 100.00

729

43

5.90%

15.60%

17.05%

11.57%

10.00 to < 20.00

490

28

5.71%

12.40%

12.77%

8.94%

20.00 to < 30.00

217

12

5.53%

24.95%

25.08%

15.46%

30.00 to < 100.00

22

3

13.64%

35.20%

33.69%

3.84%

100.00 (default)

256

256

-

100.00%

100.00%

-

TABLE 44: INTERNAL APPROACH – BACKTESTING OF PD PER EXPOSURE CLASS (ONLY FOR PD ESTIMATES ACCORDING TO POINT (F) OF ARTICLE 180(1) CRR) (CR9.1) – AIRB

 

 

31.12.2022

External rating

equivalent (S&P)

Number of obligors

at the end of the year

Observed

average default

rate

(%)

31.12.2021

Average PD

 (%)

Average

historical

annual default

rate (%)

Exposure class

PD range

 

of which number

of obligors which

defaulted during

the year

Central governments and central banks

0.000 to < 0.011

AAA

29

-

-

0.01%

0.05%

0.011 to < 0.017

AA+

230

-

-

0.01%

-

0.017 to < 0.023

AA

40

-

-

0.02%

-

0.023 to < 0.029

AA-

12

-

-

0.03%

-

0.029 to < 0.034

A+

9

-

-

0.03%

-

0.034 to < 0.047

A

4

-

-

0.04%

-

0.047 to < 0.089

A-

3

-

-

0.06%

-

0.089 to < 0.183

BBB+

7

-

-

0.13%

0.54%

0.183 to < 0.359

BBB

8

-

-

0.26%

-

0.359 to < 0.743

BBB-

9

-

-

0.50%

-

0.743 to < 1.529

BB+

4

-

-

1.10%

0.63%

1.529 to < 2.632

BB

5

-

-

2.12%

-

2.632 to < 3.877

BB-

26

-

-

3.26%

0.64%

3.877 to < 5.983

B+

11

-

-

4.61%

-

5.983 to < 9.414

B

12

3

25.00%

7.76%

1.15%

9.414 to < 12.792

B-

8

-

-

11.42%

0.35%

12.792 to < 17.113

CCC+

7

-

-

14.33%

3.32%

17.113 to < 23.6

CCC

1

-

-

20.44%

10.71%

23.60 to < 100.00

C / CC / CCC-

1

-

-

27.25%

10.64%

 

100.00 (default)

D / SD

8

8

-

100.00%

-

Institutions

0.000 to < 0.011

AAA

-

-

-

-

0

0.011 to < 0.017

AA+

-

-

-

-

-

0.017 to < 0.023

AA

-

-

-

-

-

0.023 to < 0.029

AA-

-

-

-

-

-

0.029 to < 0.034

A+

1,386

-

-

0.03%

0.15%

0.034 to < 0.047

A

285

-

-

0.04%

0.39%

0.047 to < 0.089

A-

376

-

-

0.06%

0.19%

0.089 to < 0.183

BBB+

391

-

-

0.13%

-

0.183 to < 0.359

BBB

371

1

0.27%

0.26%

0.08%

0.359 to < 0.743

BBB-

163

-

-

0.50%

0.25%

0.743 to < 1.529

BB+

57

3

5.26%

1.10%

0.57%

1.529 to < 2.632

BB

46

2

4.35%

2.12%

0.41%

2.632 to < 3.877

BB-

226

1

0.44%

3.26%

0.64%

3.877 to < 5.983

B+

34

-

-

4.61%

0.96%

5.983 to < 9.414

B

32

1

3.12%

7.76%

1.35%

9.414 to < 12.792

B-

22

-

-

11.42%

2.16%

12.792 to < 17.113

CCC+

19

-

-

14.33%

1.42%

17.113 to < 23.6

CCC

18

-

-

20.44%

6.15%

23.60 to < 100.00

C / CC / CCC-

10

-

-

27.25%

14.27%

100.00 (default)

D / SD

13

13

-

100.00%

-

Corporate – SME

0.000 to < 0.011

AAA

1

-

-

-

-

0.011 to < 0.017

AA+

-

-

-

-

-

0.017 to < 0.023

AA

-

-

-

-

-

0.023 to < 0.029

AA-

-

-

-

-

-

0.029 to < 0.034

A+

40

-

-

0.03%

0.16%

0.034 to < 0.047

A

11

-

-

0.04%

0.89%

0.047 to < 0.089

A-

828

-

-

0.06%

0.13%

0.089 to < 0.183

BBB+

3,513

2

0.06%

0.14%

0.30%

0.183 to < 0.359

BBB

3,771

5

0.13%

0.27%

0.45%

0.359 to < 0.743

BBB-

5,953

14

0.24%

0.54%

0.68%

0.743 to < 1.529

BB+

8,570

32

0.37%

1.17%

1.17%

1.529 to < 2.632

BB

7,176

44

0.61%

2.21%

0.48%

2.632 to < 3.877

BB-

7,755

117

1.51%

3.23%

2.96%

3.877 to < 5.983

B+

7,254

156

2.15%

4.60%

4.49%

5.983 to < 9.414

B

4,229

114

2.70%

7.93%

6.40%

9.414 to < 12.792

B-

2,321

99

4.27%

11.29%

11.26%

12.792 to < 17.113

CCC+

1,813

148

8.16%

14.13%

13.08%

17.113 to < 23.6

CCC

1,221

140

11.47%

19.14%

16.84%

23.60 to < 100.00

C / CC / CCC-

1,887

268

14.20%

28.15%

22.88%

100.00 (default)

D / SD

5,197

5,197

-

100.00%

-

Corporate – Specialised lending

0.000 to < 0.011

AAA

1

-

-

-

0

0.011 to < 0.017

AA+

-

-

-

-

-

0.017 to < 0.023

AA

-

-

-

-

-

0.023 to < 0.029

AA-

-

-

-

-

-

0.029 to < 0.034

A+

41

-

-

0.03%

0.56%

0.034 to < 0.047

A

35

-

-

0.04%

0.12%

0.047 to < 0.089

A-

41

-

-

0.06%

-

0.089 to < 0.183

BBB+

76

-

-

0.13%

0.44%

0.183 to < 0.359

BBB

158

-

-

0.27%

0.26%

0.359 to < 0.743

BBB-

356

-

-

0.53%

0.44%

0.743 to < 1.529

BB+

438

20

4.57%

1.13%

0.74%

1.529 to < 2.632

BB

473

4

0.85%

2.15%

0.18%

2.632 to < 3.877

BB-

371

5

1.35%

3.29%

1.53%

3.877 to < 5.983

B+

208

3

1.44%

4.64%

2.75%

5.983 to < 9.414

B

96

-

-

7.85%

5.31%

9.414 to < 12.792

B-

54

2

3.70%

11.50%

7.19%

12.792 to < 17.113

CCC+

19

1

5.26%

14.37%

17.55%

17.113 to < 23.6

CCC

20

2

10.00%

20.85%

19.16%

23.60 to < 100.00

C / CC / CCC-

20

2

10.00%

27.66%

21.50%

100.00 (default)

D / SD

85

85

-

100.00%

-

Corporate – Other

0.000 to < 0.011

AAA

-

-

-

-

0

0.011 to < 0.017

AA+

-

-

-

-

-

0.017 to < 0.023

AA

-

-

-

-

-

0.023 to < 0.029

AA-

-

-

-

-

-

0.029 to < 0.034

A+

823

-

-

0.03%

0.10%

0.034 to < 0.047

A

285

-

-

0.04%

0.13%

0.047 to < 0.089

A-

805

-

-

0.06%

0.14%

0.089 to < 0.183

BBB+

1,537

1

0.07%

0.13%

0.16%

0.183 to < 0.359

BBB

1,650

4

0.24%

0.26%

0.23%

0.359 to < 0.743

BBB-

2,584

5

0.19%

0.52%

0.41%

0.743 to < 1.529

BB+

3,175

27

0.85%

1.14%

0.87%

1.529 to < 2.632

BB

2,645

12

0.45%

2.17%

0.32%

2.632 to < 3.877

BB-

4,771

50

1.05%

3.24%

2.25%

3.877 to < 5.983

B+

2,628

34

1.29%

4.56%

3.46%

5.983 to < 9.414

B

1,740

36

2.07%

7.74%

4.30%

9.414 to < 12.792

B-

1,029

24

2.33%

11.25%

8.70%

12.792 to < 17.113

CCC+

659

35

5.31%

14.28%

8.89%

17.113 to < 23.6

CCC

466

46

9.87%

19.87%

15.64%

23.60 to < 100.00

C / CC / CCC-

568

47

8.27%

27.68%

15.11%

100.00 (default)

D / SD

1,371

1,371

-

100.00%

-

TABLE 45: INTERNAL APPROACH – BACKTESTING OF PD PER EXPOSURE CLASS (ONLY FOR PD ESTIMATES ACCORDING TO POINT (F) OF ARTICLE 180(1) CRR) (CR9.1) – FIRB

 

 

31.12.2022

External rating

equivalent (S&P)

Number of obligors

at the end of the year

Observed

average default

rate

(%)

31.12.2021

Average PD

 (%)

Average

historical

annual default

rate

(%)

Exposure class

PD range

 

of which number

of obligors which

defaulted during

the year

Central governments and central banks

0.000 to < 0.011

AAA

-

-

-

-

-

0.011 to < 0.017

AA+

9

-

-

0.01%

-

0.017 to < 0.023

AA

1

-

-

0.02%

-

0.023 to < 0.029

AA-

-

-

-

-

-

0.029 to < 0.034

A+

-

-

-

-

-

0.034 to < 0.047

A

-

-

-

-

-

0.047 to < 0.089

A-

-

-

-

-

-

0.089 to < 0.183

BBB+

-

-

-

-

-

0.183 to < 0.359

BBB

-

-

-

-

-

0.359 to < 0.743

BBB-

-

-

-

-

-

0.743 to < 1.529

BB+

-

-

-

-

-

1.529 to < 2.632

BB

-

-

-

-

-

2.632 to < 3.877

BB-

1

-

-

3.26%

-

3.877 to < 5.983

B+

-

-

-

-

-

5.983 to < 9.414

B

-

-

-

-

-

9.414 to < 12.792

B-

-

-

-

-

-

12.792 to < 17.113

CCC+

-

-

-

-

-

17.113 to < 23.6

CCC

-

-

-

-

-

23.60 to < 100.00

C / CC / CCC-

-

-

-

-

-

 

100.00 (default)

D / SD

-

-

-

-

-

Institutions

0.000 to < 0.011

AAA

-

-

-

-

-

0.011 to < 0.017

AA+

-

-

-

-

-

0.017 to < 0.023

AA

-

-

-

-

-

0.023 to < 0.029

AA-

-

-

-

-

-

0.029 to < 0.034

A+

8

-

-

0.03%

0.03%

0.034 to < 0.047

A

1

-

-

0.04%

0.36%

0.047 to < 0.089

A-

-

-

-

-

-

0.089 to < 0.183

BBB+

3

-

-

0.13%

-

0.183 to < 0.359

BBB

2

-

-

0.26%

-

0.359 to < 0.743

BBB-

1

-

-

0.50%

-

0.743 to < 1.529

BB+

-

-

-

-

-

1.529 to < 2.632

BB

1

-

-

2.12%

-

2.632 to < 3.877

BB-

1

-

-

3.26%

1.03%

3.877 to < 5.983

B+

-

-

-

-

0.93%

5.983 to < 9.414

B

1

-

-

7.76%

-

9.414 to < 12.792

B-

-

-

-

-

-

12.792 to < 17.113

CCC+

-

-

-

-

-

17.113 to < 23.6

CCC

-

-

-

-

-

23.60 to < 100.00

C / CC / CCC-

-

-

-

-

-

100.00 (default)

D / SD

-

-

-

-

-

Corporate – SME

0.000 to < 0.011

AAA

-

-

-

-

-

0.011 to < 0.017

AA+

-

-

-

-

-

0.017 to < 0.023

AA

-

-

-

-

-

0.023 to < 0.029

AA-

-

-

-

-

-

0.029 to < 0.034

A+

4

-

-

0.03%

0.09%

0.034 to < 0.047

A

2

-

-

0.04%

0.23%

0.047 to < 0.089

A-

4

-

-

0.06%

0.09%

0.089 to < 0.183

BBB+

700

-

-

0.15%

0.34%

0.183 to < 0.359

BBB

602

3

0.50%

0.29%

0.46%

0.359 to < 0.743

BBB-

1,290

-

-

0.56%

0.59%

0.743 to < 1.529

BB+

1,892

11

0.58%

1.22%

1.16%

1.529 to < 2.632

BB

1,325

12

0.91%

2.27%

0.63%

2.632 to < 3.877

BB-

2,069

31

1.50%

3.21%

3.55%

3.877 to < 5.983

B+

1,732

43

2.48%

4.58%

5.32%

5.983 to < 9.414

B

825

28

3.39%

7.88%

7.81%

9.414 to < 12.792

B-

486

22

4.53%

11.16%

10.91%

12.792 to < 17.113

CCC+

410

39

9.51%

14.14%

14.04%

17.113 to < 23.6

CCC

276

27

9.78%

18.89%

17.77%

23.60 to < 100.00

C / CC / CCC-

391

62

15.86%

28.42%

28.10%

100.00 (default)

D / SD

872

872

-

100.00%

-

Corporate – Other

0.000 to < 0.011

AAA

-

-

-

-

-

0.011 to < 0.017

AA+

-

-

-

-

-

0.017 to < 0.023

AA

-

-

-

-

-

0.023 to < 0.029

AA-

-

-

-

-

-

0.029 to < 0.034

A+

83

-

-

0.03%

0.02%

0.034 to < 0.047

A

71

-

-

0.04%

0.04%

0.047 to < 0.089

A-

132

-

-

0.06%

0.12%

0.089 to < 0.183

BBB+

283

-

-

0.13%

0.10%

0.183 to < 0.359

BBB

345

3

0.87%

0.27%

0.27%

0.359 to < 0.743

BBB-

549

-

-

0.53%

0.34%

0.743 to < 1.529

BB+

798

11

1.38%

1.17%

0.76%

1.529 to < 2.632

BB

612

5

0.82%

2.20%

0.36%

2.632 to < 3.877

BB-

1,490

26

1.74%

3.22%

2.58%

3.877 to < 5.983

B+

740

10

1.35%

4.52%

3.97%

5.983 to < 9.414

B

436

10

2.29%

7.70%

5.55%

9.414 to < 12.792

B-

285

10

3.51%

11.19%

8.63%

12.792 to < 17.113

CCC+

176

13

7.39%

14.28%

11.05%

17.113 to < 23.6

CCC

102

9

8.82%

19.62%

17.67%

23.60 to < 100.00

C / CC / CCC-

169

11

6.51%

27.96%

17.49%

100.00 (default)

D / SD

256

256

-

100.00%

-

TABLE 46: COMPARISON OF RISK PARAMETERS: ESTIMATED AND ACTUAL LGD AND EAD VALUES – RETAIL CLIENTS

Basel portfolio

31.12.2022

A-IRB LGD

Estimated losses

excluding margin

of prudence

Observed EAD/

A-IRB EAD

Real estate loans (excl. guaranteed exposures)

18%

12%

-

Revolving credits

49%

21%

79%

Other loans to individual customers

30%

25%

-

VSB and professionals

28%

19%

77%

Total Group retail clients

26%

19%

79%

The changes in estimated losses are explained by a change in backtesting methodology (1-time calculation).

The changes in EAD are explained by the implementation of new models.

The changes in the portfolio “Other loans to individual customers” are explained by a change in scope.

Basel portfolio

31.12.2021

A-IRB LGD

Estimated losses

excluding margin

of prudence

Observed EAD/

A-IRB EAD

Real estate loans (excl. guaranteed exposures)

18%

9%

-

Revolving credits

48%

43%

66%

Other loans to individual customers

28%

23%

-

VSB and professionals

29%

22%

72%

Total Group retail clients

26%

19%

68%

Governance of the modeling of credit risk

Credit own funds estimation models are subject to the global model risk management framework (see Chapter 4.12 “Model risk”).

The first line of defence is responsible for designing, putting into production, using and monitoring models, in compliance with model risk management governance rules throughout the model lifecycle, which include for credit risk internal models traceability of development and implementation stages and annual backtesting. Depending on the specificities of each model family, in particular depending on the regulatory environment, the second line of defence (LOD2) may decide to perform the backtesting of the model family. In such case the LOD2 is responsible for defining a dedicated standard for the model family and informing the first line of defence (starting with the model owner) of the outcome of the backtesting.

The Model Risk Department, reporting directly to the Risk Department, acts as a second line of defence for all credit risk models. Independent model review teams rely, for the conduct of their missions, on principles of control of the theoretical robustness (assessment of the quality of the design and development) of the models, the conformity of the implementation and the use, the continuous follow-up of model relevance over time. The independent review process concludes with (i) a report summarizing the scope of the review, the tests performed, the results of the review, the conclusions or recommendations and with (ii) Reviewing and Approval Committees (respectively Comité Modèles and Comité Experts in the case of credit risk models). The model control system gives rise to recurring reports to the Risk Department within the framework of various bodies and processes (Group Model Risk Management Committee, Risk Appetite Statement/Risk Appetite Framework, monitoring of recommendations, etc.) and annually to the General Management (CORISQ). The Model Risk Department reviews, amongst others, new models, backtesting results and any change to the credit own funds estimation models. In accordance with the Delegated Regulation (EU) No. 529/2014 of 20 May 2014 relating to the follow-up of internal models used for own funds computation, any model change to the Group’s credit risk measurement system is then subjected to two main types of notification to the competent supervisor, depending on the significant nature of the change laid down by this regulation itself:

significant changes which are subject to a request for approval prior to their implementation;

other changes which should be notified to the competent authorities: (i) prior to their implementation: changes, according to the criteria defined by the regulation, are notified to the Supervisor (ex-ante notification); barring a negative response, these may be implemented within a two months period; (ii) after their implementation: these changes are notified to the competent authorities after their implementation at least once a year, through a specific report (ex-post notification).

The Internal Audit Department, as a third line of defence, is responsible for periodically assessing the overall effectiveness of the model risk management framework (relevance of the model risk governance and efficiency of second line of defence activities) and performing the independent model audit.

Climate risk – Measuring sensitivity to transition risk

Transition risk’s impact on Societe Generale Corporate clients’ credit risk has been identified as one of the main climate change-related risk for the Group.

In order to measure this impact, the Group is gradually implementing a Corporate Climate Vulnerability Indicator (CCVI) which aims to reinforce the credit analysis on the most exposed counterparties.

(See section 4.13.4 “Incorporating the environment in the risk management framework” of the 2023 Universal Registration Document).

6.5 QUANTITATIVE INFORMATION

In this section, the measurement used for credit exposures is the EAD – Exposure At Default (on-and off-balance sheet). Under the Standardised Approach, the EAD is calculated net of collateral and provisions.

The grouping of business segments was reviewed in 2022 in order to comply with internal credit risk monitoring methodologies and new reporting requirements from EBA on sectors. The grouping used is based on the main economic activity of counterparties. The EAD is broken down according to the guarantor’s characteristics, after taking into account the substitution effect (unless otherwise indicated).

Sovereigns

Claims or contingent claims on sovereign governments, regional authorities, local authorities or public sector entities as well as on multilateral development banks and international organisations.

Institutions

Claims or contingent claims on regulated credit institutions, as well as on governments, local authorities or other public sector entities that do not qualify as sovereign counterparties.

Corporates

Claims or contingent claims on corporates, which include all exposures not covered in the portfolios defined above. In addition, small/medium-sized enterprises are included in this category as a sub-portfolio, and are defined as entities with total annual sales below EUR 50 million.

Retail

Claims or contingent claims on an individual or individuals, or on a small or medium-sized entity, provided in the latter case that the total amount owed to the credit institution does not exceed EUR 1 million.

Retail exposure is further broken down into residential mortgages, revolving credit and other forms of credit to individuals, the remainder relating to exposures to very small entities and self-employed.

Others

Claims relating to securitisation transactions, equity, fixed assets, accruals, contributions to the default fund of a CCP, as well as exposures secured by mortgages on immovable property under the standardised approach, and exposures in default under the standardised approach.

Credit risk exposure (including counterparty credit risk)

As at 31 December 2022, the Group’s Exposure at Default (EAD) amounted to EUR 1,119 billion.

Corporate and bank clients exposure

BREAKDOWN OF RISK BY INTERNAL RATING FOR CORPORATE CLIENTS AT 31 DECEMBER 2022 (AS % OF EAD)

BREAKDOWN OF RISK BY INTERNAL RATING FOR CORPORATE CLIENTS AT 31 DECEMBER 2021 (AS % OF EAD)

The scope includes performing loans recorded under the IRB method (excluding prudential classification criteria, by weight, of specialised financing) for the entire Corporate client portfolio, all divisions combined, and represents EAD of EUR 318 billion (out of total EAD for the Basel Corporate client portfolio of EUR 351 billion, standard method included).The breakdown by rating of the Group’s Corporate exposure demonstrates the sound quality of the portfolio. It is based on an internal counterparty rating system, presented above as its Standard & Poor’s equivalent.

At 31 december 2022, the majority of the portfolio (70% of Corporate clients) had an investment grade rating, i.e. counterparties with an S&P-equivalent internal rating higher than BBB-. Transactions with non-investment grade counterparties were very often backed by guarantees and collateral in order to mitigate the risk incurred.

BREAKDOWN OF RISK BY INTERNAL RATING FOR BANKING CLIENTS AT 31 DECEMBER 2022 (AS % OF EAD)

BREAKDOWN OF RISK BY INTERNAL RATING FOR BANKING CLIENTS AT 31 DECEMBER 2021 (AS % OF EAD)

The scope includes performing loans recorded under the IRB method for the entire Bank client portfolio, all divisions combined, and represents EAD of EUR 58 billion (out of total EAD for the Basel Bank client portfolio of EUR 95 billion, standard method included). The breakdown by rating of the Societe Generale Group’s bank counterparty exposure demonstrates the sound quality of the portfolio. It is based on an internal counterparty rating system, presented above as its Standard & Poor’s equivalent. At 31 december 2022, exposure on banking clients was concentrated in investment grade counterparties (96% of exposure).

Change in risk-weighted assets (RWA) and capital requirements for credit and counterparty credit risks

TABLE 48: CHANGE IN RISK-WEIGHTED ASSETS (RWA) BY APPROACH (CREDIT AND COUNTERPARTY CREDIT RISKS)

(In EURm)

RWA - IRB

RWA - Standard

RWA - Total

Capital

requirements -

IRB

Capital

requirements -

Standard

Capital

requirements -

total

RWA as at end of previous reporting period (31.12.2021)

192,368

109,682

302,051

15,389

8,775

24,164

Asset size

(3,165)

(1,264)

(4,429)

(253)

(101)

(354)

Asset quality

2,100

1,785

3,886

168

143

311

Model updates

7,758

-

7,758

621

-

621

Methodology and policy

(3,849)

(4,115)

(7,965)

(308)

(329)

(637)

Acquisitions and disposals

1,238

(7,253)

(6,015)

99

(580)

(481)

Foreign exchange movements

2,122

476

2,598

170

38

208

Other

 

 

-

-

-

-

RWA as at end of reporting period (31.12.2022)

198,572

99,311

297,883

15,886

7,945

23,831

The table above presents the data without CVA (Credit Valuation Adjustment).

The main effects explaining the EUR 4 billion decrease in RWA (excluding CVA) in 2022 are as follows:

an acquisitions and disposals effect of EUR -6.0 billion mainly related to the disposal of the ROSBANK entity;

a methodological effect of EUR -8.0 billion mainly on :

-

Counterparty risk mainly related to efforts to improve the efficiency of CCR EAD calculations and the agreement of the authorities for the recognition and application of a netting on Chinese counterparties,

-

Credit risk mainly on the off-balance sheet due to the inclusion of cash flows in the calculation of the financial maturity;

a model effect of EUR +7.8 billion euros linked to the remediation of models following the TRIM review and the entry into effect of IRB Repair;

a foreign exchange effect of EUR +2.6 billion euros mainly linked to the appreciation of the US dollar against the euro.

The effects are defined as follows:

asset size: organic changes in book size and composition (including the creation of new business lines and maturing loans) but excluding changes due to acquisitions and disposals of entities;

asset quality: changes in the quality of the Bank’s assets due to changes in borrower risk, such as rating grade migration or similar effects;

model updates: changes due to model implementation, changes in model scope or any changes intended to address model weaknesses;

methodology and policy: changes due to methodological changes in calculations driven by regulatory changes, including both revisions to existing regulations and new regulations;

acquisitions and disposals: changes in book size due to acquisitions and disposals of entities;

foreign exchange movements: changes arising from market fluctuations, such as foreign currency translation movements;

other: this category is used to capture changes that cannot be attributed to any other categories.

Net cost of risk

CHANGE IN GROUP NET COST OF RISK (IN EURM)

The Group’s net cost of risk in 2022 was EUR -1 647 million, up by 135% compared to 2021. This higher cost of risk compared to a low 2021 reference base is explained by a cost of risk which remains low on defaulted outstandings (stage 3), 17 bp compared to 18 bp in 2021, and provisions on sound outstandings (stage 1/stage 2) in order to maintain a prudent provisioning policy in an environment marked by economic prospects less favorable and in particular the rise in inflation and interest rates.

The cost of risk (expressed in basis points on the average of outstandings at the beginning of the period for the four quarters preceding the closing, including operating leases) thus stands at 28 basis points for the year 2022 compared to 13 basis points in 2021.

In French Retail Banking, the cost of risk is up to 20 basis points in 2022 compared to 5 basis points in 2021. This NCR includes an allocation of 4 bps on sound outstandings (compared to the stage 1/stage 2 recovery of -7bp in 2021).

At 52 basis points in 2022 (compared to 38 basis points in 2021), the cost of risk of the International Retail Banking and Financial Services division increased despite a lower NCR on defaulted outstandings (internship 3) due to an allocation of 15 base points on stage 1/stage 2.

The cost of risk for Global Banking and Investor Solutions posted a level of 23 basis points (compared to 4 basis points in 2021), reflecting a sharp rise in the cost of risk on performing loans (stage 1/ stage 2) at 20 bp, while the NCR on defaulted outstandings remains very moderate (4 bp against 7 bp in 2021).

NON-PERFORMING LOANS (NPL)

Non-performing loans (NPL)

The following tables have been prepared in accordance with the technical instructions of the European Banking Authority (EBA) regarding the disclosure of non-performing and renegotiated exposures (EBA/ITS/2020/04).

They present the credit quality of restructured exposures and of performing and non-performing exposures, by geographical area and industry sector, with provisions and associated collateral, as well as details of the change over the period of outstanding loans and non-performing advances.

For information purposes, and in accordance with the ECB’s recommendations, the concepts of Basel default, impaired assets and non-performing exposures are aligned within the Group.

The non-performing loans ratio at the end of December 2022 was 2.8%.

This ratio is calculated in accordance with the instructions relating to the requirements of prudential disclosures published by the EBA.

Restructured debt

For the Societe Generale group, “restructured” debt refers to loans with amounts, terms or financial conditions contractually modified due to the borrower’s financial difficulties (whether these financial difficulties have already occurred or will definitely occur unless the debt is restructured). Societe Generale aligns its definition of restructured loans with the EBA one.

Restructured debt does not include commercial renegotiations involving customers for whom the Bank has agreed to renegotiate the debt in order to maintain or develop a business relationship, in accordance with credit approval rules and without any financial difficulties.

Any situation leading to a credit restructuring and involving a loss of value greater than 1% of the original debt or in which the customer’s ability to repay the debt according to the new schedule appears compromised must result in the classification of the customer concerned in default. Basel and the classification of outstandings as impaired, in accordance with the EBA directives on the application of the definition of default according to Article 178 of European Regulation No. 575/2013. In this case, customers are kept in default as long as the Bank is uncertain about their ability to honor their future commitments and at least for one year from the date of the restructuring. In other cases, an analysis of the customer’s situation makes it possible to estimate his ability to repay according to the new schedule. If this ability is proved, the client can be remained in performing loans. Otherwise, the customer is also transferred to Basel default.

The total balance sheet amount of restructured debt at 31 December 2022 mainly corresponds to loans and receivables at amortised cost for an amount of EUR 6.9 billion.

TABLE 49: PERFORMING AND NON-PERFORMING EXPOSURES AND RELATED PROVISIONS (CR1)

(In EURm)

31.12.2022

Gross carrying amount/nominal amount

Accumulated impairment, accumulated negative changes

in fair value due to credit risk and provisions

Accu-

mulated

write-off

Collateral and

financial guarantees

received

Performing

exposures

Non-performing

exposures

Performing exposures –

accumulated impairment

and provisions

Non-performing exposures –

accumulated impairment,

accumulated negative changes

in fair value due to credit risk

and provisions

On perfor-

ming

exposures

On non

perfor-

ming

exposures

Total

of which

stage

1(1)

of which

stage

2(2)

Total

of which

stage

2(2)

of which

stage

3(3)

Total

of which

stage

1(1)

of which

stage

2(2)

Total

of which

stage

2(2)

of which

stage

3(3)

Cash balances at central banks and other demand deposits

237,810

237,734

77

-

-

-

-

-

-

-

-

-

-

-

-

Loans and advances

554,357

494,175

43,563

15,938

-

15,926

(3,168)

(1,036)

(2,131)

(7,689)

-

(7,684)

(143)

299,788

5,042

Central banks

8,151

8,150

-

13

-

13

-

-

-

(13)

-

(13)

-

65

-

General governments

26,309

19,218

317

158

-

158

(10)

(7)

(2)

(71)

-

(71)

-

6,736

47

Credit institutions

19,744

19,357

375

21

-

21

(5)

(5)

(1)

(8)

-

(8)

-

2,863

13

Other financial corporations

44,137

41,448

79

147

-

147

(10)

(6)

(4)

(128)

-

(128)

-

9,790

18

Non-financial corporations

255,467

226,012

22,720

10,193

-

10,183

(2,080)

(642)

(1,438)

(4,724)

-

(4,719)

(143)

126,158

3,595

of which SMEs

60,992

51,426

8,431

4,912

-

4,912

(658)

(244)

(414)

(2,552)

-

(2,552)

-

40,653

1,688

Households

200,549

179,989

20,072

5,405

-

5,404

(1,063)

(376)

(687)

(2,744)

-

(2,744)

-

154,175

1,370

Debt securities

58,791

58,338

146

216

-

216

(11)

(7)

(4)

(61)

-

(61)

 

8,444

-

Central banks

3,234

3,234

-

-

-

-

-

-

-

-

-

-

 

-

-

General governments

41,691

41,506

73

74

-

74

(8)

(5)

(3)

(7)

-

(7)

 

-

-

Credit institutions

3,965

3,893

72

-

-

-

-

-

-

-

-

-

 

141

-

Other financial corporations

3,921

3,740

1

6

-

6

(2)

-

(1)

(6)

-

(6)

 

2,669

-

Non-financial corporations

5,981

5,966

-

137

-

137

(1)

(1)

-

(49)

-

(49)

 

5,634

-

Off-balance- sheet exposures

455,724

441,382

14,342

972

-

972

(590)

(223)

(367)

(308)

-

(308)

 

75,011

211

Central banks

323

323

-

-

-

-

-

-

-

-

-

-

 

3

-

General governments

17,721

17,698

24

-

-

-

(1)

(1)

-

-

-

-

 

4,342

-

Credit institutions

124,143

123,775

368

113

-

113

(1)

(1)

-

(3)

-

(3)

 

830

19

Other financial corporations

84,648

84,076

572

5

-

5

(18)

(7)

(11)

(6)

-

(6)

 

11,043

-

Non-financial corporations

213,924

202,440

11,484

810

-

810

(510)

(189)

(321)

(282)

-

(282)

 

54,853

187

Households

14,964

13,070

1,894

44

-

44

(60)

(26)

(35)

(19)

-

(19)

 

3,940

5

TOTAL

1,306,681

1,231,629

58,127

17,126

-

17,114

(3,768)

(1,266)

(2,502)

(8,058)

-

(8,053)

(143)

383,243

5,253

(1)

Assets without significant increase in credit risk since initial recognition.

(2)

Assets with significant increase in credit risk since initial recognition, but not impaired..

(3)

Impaired assets.

(In EURm)

31.12.2021

Gross carrying amount/nominal amount

Accumulated impairment, accumulated negative changes

in fair value due to credit risk and provisions

Accu-

mulated

write-off

Collateral and

financial guarantees

received

Performing

exposures

Non-performing

exposures

Performing exposures –

accumulated impairment

and provisions

Non-performing exposures –

accumulated impairment,

accumulated negative changes

in fair value due to credit risk

and provisions

On perfor-

ming

exposures

On non

perfor-

ming

exposures

Total

of which

stage

1(1)

of which

stage

2(2)

Total

of which

stage

2(2)

of which

stage

3(3)

Total

of which

stage

1(1)

of which

stage

2(2)

Total

of which

stage

2(2)

of which

stage

3(3)

Cash balances at central banks and other demand deposits

204,473

204,453

20

-

-

-

-

-

-

-

-

-

-

9

-

Loans and advances

543,930

479,941

43,471

16,491

-

16,485

(2,815)

(1,143)

(1,672)

(8,382)

-

(8,382)

(1,592)

292,794

4,944

Central banks

8,050

8,050

-

13

-

13

(0)

(0)

-

(13)

-

(13)

-

-

-

General governments

27,619

18,325

606

115

-

115

(15)

(6)

(9)

(58)

-

(58)

(0)

5,859

40

Credit institutions

14,681

14,336

301

22

-

22

(5)

(4)

(1)

(7)

-

(7)

(0)

2,252

15

Other financial corporations

44,887

42,388

223

131

-

131

(15)

(11)

(5)

(124)

-

(124)

-

9,179

8

Non-financial corporations

224,118

195,068

20,202

8,635

-

8,628

(1,526)

(546)

(980)

(4,124)

-

(4,124)

(737)

107,930

3,094

of which SMEs

47,592

39,458

6,612

3,778

-

3,772

(597)

(180)

(417)

(2,024)

-

(2,024)

-

29,955

1,321

Households

224,575

201,774

22,139

7,574

-

7,574

(1,253)

(575)

(677)

(4,055)

-

(4,055)

(855)

167,574

1,787

Debt securities

62,609

62,163

248

107

-

107

(9)

(7)

(2)

(56)

-

(56)

-

6,654

-

Central banks

2,955

2,955

-

-

-

-

(0)

(0)

-

-

-

-

-

-

-

General governments

44,001

43,895

102

8

-

8

(6)

(5)

(1)

(6)

-

(6)

-

-

-

Credit institutions

5,100

5,052

48

-

-

-

(1)

(1)

(0)

-

-

-

-

118

-

Other financial corporations

4,789

4,513

98

-

-

-

(1)

(0)

(1)

-

-

-

-

1,922

-

Non-financial corporations

5,763

5,748

-

99

-

99

(1)

(1)

-

(50)

-

(50)

-

4,613

-

Off-balance- sheet exposures

382,724

370,571

12,153

1,001

-

1,001

(530)

(217)

(313)

(358)

-

(358)

-

65,756

219

Central banks

241

241

-

-

-

-

(0)

(0)

-

-

-

-

 

43

-

General governments

6,275

6,153

122

0

-

0

(3)

(1)

(1)

-

-

-

 

3,690

0

Credit institutions

98,433

98,073

360

-

-

-

(22)

(2)

(21)

-

-

-

 

526

-

Other financial corporations

52,621

52,342

279

0

-

0

(5)

(4)

(1)

-

-

-

 

7,610

-

Non-financial corporations

207,858

197,127

10,731

904

-

904

(438)

(183)

(256)

(333)

-

(333)

 

47,931

205

Households

17,297

16,635

661

97

-

97

(62)

(28)

(34)

(26)

-

(26)

 

5,957

14

TOTAL

1,193,736

1,117,128

55,892

17,599

-

17,593

(3,354)

(1,367)

(1,987)

(8,796)

-

(8,796)

(1,592)

365,213

5,163

(1)

Assets without significant increase in credit risk since initial recognition.

(2)

Assets with significant increase in credit risk since initial recognition, but not impaired..

(3)

Impaired assets.

TABLE 50: CHANGES IN THE STOCK OF NON-PERFORMING LOANS AND ADVANCES (CR2)

(In EURm)

31.12.2022

Gross carrying value

defaulted exposures

Initial stock of non-performing loans and advances

16,491

Inflows to non-performing portfolios

4,652

Outflows from non-performing portfolios

(5,204)

Outflows due to write-offs

(2,665)

Outflow due to other situations

(2,539)

Final stock of non-performing loans and advances

15,938

TABLE 51: CREDIT QUALITY OF FORBORNE EXPOSURES (CQ1)

(In EURm)

31.12.2022

Gross carrying amount/nominal

amount of exposures with

forbearance measures

Accumulated impairment,

accumulated negative changes

in fair value due to credit risk

and provisions

Collateral received and financial

guarantees received on forborne

exposures

Performing

forborne

Non-performing forborne

On

performing

forborne

exposures

On

non-performing

forborne

exposures

Total

of which collateral and

financial guarantees

received on

non-performing

exposures with

forbearance measures

Total

of which

defaulted

of which

impaired

Cash balances
at central banks
and other demand deposits

-

-

-

-

-

-

-

-

Loans and advances

4,314

2,613

2,613

2,608

(101)

(942)

4,338

1,047

Central banks

-

-

-

-

-

-

-

-

General governments

1

4

4

4

-

(1)

-

-

Credit institutions

-

-

-

-

-

-

-

-

Other financial corporations

-

18

18

18

-

-

18

18

Non-financial corporations

3,524

1,587

1,587

1,582

(86)

(595)

3,544

785

Households

789

1,004

1,004

1,004

(15)

(345)

776

245

Debt Securities

-

-

-

-

-

-

-

-

Loan commitments given

465

32

32

32

(7)

(3)

356

20

TOTAL

4,779

2,645

2,645

2,640

(108)

(945)

4,694

1,068

(In EURm)

31.12.2021

Gross carrying amount/nominal

amount of exposures with

forbearance measures

Accumulated impairment,

accumulated negative changes

in fair value due to credit risk

and provisions

Collateral received and financial

guarantees received on forborne

exposures

Performing

forborne

Non-performing forborne

On

performing

forborne

exposures

On

non-performing

forborne

exposures

Total

of which collateral and

financial guarantees

received on

non-performing

exposures with

forbearance measures

Total

of which

defaulted

of which

impaired

Cash balances
at central banks
and other demand deposits

-

-

-

-

-

-

-

-

Loans and advances

4,879

3,308

3,308

3,302

(58)

(1,239)

5,020

1,372

Central banks

-

-

-

-

-

-

-

-

General governments

28

-

-

-

-

-

-

-

Credit institutions

-

-

-

-

-

-

-

-

Other financial corporations

11

0

0

0

(0)

(0)

11

-

Non-financial corporations

3,665

2,051

2,051

2,046

(58)

(701)

4,229

1,109

Households

1,175

1,256

1,256

1,256

(0)

(538)

780

263

Debt Securities

-

-

-

-

-

-

-

-

Loan commitments given

545

34

34

34

(8)

(2)

488

19

TOTAL

5,424

3,342

3,342

3,336

(66)

(1,241)

5,508

1,391

TABLE 52: CREDIT QUALITY OF PERFORMING AND NON-PERFORMING EXPOSURES BY PAST DUE DAYS (CQ3)

(In EURm)

31.12.2022

Performing exposures

Non-performing exposures

Total
performing

Not past
due or
past due
≤ 30
days

Past
due
> 30
days
≤ 90
days

Total
non
perfor-
ming

Unlikely
to pay
that are
not past
due or are
past due
≤ 90 days

Past
due
> 90
days
≤ 180
days

Past
due
> 180
days
≤ 1 year

Past
due
> 1
year
≤ 2
years

Past
due
> 2
years
≤ 5
years

Past
due
> 5
years
≤ 7
years

Past
due
> 7 years

of which
defaulted

Cash balances
at central banks and other demand deposits

237,810

237,810

-

-

-

-

-

-

-

-

-

-

Loans and advances

554,357

552,123

2,233

15,938

11,421

581

872

753

1,504

301

507

15,938

Central banks

8,151

8,151

-

13

-

-

-

-

-

-

13

13

General governments

26,309

26,286

22

158

62

20

-

1

28

1

46

158

Credit institutions

19,744

19,733

11

21

19

-

-

-

-

-

3

21

Other financial corporations

44,137

43,990

147

147

43

-

-

-

104

-

-

147

Non-financial corporations

255,467

254,510

957

10,193

7,929

235

573

354

688

138

276

10,193

of which SMEs

60,992

60,728

264

4,912

3,570

164

223

205

412

111

227

4,912

Households

200,549

199,454

1,095

5,405

3,368

327

298

398

685

161

169

5,405

Debt securities

58,791

58,791

-

216

216

-

-

-

-

-

-

216

Central banks

3,234

3,234

-

-

-

-

-

-

-

-

-

-

General governments

41,691

41,691

-

74

74

-

-

-

-

-

-

74

Credit institutions

3,965

3,965

-

-

-

-

-

-

-

-

-

-

Other financial corporations

3,921

3,921

-

6

6

-

-

-

-

-

-

6

Non-financial corporations

5,981

5,981

-

137

137

-

-

-

-

-

-

137

Off-balance-sheet exposures

455,724

-

-

972

-

-

-

-

-

-

-

972

Central banks

323

-

-

-

-

-

-

-

-

-

-

-

General governments

17,721

-

-

-

-

-

-

-

-

-

-

-

Credit institutions

124,143

-

-

113

-

-

-

-

-

-

-

113

Other financial corporations

84,648

-

-

5

-

-

-

-

-

-

-

5

Non-financial corporations

213,924

-

-

810

-

-

-

-

-

-

-

810

Households

14,964

-

-

44

-

-

-

-

-

-

-

44

TOTAL

1,306,681

848,724

2,233

17,126

11,637

581

872

753

1,504

301

507

17,126

(In EURm)

31.12.2021

Performing exposures

Non-performing exposures

Total
performing

Not past
due or
past due
≤ 30
days

Past
due
> 30
days
≤ 90
days

Total
non
perfor-
ming

Unlikely
to pay
that are
not past
due or are
past due
≤ 90 days

Past
due
> 90
days
≤ 180
days

Past
due
> 180
days
≤ 1 year

Past
due
> 1
year
≤ 2
years

Past
due
> 2
years
≤ 5
years

Past
due
> 5
years
≤ 7
years

Past
due
> 7 years

of which
defaulted

Cash balances
at central banks and other demand deposits

204,473

204,473

-

-

-

-

-

-

-

-

-

-

Loans and advances

543,930

543,055

874

16,491

12,017

477

612

1,185

1,319

316

565

16,491

Central banks

8,050

8,050

-

13

-

-

-

-

-

-

13

13

General governments

27,619

27,606

13

115

31

0

1

0

39

-

44

115

Credit institutions

14,681

14,680

0

22

19

-

-

-

-

-

3

22

Other financial corporations

44,887

44,886

0

131

32

2

0

-

98

-

-

131

Non-financial corporations

224,118

223,834

284

8,635

7,148

99

199

469

424

67

228

8,635

of which SMEs

47,592

47,490

102

3,778

2,910

69

152

204

219

52

172

3,778

Households

224,575

223,998

577

7,574

4,786

376

411

716

758

249

277

7,574

Debt securities

62,609

62,609

-

107

107

-

-

-

-

-

-

107

Central banks

2,955

2,955

-

-

-

-

-

-

-

-

-

-

General governments

44,001

44,001

-

8

8

-

-

-

-

-

-

8

Credit institutions

5,100

5,100

-

-

-

-

-

-

-

-

-

-

Other financial corporations

4,789

4,789

-

-

-

-

-

-

-

-

-

-

Non-financial corporations

5,763

5,763

-

99

99

-

-

-

-

-

-

99

Off-balance-sheet exposures

382,724

-

-

1,001

-

-

-

-

-

-

-

1,001

Central banks

241

 

 

-

 

 

 

 

 

 

 

-

General governments

6,275

 

 

0

 

 

 

 

 

 

 

0

Credit institutions

98,433

 

 

-

 

 

 

 

 

 

 

-

Other financial corporations

52,621

 

 

0

 

 

 

 

 

 

 

0

Non-financial corporations

207,858

 

 

904

 

 

 

 

 

 

 

904

Households

17,297

 

 

97

 

 

 

 

 

 

 

97

TOTAL

1,193,736

810,137

874

17,599

12,124

477

612

1,185

1,319

316

565

17,599

TABLE 53: CREDIT QUALITY OF NON-PERFORMING EXPOSURES BY GEOGRAPHY (CQ4)

(In EURm)

31.12.2022

Gross carrying/nominal amount

Accumulated

impairment

Provisions on

off-balance-sheet

commitments

and financial

guarantees

given

Accumulated

negative

changes in fair

value due to

credit risk on

non-performing

exposures

Total

nominal

of which

non-performing

of which

subject to

impairment

Total non

performing

of which

defaulted

On-balance sheet exposures

629,301

16,154

16,154

612,370

(10,928)

 

-

Europe

478,502

11,272

11,272

463,671

(7,412)

 

-

France

295,595

8,192

8,192

283,872

(4,921)

 

-

Czech Republic

45,428

712

712

45,428

(553)

 

-

Germany

22,952

499

499

22,918

(320)

 

-

Luxembourg

15,828

223

223

15,708

(186)

 

-

United Kingdom

26,679

222

222

24,543

(94)

 

-

Italy

18,630

669

669

18,630

(556)

 

-

Switzerland

5,853

48

48

5,528

(19)

 

-

Russian Federation

581

5

5

581

(36)

 

-

Romania

10,369

252

252

10,369

(380)

 

-

Spain

5,075

116

116

4,921

(96)

 

-

Other European countries:
EU and EFTA

23,484

247

247

23,145

(218)

 

-

Other European countries

8,028

88

88

8,027

(34)

 

-

North America

65,820

179

179

65,263

(180)

 

-

United States

63,134

160

160

62,577

(173)

 

-

Other North American countries

2,686

19

19

2,686

(6)

 

-

Asia-Pacific

30,922

580

580

30,286

(281)

 

-

Japan

1,889

14

14

1,889

(3)

 

-

China

7,256

97

97

7,122

(93)

 

-

Other Asia-Pacific countries

21,776

468

468

21,274

(184)

 

-

Africa and Middle East

46,773

3,805

3,805

46,772

(2,947)

 

-

Morocco

10,553

1,560

1,560

10,553

(1,083)

 

-

Other Africa and
Middle East countries

36,220

2,244

2,244

36,219

(1,864)

 

-

Latin America and Caribbean

7,285

318

318

6,378

(109)

 

-

Off-balance sheet exposures

456,696

972

972

 

 

(898)

 

Europe

321,761

685

685

 

 

(656)

 

France

194,355

438

438

 

 

(376)

 

Czech Republic

10,036

49

49

 

 

(38)

 

Germany

22,483

15

15

 

 

(34)

 

Luxembourg

10,572

2

2

 

 

(6)

 

United Kingdom

29,411

0

0

 

 

(12)

 

Italy

10,002

14

14

 

 

(21)

 

Switzerland

8,820

0

0

 

 

(1)

 

Russian Federation

291

114

114

 

 

(5)

 

Romania

2,394

34

34

 

 

(68)

 

Spain

8,876

5

5

 

 

(17)

 

Other European countries:
EU and EFTA

23,316

14

14

 

 

(74)

 

Other European countries

1,204

0

0

 

 

(1)

 

North America

84,266

8

8

 

 

(90)

 

United States

80,116

7

7

 

 

(89)

 

Other North American countries

4,150

1

1

 

 

(1)

 

Asia-Pacific

33,692

80

80

 

 

(15)

 

Japan

15,981

0

0

 

 

(1)

 

China

3,896

0

0

 

 

(1)

 

Other Asia-Pacific countries

13,815

80

80

 

 

(13)

 

Africa and Middle East

13,381

197

197

 

 

(135)

 

Morocco

2,093

105

105

 

 

(40)

 

Other Africa and
Middle East countries

11,288

92

92

 

 

(95)

 

Latin America and
the Caribbean

3,596

2

2

 

 

(3)

 

TOTAL

1,085,997

17,126

17,126

612,370

(10,928)

(898)

-

(In EURm)

31.12.2021

Gross carrying/nominal amount

Accumulated

impairment

Provisions on

off-balance-sheet

commitments

and financial

guarantees

given

Accumulated

negative

changes in fair

value due to

credit risk on

non-performing

exposures

Total

nominal

of which

non-performing

of which

subject to

impairment

Total non

performing

of which

defaulted

On-balance sheet exposures

623,135

16,596

16,596

602,583

(11,260)

 

-

Europe

490,767

11,823

11,823

471,017

(7,779)

 

-

France

305,781

7,913

7,913

287,486

(4,968)

 

-

Czech Republic

41,272

667

667

41,272

(496)

 

-

Germany

22,659

501

501

22,528

(310)

 

-

Luxembourg

12,360

425

425

12,353

(67)

 

-

United Kingdom

27,049

374

374

26,053

(163)

 

-

Italy

16,742

713

713

16,742

(571)

 

-

Switzerland

5,454

47

47

5,452

(26)

 

-

Russian Federation

15,170

332

332

15,170

(438)

 

-

Romania

10,564

295

295

10,564

(406)

 

-

Spain

4,918

175

175

4,856

(108)

 

-

Other European countries:
EU and EFTA

20,193

274

274

19,943

(179)

 

-

Other European countries

8,605

106

106

8,598

(48)

 

-

North America

58,068

164

164

58,068

(149)

 

-

United States

55,863

162

162

55,863

(146)

 

-

Other North American countries

2,206

2

2

2,205

(2)

 

-

Asia-Pacific

23,218

612

612

23,181

(384)

 

-

Japan

1,512

0

0

1,512

(1)

 

-

China

5,003

148

148

5,003

(90)

 

-

Other Asia-Pacific countries

16,703

464

464

16,666

(293)

 

-

Africa and Middle East

42,847

3,754

3,754

42,846

(2,850)

 

-

Morocco

10,684

1,647

1,647

10,684

(1,113)

 

-

Other Africa and
Middle East countries

32,164

2,107

2,107

32,163

(1,736)

 

-

Latin America and Caribbean

8,236

243

243

7,471

(98)

 

-

Off-balance sheet exposures

383,725

1,001

1,001

 

 

(888)

 

Europe

274,851

696

696

 

 

(664)

 

France

176,038

481

481

 

 

(363)

 

Czech Republic

9,447

50

50

 

 

(43)

 

Germany

14,574

5

5

 

 

(34)

 

Luxembourg

9,634

1

1

 

 

(4)

 

United Kingdom

14,329

1

1

 

 

(17)

 

Italy

7,462

12

12

 

 

(17)

 

Switzerland

8,135

1

1

 

 

(2)

 

Russian Federation

4,696

7

7

 

 

(10)

 

Romania

2,165

43

43

 

 

(64)

 

Spain

7,663

70

70

 

 

(54)

 

Other European countries:
EU and EFTA

18,935

22

22

 

 

(52)

 

Other European countries

1,774

1

1

 

 

(4)

 

North America

71,131

10

10

 

 

(72)

 

United States

68,712

10

10

 

 

(71)

 

Other North American countries

2,419

0

0

 

 

(1)

 

Asia-Pacific

22,423

48

48

 

 

(12)

 

Japan

6,725

-

-

 

 

(1)

 

China

3,382

-

-

 

 

(0)

 

Other Asia-Pacific countries

12,317

48

48

 

 

(11)

 

Africa and Middle East

11,857

247

247

 

 

(136)

 

Morocco

2,040

73

73

 

 

(42)

 

Other Africa and
Middle East countries

9,817

174

174

 

 

(93)

 

Latin America and
the Caribbean

3,463

0

0

 

 

(4)

 

TOTAL

1,006,860

17,597

17,597

602,583

(11,260)

(888)

-

TABLE 54: CREDIT QUALITY OF LOANS AND ADVANCES TO NON-FINANCIAL CORPORATIONS BY INDUSTRY (CQ5)

(In EURm)

31.12.2022

Gross carrying amount

Accumulated

impairment

Accumulated

negative

changes in fair

value due to

credit risk on

non-performing

exposures

Total

nominal

of which non-performing



of which loans

and advances

subject to

impairment

Total non

performing

of which

defaulted

Agriculture, forestry
and fishing

2,138

127

127

2,088

(114)

-

Mining and quarrying

7,871

128

128

7,862

(72)

-

Manufacturing

36,062

1,856

1,856

35,729

(1,176)

-

Electricity, gas, steam and air conditioning supply

18,075

266

266

18,043

(179)

-

Water supply

2,035

29

29

1,724

(30)

-

Construction

8,545

846

846

8,429

(574)

-

Wholesale and retail trade

33,500

1,802

1,802

32,800

(1,313)

-

Transport and storage

21,227

610

610

20,984

(381)

-

Accommodation and food service activities

5,703

854

854

5,481

(462)

-

Information and communication

10,814

109

109

10,479

(122)

-

Financial and insurance actvities

23,059

290

290

22,651

(177)

-

Real estate activities

40,317

888

888

38,502

(452)

-

Professional, scientific and technical activities

9,183

338

338

9,012

(239)

-

Administrative
and support service activities

11,715

342

342

11,643

(185)

-

Public administration
and defence, compulsory social security

2,027

4

4

1,776

(2)

-

Education

543

40

40

535

(26)

-

Human health services and social work activities

2,325

414

414

2,302

(122)

-

Arts, entertainment
and recreation

930

78

78

894

(58)

-

Other services

29,591

1,174

1,174

27,986

(1,123)

-

TOTAL

265,660

10,193

10,193

258,920

(6,804)

-

(In EURm)

31.12.2021

Gross carrying amount

Accumulated impairment

Accumulated negative changes in fair value due to credit risk on non-performing exposures

Total
nominal

of which non-performing

of which loans and advances subject to impairment

Total non performing

of which
defaulted

Agriculture, forestry and fishing

1,907

125

125

1,841

(104)

-

Mining and quarrying

9,650

201

201

9,638

(102)

-

Manufacturing

30,649

1,638

1,638

30,110

(1,073)

-

Electricity, gas, steam and air conditioning supply

16,694

80

80

16,406

(83)

-

Water supply

2,159

23

23

1,778

(28)

-

Construction

7,152

805

805

6,956

(571)

-

Wholesale and retail trade

28,738

1,817

1,817

28,138

(1,364)

-

Transport and storage

21,479

592

592

21,142

(340)

-

Accommodation and food service activities

4,070

1,143

1,143

3,902

(432)

-

Information and communication

8,824

79

79

8,346

(89)

-

Financial and insurance actvities

19,817

280

280

18,552

(221)

-

Real estate activities

31,417

491

491

29,141

(372)

-

Professional, scientific and technical activities

6,798

213

213

6,611

(196)

-

Administrative and support service activities

8,262

360

360

8,145

(156)

-

Public administration and defence, compulsory social security

1,835

6

6

1,575

(4)

-

Education

359

24

24

349

(15)

-

Human health services and social work activities

1,501

63

63

1,461

(39)

-

Arts, entertainment and recreation

967

71

71

882

(51)

-

Other services

30,476

623

623

28,926

(411)

-

TOTAL

232,753

8,635

8,635

223,899

(5,651)

-

TABLE 55: COLLATERAL OBTAINED BY TAKING POSSESSION AND EXECUTION PROCESSES (CQ7)

(In EURm)

31.12.2022

Collateral obtained by taking possession accumulated

Value at initial

recognition

Accumulated negative

changes

Property, plant and equipment (PP&E)

23

(13)

Other than PP&E

97

(40)

Residential immovable property

-

-

Commercial Immovable property

-

-

Movable property (auto, shipping, etc.)

-

-

Equity and debt instruments

-

-

Other

97

(40)

TOTAL

120

(53)

(In EURm)

31.12.2021

Collateral obtained by taking possession accumulated

Value at initial

recognition

Accumulated negative

changes

Property, plant and equipment (PP&E)

34

(14)

Other than PP&E

64

(29)

Residential immovable property

0

(0)

Commercial Immovable property

-

-

Movable property (auto, shipping, etc.)

-

-

Equity and debt instruments

-

-

Other

63

(29)

TOTAL

98

(44)

TABLE 56: MATURITY OF EXPOSURES (CR1-A)

(In EURm)

31.12.2022

Net exposure value

On demand

≤ 1 year

> 1 year

≤ 5 years

> 5 years

No stated

maturity

Total

Loans and advances

13,435

167,919

142,043

198,926

47,972

570,294

Debt securities

5

18,779

23,557

16,524

141

59,007

TOTAL

13,440

186,698

165,601

215,450

48,113

629,301

(In EURm)

31.12.2021

Net exposure value

On demand

≤ 1 year

> 1 year

≤ 5 years

> 5 years

No stated

maturity

Total

Loans and advances

14,571

144,350

157,530

187,864

56,104

560,421

Debt securities

5

20,750

24,689

17,160

112

62,716

TOTAL

14,576

165,100

182,220

205,025

56,216

623,137

TABLE 57: CREDIT RISK MITIGATION TECHNIQUES – OVERVIEW (CR3)

(In EURm)

31.12.2022

Exposures

unsecured –

Carrying amount

Exposures secured –

Carrying amount

of which secured by

collateral

of which secured by

financial guarantees

of which secured by

credit derivatives

Total loans

492,418

304,830

128,393

176,437

-

Total debt securities

50,491

8,444

8,363

81

 

TOTAL EXPOSURES

542,909

313,274

136,756

176,518

-

of which non-performing exposures

3,362

5,042

2,389

2,653

-

of which defaulted

3,362

5,042

2,389

2,653

-

The table as at 31 December 2021 has been modified as follows:

(In EURm)

31.12.2021

Exposures

unsecured –

Carrying amount

Exposures secured –

Carrying amount

of which secured by

collateral

of which secured by

financial guarantees

of which secured by

credit derivatives

Total loans

455,960

297,738

124,447

173,291

-

Total debt securities

55,998

6,654

6,561

93

 

TOTAL EXPOSURES

511,957

304,391

131,008

173,384

-

of which non-performing exposures

3,216

4,944

2,217

2,727

-

of which defaulted

3,216

4,944

2,217

2,727

-

TABLE 58: INFORMATION ON LOANS AND ADVANCES SUBJECT TO LEGISLATIVE AND NON-LEGISLATIVE MORATORIA

(In EURm)

31.12.2022

Gross carrying amount

Accumulated impairment, accumulated negative changes

in fair value due to credit risk

Gross

carrying

amount

Total

Performing

Non-performing

Total

Performing

Non-performing

Inflows to

non-

performing

exposures

Total

performing

of which

exposures

with for-

bearance

measures

of which

Instru-

ments

with

significant

increase in

credit risk

since

initial

recogni-

tion but

not credit

impaired

(Stage 2)

Total

non-

performing

of which

exposures

with for-

bearance

measures

of which

Unlikely

to pay

that are

not

past-due

or

past-due

≤ 90 days

Total

performing

of which

exposures

with for-

bearance

measures

of which

Instru-

ments

with

significant

increase in

credit risk

since

initial

recogni-

tion but

not credit

impaired

(Stage 2)

Total

non-

performing

of which

exposures

with for-

bearance

measures

of which

Unlikely

to pay

that are

not

past-due

or

past-due

≤ 90 days 

Loans and advances subject to moratorium

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

of which
Households

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

of which Collateralised
by residential immovable property

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

of which Non-financial corporations

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

of which Small and Medium-sized Enterprises

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

of which Collateralised
by commercial immovable property

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

(In EURm)

30.06.2022

Gross carrying amount

Accumulated impairment, accumulated negative changes

in fair value due to credit risk

Gross

carrying

amount

Total

Performing

Non-performing

Total

Performing

Non-performing

Inflows to

non-

performing

exposures

Total

performing

of which

exposures

with for-

bearance

measures

of which

Instru-

ments

with

significant

increase in

credit risk

since

initial

recogni-

tion but

not credit

impaired

(Stage 2)

Total

non-

performing

of which

exposures

with for-

bearance

measures

of which

Unlikely

to pay

that are

not

past-due

or

past-due

≤ 90 days 

Total

performing

of which

exposures

with for-

bearance

measures

of which

Instru-

ments

with

significant

increase in

credit risk

since

initial

recogni-

tion but

not credit

impaired

(Stage 2)

Total

non-

performing

of which

exposures

with for-

bearance

measures

of which

Unlikely

to pay

that are

not

past-due

or

past-due

≤ 90 days

Loans and advances subject to moratorium

0

0

-

0

-

-

-

(0)

(0)

-

(0)

-

-

-

-

of which
Households

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

of which Collateralised
by residential immovable property

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

of which Non-financial corporations

0

0

-

0

-

-

-

(0)

(0)

-

(0)

-

-

-

-

of which Small and Medium-sized Enterprises

0

0

-

0

-

-

-

(0)

(0)

-

(0)

-

-

-

-

of which Collateralised
by commercial immovable property

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

TABLE 59: BREAKDOWN OF LOANS AND ADVANCES SUBJECT TO LEGISLATIVE AND NON-LEGISLATIVE MORATORIA BY RESIDUAL MATURITY OF THE MORATORIA

(In EURm)

3.12.2022

Number

of obligors

Gross carrying amount

Total

of which

legislative

moratoria

of which

expired

Residual maturity of moratoria

≤ 3 months

> 3 months

≤ 6 months

> 6 months

≤ 9 months

> 9 months

≤ 12 months

> 1 year

Loans and advances
for which moratorium
was offered

419,380

19,839

 

 

 

 

 

 

 

Loans and advances subject to moratorium (granted)

394,514

18,998

2,400

18,998

-

-

-

-

-

of which
Households

 

3,792

1,164

3,792

-

-

-

-

-

of which Collateralised by residential immovable property

 

2,848

1,005

2,848

-

-

-

-

-

of which Non-financial corporations

 

15,198

1,235

15,198

-

-

-

-

-

of which Small and Medium-sized Enterprises

 

9,349

1,040

9,349

-

-

-

-

-

of which Collateralised by commercial immovable property

 

2,195

886

2,195

-

-

-

-

-

(In EURm)

30.06.2022

Number

of obligors

Gross carrying amount

Total

of which

legislative

moratoria

of which

expired

Residual maturity of moratoria

≤ 3 months

> 3 months

≤ 6 months

> 6 months

≤ 9 months

> 9 months

≤ 12 months

> 1 year

Loans and advances
for which moratorium
was offered

427,825

22,681

 

 

 

 

 

 

 

Loans and advances subject to moratorium (granted)

402,921

21,828

2,896

21,828

-

-

-

-

-

of which Households

 

4,148

1,412

4,148

-

-

-

-

-

of which Collateralised by residential immovable property

 

3,087

1,199

3,087

-

-

-

-

-

of which Non-financial corporations

 

17,667

1,483

17,667

-

-

-

-

-

of which Small and Medium-sized Enterprises

 

10,807

1,243

10,807

-

-

-

-

-

of which Collateralised by commercial immovable property

 

2,385

1,015

2,385

-

-

-

-

-

TABLE 60: INFORMATION ON NEWLY ORIGINATED LOANS AND ADVANCES PROVIDED UNDER NEWLY APPLICABLE PUBLIC GUARANTEE SCHEMES INTRODUCED IN RESPONSE TO COVID-19 CRISIS

(In EURm)

31.12.2022

Gross carrying amount

Maximum amount

of the guarantee

that can be considered

Gross carrying amount

Total

of which

forborne

Public guarantees received

Inflows to non

performing exposures

Newly originated loans and advances subject to public guarantee schemes

13,320

155

10,989

308

of which Households

3,532

 

 

5

of which Collateralised by residential immovable property

2

 

 

-

of which Non-financial corporations

9,776

155

7,448

256

of which Small and Medium-sized Enterprises

5,258

 

 

109

of which Collateralised by commercial immovable property

51

 

 

-

(In EURm)

30.06.2022

Gross carrying amount

Maximum amount

of the guarantee

that can be considered

Gross carrying amount

Total

of which

forborne

Public guarantees received

Inflows to non

performing exposures

Newly originated loans and advances subject to public guarantee schemes

15,256

111

12,633

194

of which Households

3,940

-

-

54

of which Collateralised by residential immovable property

2

 

 

-

of which Non-financial corporations

11,309

111

8,512

141

of which Small and Medium-sized Enterprises

5,858

-

-

116

of which Collateralised by commercial immovable property

61

 

 

-

6.6 ADDITIONAL QUANTITATIVE INFORMATION ON CREDIT RISK

DEFINITION OF REGULATORY METRICS

The main metrics used in the following tables are:

Exposure: defined as all assets (e.g. loans, receivables, accruals, etc.) associated with market or customer transactions, recorded on- and off-balance sheet;

EAD (Exposure At Default) is defined as the bank’s exposure (on- and off-balance sheet) in the event of a counterparty’s default. Unless otherwise specifically indicated to the contrary, the EAD is reported post-CRM (Credit Risk Mitigation), after factoring in guarantees and collateral. Under the Standardised approach, EADs are presented net of specific provisions and financial collateral;

Risk-Weighted Assets (RWA): are computed from the exposures and the associated level of risk, which depends on the debtors’ credit quality;

Expected Loss (EL): potential loss incurred, given the quality of the structuring of a transaction and any risk mitigation measures such as collateral. Under the AIRB method, the following equation summarises the relation between these variables: EL = EAD x PD x LGD (except for defaulted exposures).

BREAKDOWN OF CREDIT RISK – OVERVIEW

TABLE 61: CREDIT RISK EXPOSURE, EAD AND RWA BY EXPOSURE CLASS AND APPROACH

(In EURm)

31.12.2022

IRB approach

Standardised approach

Total

Exposure classes

Exposure

EAD

RWA

Exposure

EAD

RWA

Exposure

EAD

RWA

Sovereign

262,233

271,739

5,853

6,461

8,565

1,742

268,694

280,305

7,595

Institutions

49,646

38,845

5,038

5,465

5,352

1,689

55,111

44,197

6,727

Corporates

412,410

267,695

110,356

48,451

31,227

29,371

460,861

298,922

139,727

Retail

193,572

193,547

37,027

37,255

29,611

19,264

230,827

223,158

56,291

Others

49,119

48,858

23,456

74,492

63,360

43,090

123,611

112,218

66,546

TOTAL

966,980

820,684

181,730

172,123

138,116

95,155

1,139,103

958,800

276,885

(In EURm)

31.12.2021

IRB approach

Standardised approach

Total

Exposure classes

Exposure

EAD

RWA

Exposure

EAD

RWA

Exposure

EAD

RWA

Sovereign

244,975

265,460

6,755

8,494

10,511

1,753

253,469

275,971

8,508

Institutions

47,421

39,906

4,523

6,152

20,627

4,867

53,573

60,533

9,389

Corporates

378,223

245,456

103,947

51,311

32,935

31,516

429,534

278,392

135,463

Retail

177,329

177,250

30,629

39,624

33,015

21,510

216,954

210,266

52,139

Others

48,312

47,690

27,893

82,859

61,566

43,986

131,171

109,256

71,879

TOTAL

896,261

775,763

173,747

188,440

158,655

103,632

1,084,701

934,418

277,379

BREAKDOWN OF CREDIT RISK – DETAILS

TABLE 62: STANDARDISED APPROACH – CREDIT RISK EXPOSURE AND CREDIT RISK MITIGATION (CRM) EFFECTS (CR4)

The credit conversion factor (CCF) is the ratio between the current undrawn part of a credit line which could be drawn and would therefore be exposed in the event of default and the undrawn part of this credit line. The significance of the credit line depends on the authorised limit, unless the unauthorised limit is greater.

The concept of “credit risk mitigation” (CRM) is a technique used by an institution to reduce the credit risk associated with its exposures.

In accordance with EBA instructions (EBA/ITS/2020/04), the amounts are presented without securitisation and contributions to default funds of central counterparties.

(In EURm)

31.12.2022

Exposures before CCF and CRM

Exposures post-CCF and CRM

RWA and RWA density

Exposure classes

On-balance
sheet
exposures

Off-balance
sheet
exposures

On-balance
sheet
exposures

Off-balance
sheet
exposures

RWA

RWA
density
(%)

Central governments or central banks

5,432

69

7,304

131

1,684

23%

Regional government or local authorities

567

48

861

28

169

19%

Public sector entities

243

4

203

1

108

53%

Multilateral development banks

927

-

1,100

1

58

5%

International organisations

30

-

30

-

-

 

Institutions

3,566

1,031

3,448

811

1,412

33%

Corporates

38,848

8,711

28,498

2,729

29,371

94%

Retail

30,557

6,195

28,369

1,243

19,264

65%

Secured by mortgages on immovable property

13,536

438

12,478

145

5,718

45%

Exposures in defaul

2,331

174

2,117

43

2,447

113%

Higher-risk categories

223

156

202

72

411

150%

Covered bonds

136

-

136

-

14

10%

Institutions and corporates
with a short term credit assessment

-

-

-

-

-

 

Collective investment undertakings

18

-

18

-

119

676%

Equity

1,222

-

1,222

-

1,098

90%

Other items

36,412

7,544

36,412

2,430

32,211

83%

TOTAL

134,045

24,371

122,398

7,633

94,083

72%

(In EURm)

31.12.2021

Exposures before CCF and CRM

Exposures post-CCF and CRM

RWA and RWA density

Exposure classes

On-balance
sheet
exposures

Off-balance
sheet
exposures

On-balance
sheet
exposures

Off-balance
sheet
exposures

RWA

RWA
density
(%)

Central governments or central banks

7,153

37

8,992

69

1,710

19%

Regional government or local authorities

633

137

895

74

265

27%

Public sector entities

255

15

227

0

130

57%

Multilateral development banks

1,285

17

1,450

1

43

3%

International organisations

-

-

-

-

-

 

Institutions

3,982

1,114

18,760

671

4,472

23%

Corporates

39,775

11,189

29,704

3,232

31,516

96%

Retail

32,513

6,690

31,331

1,684

21,510

65%

Secured by mortgages on immovable property

31,868

1,588

16,715

165

7,357

44%

Exposures in defaul

2,753

322

2,391

191

2,881

112%

Higher-risk categories

210

82

162

36

297

150%

Covered bonds

197

-

197

-

20

10%

Institutions and corporates
with a short term credit assessment

-

-

-

-

-

 

Collective investment undertakings

13

-

13

-

84

656%

Equity

1,195

-

1,195

-

884

74%

Other items

32,352

4,696

32,352

4,688

32,154

87%

TOTAL

154,185

25,888

144,385

10,811

103,323

67%

TABLE 63: STANDARDISED APPROACH – CREDIT RISK EXPOSURES BY REGULATORY EXPOSURE CLASS AND RISK WEIGHTS (CR5)

In accordance with EBA instructions (EBA/ITS/2020/04), the amounts are presented without securitisation and contributions to default funds of central counterparties.

(In EURm)

31.12.2022

Risk Weight

Exposure classes

0%

2%

4%

10%

20%

35%

50%

70%

75%

100%

150%

250%

370%

1,250%

Other Risk Weight

Total

of which unrated

Central governments or central banks

5,746

-

-

-

165

-

-

-

-

1,268

255

-

-

-

-

7,435

2,606

Regional governments or local authorities

184

-

-

-

660

-

1

-

-

44

-

-

-

-

0

889

486

Public sector entities

0

-

-

-

121

-

0

-

-

83

-

-

-

-

0

204

193

Multilateral Development Banks

1,043

-

-

-

-

-

-

-

-

58

-

-

-

-

-

1,101

80

International Organisations

30

-

-

-

-

-

-

-

-

-

-

-

-

-

-

30

Institutions

90

28

-

-

3,030

-

594

-

-

510

7

-

-

-

0

4,259

1,027

Corporates

20

-

-

-

1,434

-

618

904

49

26,716

1,482

-

-

-

5

31,227

25,165

Retail

-

-

-

-

-

626

-

-

28,765

181

-

-

-

-

39

29,611

28,863

Secured by
mortgages on immovable property

-

-

-

-

-

7,943

1,608

-

2,827

245

-

-

-

-

1

12,624

11,683

Exposures
in default

-

-

-

-

-

-

-

-

-

1,554

590

-

-

-

16

2,160

1,975

Items associated with 
particularly high risk

-

-

-

-

-

-

-

-

-

-

274

-

-

-

-

274

205

Covered bonds

-

-

-

136

-

-

-

-

-

-

-

-

-

-

-

136

Claims on institutions and corporates with a short-term credit assessment

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

Collective investments undertakings (CIU)

-

-

-

-

-

-

-

-

-

1

-

-

1

9

7

18

18

Equity exposures

24

-

-

-

-

-

-

-

-

930

-

64

-

-

204

1,222

1,222

Other exposures

3,480

-

-

0

462

0

3,762

-

604

22,048

17

2,539

-

-

5,930

38,841

37,290

TOTAL

10,616

28

-

136

5,872

8,569

6,582

904

32,245

53,640

2,625

2,602

1

9

6,203

130,031

110,812

(In EURm)

31.12.2021

Risk Weight

Exposure classes

0%

2%

4%

10%

20%

35%

50%

70%

75%

100%

150%

250%

370%

1,250%

Other Risk Weight

Total

of which unrated

Central governments or central banks

7,353

-

-

-

2

-

-

-

-

1,698

7

-

-

-

-

9,060

2,456

Regional governments or local authorities

174

-

-

-

652

-

1

-

-

140

-

-

-

-

2

969

546

Public sector entities

0

-

-

-

121

-

0

-

-

105

-

-

-

-

0

227

203

Multilateral Development Banks

1,408

-

-

-

-

-

-

-

-

43

-

-

-

-

-

1,451

66

International Organisations

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

Institutions

328

-

-

-

17,985

-

461

-

-

657

0

-

-

-

0

19,431

1,039

Corporates

-

-

-

-

1,498

-

782

-

35

30,213

392

-

-

-

15

32,935

26,349

Retail

-

-

-

-

-

1,714

-

-

31,089

176

-

-

-

-

37

33,015

32,202

Secured by
mortgages on immovable property

-

-

-

-

-

11,663

1,818

-

3,156

238

-

-

-

-

6

16,880

15,731

Exposures
in default

-

-

-

-

-

-

-

-

-

1,838

673

-

-

-

72

2,582

2,448

Items associated with 
particularly high risk

-

-

-

-

-

-

-

-

-

-

198

-

-

-

-

198

181

Covered bonds

-

-

-

197

-

-

-

-

-

-

-

-

-

-

-

197

-

Claims on institutions and corporates with a short-term credit assessment

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

Collective investments undertakings (CIU)

-

-

-

-

-

-

-

-

-

1

-

-

-

6

5

13

13

Equity exposures

27

-

-

-

-

-

-

-

-

851

-

7

-

-

309

1,195

1,195

Other exposures

1,537

-

-

1

443

-

3,567

-

-

19,842

-

2,487

-

-

9,163

37,041

35,270

TOTAL

10,827

-

-

198

20,701

13,376

6,628

-

34,280

55,804

1,270

2,494

-

6

9,610

155,195

117,700

TABLE 64: INTERNAL APPROACH – CREDIT RISK EXPOSURES BY EXPOSURE CLASS AND PD RANGE (CR6) – AIRB

The table below pesents Group exposures subject to credit risk and for which an internal model is used with a view to calculating RWA.

(In EURm)

31.12.2022

PD scale

Original

on-

 balance

sheet

gross

exposure

Off- 

balance

sheet

exposures

pre CCF

Average

CCF

EAD post

CRM and

post-CCF

Average

PD

Number of

obligors

Average

LGD

Average

maturity

RWA

RWA

density

EL

Value

adjust-

ments

and

Provi-

sions

Central governments 
and central banks

0.00 to < 0.15

234,250

11,323

36%

238,964

0.01%

389

0.76%

1

821

0.34%

1

(0)

0.00 to < 0.10

231,649

11,322

36%

235,571

0.01%

386

0.57%

1

392

0.17%

0

(0)

0.10 to < 0.15

2,602

1

48%

3,393

0.15%

3

14.28%

3

429

12.63%

1

(0)

0.15 to < 0.25

-

-

-

28

-

-

-

2

-

-

-

-

0.25 to < 0.50

1,753

326

75%

2,819

0.26%

12

10.73%

3

348

12.36%

1

(0)

0.50 to < 0.75

3,121

61

75%

6,006

0.51%

10

12.67%

2

1,302

21.67%

3

(0)

0.75 to < 2.50

3,064

640

74%

7,588

1.59%

11

11.23%

4

1,358

17.90%

9

(3)

0.75 to < 1.75

1,686

61

75%

3,920

1.10%

2

12.31%

4

908

23.16%

4

(1)

1.75 to < 2.50

1,378

580

74%

3,668

2.12%

9

10.07%

3

450

12.27%

5

(2)

2.50 to < 10.00

3,107

2,538

72%

9,907

5.03%

168

4.85%

4

818

8.25%

7

(2)

2.50 to < 5.00

2,164

2,173

72%

7,412

4.11%

160

4.13%

4

558

7.53%

5

(1)

5.00 to < 10.00

943

365

75%

2,495

7.76%

8

6.97%

3

259

10.39%

2

(1)

10.00 to < 100.00

1,220

658

77%

5,150

15.27%

25

6.13%

3

995

19.32%

20

(7)

10.00 to < 20.00

1,176

637

79%

2,783

11.05%

18

7.51%

3

828

29.75%

20

(3)

20.00 to < 30.00

44

20

-

2,340

20.46%

7

4.57%

4

167

7.13%

1

(4)

30.00 to < 100.00

-

-

-

27

-

-

-

2

-

-

-

-

100.00 (default)

124

0

75%

1,217

100.00%

11

7.87%

2

206

16.90%

80

(81)

Subtotal

246,638

15,546

46%

271,679

0

626

0

1

5,847

0

122

(94)

Institutions

0.00 to < 0.15

27,610

14,133

70%

32,864

0.03%

2,598

24.71%

2

1,875

5.71%

3

(1)

0.00 to < 0.10

26,834

13,687

70%

31,379

0.03%

2,209

24.93%

2

1,688

5.38%

3

(0)

0.10 to < 0.15

777

446

69%

1,485

0.13%

389

20.00%

2

187

12.62%

0

(0)

0.15 to < 0.25

-

-

-

-

-

-

-

-

-

-

-

-

0.25 to < 0.50

829

979

62%

1,640

0.26%

327

22.52%

2

394

24.02%

1

(0)

0.50 to < 0.75

1,555

856

65%

1,080

0.50%

135

25.81%

2

587

54.39%

1

(0)

0.75 to < 2.50

607

352

43%

1,005

1.56%

112

25.14%

2

421

41.89%

3

(0)

0.75 to < 1.75

271

285

41%

465

1.10%

59

25.99%

2

207

44.56%

1

(0)

1.75 to < 2.50

336

67

52%

540

1.96%

53

24.41%

2

214

39.58%

2

(0)

2.50 to < 10.00

1,448

484

49%

1,556

4.97%

533

29.95%

2

807

51.88%

10

(21)

2.50 to < 5.00

835

417

48%

1,233

4.24%

505

28.34%

2

629

51.03%

7

(19)

5.00 to < 10.00

613

67

55%

324

7.76%

28

36.08%

2

178

55.14%

3

(1)

10.00 to < 100.00

275

247

59%

389

15.01%

64

27.61%

1

360

92.62%

11

(5)

10.00 to < 20.00

230

152

49%

277

12.03%

38

21.71%

1

145

52.34%

3

(1)

20.00 to < 30.00

45

95

75%

111

22.51%

26

42.24%

2

215

193.46%

8

(4)

30.00 to < 100.00

-

-

-

0

-

-

45.00%

1

0

10.79%

0

(0)

100.00 (default)

129

143

88%

310

100.00%

20

38.34%

3

592

191.32%

449

(104)

Subtotal

32,452

17,192

68%

38,844

1.24%

3,789

25.01%

2

5,037

12.97%

478

(131)

Corporate – SME

0.00 to < 0.15

1,607

1,926

63%

2,140

0.14%

4,760

36.25%

3

504

23.55%

1

(2)

0.00 to < 0.10

320

363

74%

574

0.08%

1,285

34.60%

3

116

20.23%

0

(0)

0.10 to < 0.15

1,288

1,563

61%

1,566

0.16%

3,475

36.86%

3

388

24.76%

1

(2)

0.15 to < 0.25

78

23

68%

61

0.16%

366

38.08%

2

14

22.84%

0

(0)

0.25 to < 0.50

1,964

1,006

77%

2,347

0.37%

8,160

36.80%

2

838

35.68%

4

(3)

0.50 to < 0.75

6,007

2,823

81%

7,181

0.68%

9,492

24.90%

2

2,630

36.63%

9

(10)

0.75 to < 2.50

11,962

2,411

74%

12,145

1.95%

20,276

27.65%

4

6,255

51.51%

61

(41)

0.75 to < 1.75

5,468

1,612

73%

5,808

1.26%

11,427

30.68%

3

2,866

49.34%

23

(16)

1.75 to < 2.50

6,494

799

77%

6,337

2.58%

8,849

24.88%

4

3,390

53.49%

38

(24)

2.50 to < 10.00

8,665

1,509

75%

8,387

5.10%

19,805

32.30%

3

6,436

76.74%

137

(150)

2.50 to < 5.00

6,866

1,236

75%

6,699

4.28%

15,461

32.86%

3

5,032

75.12%

95

(100)

5.00 to < 10.00

1,799

273

77%

1,688

8.36%

4,344

30.06%

3

1,404

83.17%

42

(50)

10.00 to < 100.00

2,333

276

70%

1,927

18.70%

6,525

29.27%

2

1,943

100.83%

105

(145)

10.00 to < 20.00

1,487

157

71%

1,217

13.60%

3,834

29.40%

2

1,155

94.85%

50

(75)

20.00 to < 30.00

700

104

68%

566

25.37%

2,015

30.48%

2

658

116.22%

43

(57)

30.00 to < 100.00

147

15

66%

143

35.64%

676

23.37%

2

130

90.88%

12

(13)

100.00 (default)

1,894

230

72%

1,598

100.00%

5,538

46.53%

2

2,471

154.62%

840

(753)

Subtotal

34,511

10,204

74%

35,786

7.50%

74,922

30.25%

3

21,092

58.94%

1,158

(1,103)

Corporate – Specialised lending

0.00 to < 0.15

8,802

6,912

53%

11,168

0.10%

226

21.57%

3

1,230

11.01%

2

(2)

0.00 to < 0.10

5,195

3,639

53%

6,682

0.07%

128

22.45%

3

640

9.57%

1

(1)

0.10 to < 0.15

3,607

3,272

54%

4,485

0.14%

98

20.25%

2

590

13.16%

1

(1)

0.15 to < 0.25

-

-

-

-

-

-

-

-

-

-

-

-

0.25 to < 0.50

4,932

4,675

67%

6,804

0.27%

163

17.83%

2

1,130

16.60%

3

(2)

0.50 to < 0.75

11,497

3,515

47%

12,115

0.58%

409

13.12%

4

3,786

31.25%

9

(8)

0.75 to < 2.50

18,460

8,839

46%

19,890

1.69%

1,041

14.10%

3

6,267

31.51%

43

(23)

0.75 to < 1.75

11,198

5,044

46%

11,936

1.27%

579

13.30%

3

3,603

30.18%

19

(11)

1.75 to < 2.50

7,261

3,795

46%

7,955

2.32%

462

15.30%

3

2,664

33.49%

24

(12)

2.50 to < 10.00

9,782

3,993

42%

8,970

4.33%

763

19.29%

3

3,929

43.80%

54

(189)

2.50 to < 5.00

8,481

3,398

42%

8,051

4.05%

643

19.03%

3

3,413

42.39%

43

(152)

5.00 to < 10.00

1,301

595

42%

919

6.81%

120

21.55%

2

516

56.13%

10

(37)

10.00 to < 100.00

2,434

1,211

53%

1,765

15.45%

144

18.28%

3

1,139

64.54%

37

(159)

10.00 to < 20.00

1,627

392

50%

1,458

14.03%

96

17.39%

3

836

57.36%

24

(99)

20.00 to < 30.00

807

818

55%

307

22.20%

47

22.51%

4

303

98.61%

13

(50)

30.00 to < 100.00

-

1

20%

0

36.21%

1

38.50%

1

0

150.15%

0

(10)

100.00 (default)

1,574

83

43%

1,258

100.00%

112

40.28%

2

799

63.50%

527

(527)

Subtotal

57,480

29,227

51%

61,970

3.80%

2,858

17.07%

3

18,279

29.50%

675

(909)

Corporate – Other

0.00 to < 0.15

32,115

99,029

53%

72,229

0.08%

4,680

30.99%

2

9,963

13.79%

17

(15)

0.00 to < 0.10

18,509

70,854

55%

47,791

0.05%

3,094

32.04%

2

5,273

11.03%

7

(7)

0.10 to < 0.15

13,607

28,175

47%

24,437

0.14%

1,586

28.94%

2

4,690

19.19%

9

(8)

0.15 to < 0.25

55

21

44%

60

0.16%

102

35.78%

2

18

29.36%

0

(0)

0.25 to < 0.50

13,450

26,508

48%

23,140

0.28%

6,002

29.02%

2

6,324

27.33%

15

(12)

0.50 to < 0.75

12,382

17,429

45%

18,060

0.55%

3,258

31.56%

2

10,918

60.45%

25

(18)

0.75 to < 2.50

17,428

15,689

50%

22,097

1.67%

6,259

31.39%

2

14,649

66.30%

97

(65)

0.75 to < 1.75

8,751

9,172

48%

11,411

1.18%

3,399

32.01%

2

6,544

57.35%

34

(22)

1.75 to < 2.50

8,676

6,517

52%

10,686

2.19%

2,860

30.72%

2

8,105

75.85%

64

(43)

2.50 to < 10.00

19,015

10,106

58%

21,293

4.57%

11,179

29.55%

2

16,609

78.00%

221

(428)

2.50 to < 5.00

15,841

8,600

57%

17,416

3.84%

9,605

29.36%

2

12,926

74.22%

155

(303)

5.00 to < 10.00

3,174

1,506

66%

3,877

7.86%

1,574

30.40%

2

3,683

94.98%

66

(125)

10.00 to < 100.00

5,037

1,919

54%

4,143

14.75%

2,569

33.41%

2

5,738

138.49%

162

(327)

10.00 to < 20.00

3,029

1,232

56%

3,199

12.35%

1,283

34.23%

2

4,411

137.87%

107

(242)

20.00 to < 30.00

1,961

669

49%

905

22.39%

1,207

30.45%

2

1,259

139.15%

52

(79)

30.00 to < 100.00

47

18

60%

39

34.51%

79

34.82%

1

68

172.83%

3

(7)

100.00 (default)

2,229

314

72%

1,945

100.00%

1,070

49.47%

2

1,916

98.53%

975

(976)

Subtotal

101,710

171,017

51%

162,968

2.53%

35,119

30.92%

2

66,135

40.58%

1,512

(1,841)

Retail – Secured by real estate SME

0.00 to < 0.15

7

0

100%

7

0.08%

14,967

18.44%

-

0

2.86%

0

(0)

0.00 to < 0.10

3

0

100%

3

0.05%

14,953

18.79%

-

0

2.11%

0

(0)

0.10 to < 0.15

4

-

-

4

0.10%

14

18.15%

-

0

3.48%

0

(0)

0.15 to < 0.25

1

-

-

1

0.19%

13

18.77%

-

0

5.88%

0

(0)

0.25 to < 0.50

864

12

100%

876

0.27%

4,787

16.20%

-

57

6.56%

0

(0)

0.50 to < 0.75

1,735

28

100%

1,764

0.62%

14

9.89%

-

122

6.91%

1

(0)

0.75 to < 2.50

1,939

30

100%

1,969

0.37%

8,966

14.22%

-

302

15.33%

3

(1)

0.75 to < 1.75

1,601

27

100%

1,628

0.01%

8,620

14.16%

-

222

13.64%

2

(0)

1.75 to < 2.50

338

2

100%

341

2.07%

346

14.50%

-

80

23.38%

1

(0)

2.50 to < 10.00

470

7

100%

477

2.84%

2,379

15.62%

-

143

29.94%

2

(1)

2.50 to < 5.00

440

7

100%

447

2.56%

2,225

15.57%

-

128

28.52%

2

(1)

5.00 to < 10.00

30

0

100%

30

6.94%

154

16.36%

-

15

51.18%

0

(0)

10.00 to < 100.00

205

4

100%

209

15.30%

630

9.85%

-

87

41.61%

3

(1)

10.00 to < 20.00

191

4

100%

194

14.48%

547

9.38%

-

76

39.10%

3

(1)

20.00 to < 30.00

14

0

100%

14

26.52%

83

16.33%

-

11

76.00%

1

(0)

30.00 to < 100.00

-

-

-

-

-

-

-

-

-

-

-

-

100.00 (default)

96

0

100%

94

100.00%

487

28.55%

-

116

123.25%

23

(24)

Subtotal

5,318

80

100%

5,397

2.97%

32,243

13.34%

-

827

15.32%

33

(26)

Retail –
Secured by 
real estate non-SME

0.00 to < 0.15

45,379

1,159

100%

46,516

0.07%

344,679

15.74%

-

1,349

2.90%

5

(5)

0.00 to < 0.10

32,099

792

100%

32,870

0.06%

253,192

15.85%

-

844

2.57%

3

(2)

0.10 to < 0.15

13,280

367

100%

13,646

0.10%

91,487

15.48%

-

505

3.70%

2

(3)

0.15 to < 0.25

27,882

803

91%

28,576

0.19%

176,311

16.36%

-

1,847

6.46%

9

(9)

0.25 to < 0.50

13,839

480

88%

14,143

0.40%

124,427

16.80%

-

1,638

11.58%

10

(11)

0.50 to < 0.75

5,222

254

79%

5,393

0.56%

19,669

13.36%

-

1,021

18.93%

4

(2)

0.75 to < 2.50

25,024

792

91%

25,679

1.31%

161,640

15.52%

-

5,708

22.23%

49

(39)

0.75 to < 1.75

17,675

629

89%

18,185

0.94%

132,589

16.71%

-

3,706

20.38%

29

(26)

1.75 to < 2.50

7,349

163

99%

7,493

2.21%

29,051

12.63%

-

2,002

26.72%

20

(13)

2.50 to < 10.00

4,720

115

94%

4,816

5.03%

32,678

15.02%

-

2,357

48.95%

36

(21)

2.50 to < 5.00

3,418

88

92%

3,490

3.87%

24,155

14.95%

-

1,509

43.23%

20

(13)

5.00 to < 10.00

1,302

27

99%

1,326

8.10%

8,523

15.22%

-

848

63.97%

16

(8)

10.00 to < 100.00

586

12

100%

595

23.10%

4,046

14.13%

-

471

79.14%

21

(10)

10.00 to < 20.00

209

5

99%

212

13.63%

1,229

12.41%

-

139

65.59%

4

(3)

20.00 to < 30.00

350

7

100%

356

26.07%

2,431

14.78%

-

309

86.81%

14

(5)

30.00 to < 100.00

27

0

100%

27

58.96%

386

19.06%

-

23

84.68%

3

(3)

100.00 (default)

1,041

3

99%

1,027

100.00%

7,353

28.46%

-

1,350

131.47%

200

(211)

Subtotal

123,692

3,617

93%

126,745

1.51%

870,803

15.92%

-

15,741

12.42%

334

(309)

Retail – Qualifying revolving

0.00 to < 0.15

113

914

34%

1,824

0.07%

2,006,091

53.23%

-

47

2.58%

1

(1)

0.00 to < 0.10

14

381

29%

1,069

0.05%

1,067,001

54.58%

-

21

1.95%

0

(0)

0.10 to < 0.15

99

533

37%

755

0.11%

939,090

51.32%

-

26

3.47%

0

(1)

0.15 to < 0.25

70

334

31%

656

0.19%

1,015,785

51.17%

-

36

5.52%

1

(1)

0.25 to < 0.50

116

289

38%

388

0.37%

600,570

47.83%

-

34

8.79%

1

(1)

0.50 to < 0.75

12

60

56%

43

0.64%

56,775

51.11%

-

172

399.63%

0

(0)

0.75 to < 2.50

506

561

37%

1,133

1.37%

1,804,215

45.05%

-

253

22.31%

7

(9)

0.75 to < 1.75

321

413

36%

799

0.97%

1,291,628

45.64%

-

143

17.84%

4

(5)

1.75 to < 2.50

185

148

38%

334

2.33%

512,587

43.65%

-

110

32.99%

3

(4)

2.50 to < 10.00

515

166

39%

688

5.77%

868,904

43.59%

-

416

60.40%

18

(19)

2.50 to < 5.00

277

110

39%

389

4.06%

503,049

42.21%

-

184

47.20%

7

(8)

5.00 to < 10.00

238

56

38%

299

7.98%

365,855

45.39%

-

232

77.55%

11

(11)

10.00 to < 100.00

218

22

34%

258

23.10%

316,815

45.56%

-

315

122.22%

27

(20)

10.00 to < 20.00

104

8

36%

107

12.72%

57,848

46.42%

-

109

102.19%

6

(5)

20.00 to < 30.00

78

14

33%

114

26.92%

244,060

45.90%

-

160

139.79%

14

(6)

30.00 to < 100.00

37

1

24%

37

41.24%

14,907

42.02%

-

46

125.68%

6

(9)

100.00 (default)

238

6

52%

236

100.00%

158,941

60.97%

-

247

104.90%

135

(136)

Subtotal

1,789

2,352

36%

5,226

6.79%

6,828,096

49.48%

-

1,520

29.09%

189

(186)

Retail –
Other SME

0.00 to < 0.15

70

1

98%

71

0.08%

356

17.78%

-

9

12.07%

0

(0)

0.00 to < 0.10

39

1

97%

40

0.05%

221

16.40%

-

6

14.12%

0

(0)

0.10 to < 0.15

30

1

99%

31

0.11%

135

19.57%

-

3

9.43%

0

(0)

0.15 to < 0.25

54

11

12%

66

0.19%

9,047

24.90%

-

5

7.72%

0

(0)

0.25 to < 0.50

2,527

316

89%

2,769

0.38%

109,898

22.49%

-

304

11.00%

2

(2)

0.50 to < 0.75

2,458

31

89%

2,457

0.59%

52,814

23.61%

-

1,531

62.33%

4

(5)

0.75 to < 2.50

9,929

508

80%

10,398

1.51%

196,852

25.89%

-

2,532

24.35%

41

(28)

0.75 to < 1.75

8,138

359

91%

8,449

1.33%

135,353

24.94%

-

1,906

22.56%

28

(20)

1.75 to < 2.50

1,791

149

55%

1,949

2.28%

61,499

29.99%

-

626

32.11%

13

(8)

2.50 to < 10.00

4,123

209

62%

4,344

5.08%

114,069

27.95%

-

1,636

37.65%

61

(82)

2.50 to < 5.00

2,516

157

52%

2,692

3.97%

75,363

28.73%

-

903

33.55%

31

(49)

5.00 to < 10.00

1,607

53

91%

1,652

6.88%

38,706

26.67%

-

732

44.34%

30

(33)

10.00 to < 100.00

1,323

107

33%

1,471

18.81%

67,475

30.67%

-

747

50.78%

84

(76)

10.00 to < 20.00

894

76

37%

1,005

13.06%

41,543

29.70%

-

440

43.79%

37

(35)

20.00 to < 30.00

273

24

26%

299

25.53%

19,088

33.01%

-

192

64.27%

25

(18)

30.00 to < 100.00

156

7

14%

167

41.37%

6,844

32.35%

-

115

68.68%

22

(22)

100.00 (default)

1,310

5

95%

1,297

100.00%

37,646

37.64%

-

779

60.09%

668

(668)

Subtotal

21,793

1,189

75%

22,872

8.64%

588,157

26.57%

-

7,543

32.98%

861

(861)

Retail –
Other
non-SME

0.00 to < 0.15

2,248

53

91%

2,295

0.08%

69,980

21.31%

-

103

4.48%

0

(4)

0.00 to < 0.10

1,026

27

87%

1,053

0.05%

25,479

19.41%

-

30

2.81%

0

(1)

0.10 to < 0.15

1,222

26

96%

1,242

0.10%

44,501

22.92%

-

73

5.89%

0

(3)

0.15 to < 0.25

2,796

174

100%

2,971

0.18%

173,297

23.83%

-

277

9.31%

1

(8)

0.25 to < 0.50

3,389

519

100%

3,869

0.43%

350,175

35.83%

-

914

23.63%

5

(8)

0.50 to < 0.75

6,403

1,124

100%

7,223

0.73%

258,467

12.92%

-

1,737

24.05%

5

(5)

0.75 to < 2.50

9,121

534

100%

9,585

1.38%

776,508

33.97%

-

3,764

39.27%

42

(54)

0.75 to < 1.75

7,548

454

100%

7,933

1.19%

635,922

34.25%

-

3,021

38.08%

31

(35)

1.75 to < 2.50

1,573

80

100%

1,651

2.31%

140,586

32.61%

-

743

45.03%

11

(19)

2.50 to < 10.00

4,540

128

100%

4,665

4.42%

398,286

37.63%

-

2,679

57.43%

75

(80)

2.50 to < 5.00

3,269

112

100%

3,379

3.49%

271,744

35.70%

-

1,795

53.12%

40

(37)

5.00 to < 10.00

1,270

17

100%

1,287

6.86%

126,542

42.71%

-

884

68.73%

36

(43)

10.00 to < 100.00

1,169

112

100%

1,278

23.80%

127,027

37.39%

-

1,099

86.04%

104

(107)

10.00 to < 20.00

528

8

100%

533

13.30%

47,094

45.71%

-

477

89.38%

31

(45)

20.00 to < 30.00

476

104

100%

581

27.80%

61,145

29.45%

-

452

77.85%

44

(33)

30.00 to < 100.00

166

0

100%

164

43.77%

18,788

38.43%

-

171

104.18%

28

(29)

100.00 (default)

1,427

6

100%

1,422

100.00%

169,122

52.79%

-

822

57.79%

813

(813)

Subtotal

31,092

2,650

100%

33,307

6.43%

2,322,862

29.29%

-

11,396

34.21%

1,047

(1,079)

TOTAL

 

656,476

253,075

54%

764,793

2.47%

10,759,475

16.40%

 

153,417

20.06%

6,408

(6,539)

(In EURm)

31.12.2021

PD scale

Original

on-

 balance

sheet

gross

exposure

Off- 

balance

sheet

exposures

pre CCF

Average

CCF

EAD post

CRM and

post-CCF

Average

PD

Number of

obligors

Average

LGD

Average

maturity

RWA

RWA

density

EL

Value

adjust-

ments

and

Provi-

sions

Central governments 
and central banks

0.00 to < 0.15

228,423

1,723

87%

230,603

0.01%

363

1.91%

1

1,351

0.59%

2

 

0.00 to < 0.10

223,428

1,722

87%

225,187

0.01%

355

1.55%

1

568

0.25%

1

 

0.10 to < 0.15

4,996

1

34%

5,416

0.13%

8

16.82%

3

783

14.46%

1

 

0.15 to < 0.25

-

-

-

118

-

-

-

2

-

-

-

 

0.25 to < 0.50

1,575

2

100%

2,828

0.26%

11

13.55%

3

384

13.60%

1

 

0.50 to < 0.75

2,266

118

100%

5,951

0.50%

9

10.88%

3

1,017

17.10%

26

 

0.75 to < 2.50

3,007

508

100%

8,331

1.55%

10

10.11%

3

1,484

17.82%

8

 

0.75 to < 1.75

2,268

7

100%

4,635

1.10%

5

11.70%

3

1,062

22.92%

5

 

1.75 to < 2.50

739

502

100%

3,696

2.12%

5

8.11%

3

422

11.42%

3

 

2.50 to < 10.00

3,560

2,164

92%

10,770

4.98%

50

4.44%

3

1,395

12.95%

9

 

2.50 to < 5.00

2,632

1,927

91%

7,997

4.01%

38

3.65%

3

1,142

14.28%

7

 

5.00 to < 10.00

928

236

100%

2,773

7.76%

12

6.70%

3

253

9.12%

2

 

10.00 to < 100.00

1,095

405

91%

5,853

16.32%

19

5.63%

3

998

17.06%

21

 

10.00 to < 20.00

1,092

405

91%

2,888

12.55%

17

7.38%

3

834

28.87%

21

 

20.00 to < 30.00

2

-

-

2,896

20.46%

2

4.02%

4

165

5.69%

1

 

30.00 to < 100.00

-

-

-

69

-

-

-

3

-

-

-

 

100.00 (default)

110

0

100%

973

100.00%

9

8.59%

3

122

12.55%

71

 

Subtotal

240,036

4,920

91%

265,428

1.00%

471

2.70%

1

6,752

2.54%

138

(105)

Institutions

0.00 to < 0.15

29,144

9,564

62%

33,938

0.04%

2,526

23.48%

2

1,981

5.84%

3

 

0.00 to < 0.10

26,896

9,148

61%

31,039

0.03%

2,130

24.46%

2

1,723

5.55%

2

 

0.10 to < 0.15

2,248

416

82%

2,898

0.13%

396

13.00%

3

257

8.87%

0

 

0.15 to < 0.25

-

-

-

1

-

-

5.10%

5

0

2.49%

0

 

0.25 to < 0.50

752

649

67%

1,329

0.26%

372

23.61%

2

301

22.65%

1

 

0.50 to < 0.75

2,254

932

67%

1,248

0.50%

163

24.24%

2

419

33.57%

1

 

0.75 to < 2.50

708

514

67%

1,352

1.54%

110

26.72%

2

724

53.54%

4

 

0.75 to < 1.75

363

224

50%

766

1.10%

58

25.78%

2

406

53.01%

1

 

1.75 to < 2.50

345

290

80%

585

2.12%

52

27.94%

2

318

54.24%

3

 

2.50 to < 10.00

1,707

483

34%

1,324

4.66%

293

17.94%

2

681

51.44%

9

 

2.50 to < 5.00

951

286

38%

1,076

3.94%

261

15.12%

2

450

41.85%

4

 

5.00 to < 10.00

756

197

28%

248

7.76%

32

30.16%

1

231

92.99%

5

 

10.00 to < 100.00

513

171

35%

544

14.59%

73

22.70%

1

350

64.34%

10

 

10.00 to < 20.00

461

97

25%

447

13.21%

42

19.26%

1

182

40.72%

4

 

20.00 to < 30.00

52

74

49%

96

21.19%

31

38.47%

2

168

174.76%

6

 

30.00 to < 100.00

-

-

-

1

-

-

45.00%

2

0

9.76%

0

 

100.00 (default)

30

-

-

170

100.00%

14

13.75%

4

67

39.47%

10

 

Subtotal

35,107

12,313

61%

39,906

0.89%

3,551

23.38%

2

4,523

11.33%

38

(50)

Corporate – SME

0.00 to < 0.15

1,084

534

71%

1,338

0.10%

3,171

31.48%

3

238

17.78%

0

 

0.00 to < 0.10

408

198

93%

563

0.05%

932

25.11%

3

67

11.87%

0

 

0.10 to < 0.15

676

336

58%

775

0.13%

2,239

36.10%

3

171

22.08%

0

 

0.15 to < 0.25

4,108

710

89%

4,618

0.20%

1,280

13.16%

1

351

7.61%

1

 

0.25 to < 0.50

930

770

64%

1,102

0.30%

7,754

55.80%

3

560

50.82%

2

 

0.50 to < 0.75

3,057

1,537

60%

3,234

0.53%

6,319

34.93%

3

1,383

42.77%

6

 

0.75 to < 2.50

10,320

2,139

66%

10,052

1.53%

15,710

28.86%

4

5,428

54.00%

45

 

0.75 to < 1.75

6,730

1,170

67%

6,579

1.18%

9,450

27.42%

4

3,289

49.99%

21

 

1.75 to < 2.50

3,590

968

63%

3,473

2.19%

6,260

31.60%

3

2,139

61.59%

24

 

2.50 to < 10.00

9,489

1,406

72%

8,073

4.58%

20,435

32.84%

3

6,431

79.65%

119

 

2.50 to < 5.00

7,397

1,185

73%

6,450

3.78%

15,032

33.29%

3

5,083

78.81%

80

 

5.00 to < 10.00

2,092

220

69%

1,623

7.74%

5,403

31.06%

3

1,347

83.02%

39

 

10.00 to < 100.00

2,613

230

63%

1,881

17.41%

6,935

32.15%

3

2,084

110.78%

104

 

10.00 to < 20.00

1,767

134

62%

1,274

13.19%

4,426

31.93%

3

1,331

104.44%

54

 

20.00 to < 30.00

729

84

65%

544

25.41%

2,084

31.57%

2

652

119.81%

42

 

30.00 to < 100.00

116

13

62%

63

33.55%

425

41.50%

2

102

160.50%

9

 

100.00 (default)

1,745

209

52%

1,601

100.00%

5,282

47.75%

2

2,280

142.44%

801

 

Subtotal

33,345

7,535

68%

31,900

7.78%

66,886

30.39%

3

18,755

58.79%

1,079

(1,167)

Corporate – Specialised lending

0.00 to < 0.15

6,324

5,103

51%

8,565

0.31%

750

19.63%

2

955

11.16%

2

 

0.00 to < 0.10

2,996

2,312

49%

4,046

0.05%

656

21.26%

3

455

11.25%

0

 

0.10 to < 0.15

3,328

2,792

53%

4,518

0.55%

94

18.17%

2

500

11.07%

1

 

0.15 to < 0.25

-

-

-

-

-

-

-

-

-

-

-

 

0.25 to < 0.50

5,645

3,416

42%

6,372

0.27%

164

15.76%

2

1,037

16.27%

3

 

0.50 to < 0.75

10,840

3,450

48%

11,275

0.53%

369

12.76%

4

2,675

23.73%

9

 

0.75 to < 2.50

15,734

8,056

45%

16,954

1.61%

971

13.01%

3

5,626

33.18%

38

 

0.75 to < 1.75

8,799

5,060

46%

9,427

1.15%

469

12.85%

3

3,121

33.11%

16

 

1.75 to < 2.50

6,935

2,997

44%

7,527

2.18%

502

13.22%

3

2,505

33.28%

22

 

2.50 to < 10.00

8,960

3,841

48%

8,874

4.32%

744

16.25%

3

3,739

42.13%

44

 

2.50 to < 5.00

7,212

3,097

47%

7,527

3.82%

632

15.15%

3

3,183

42.29%

34

 

5.00 to < 10.00

1,748

744

52%

1,347

7.11%

112

22.41%

2

556

41.28%

11

 

10.00 to < 100.00

1,322

403

76%

1,358

16.57%

115

15.10%

3

959

70.64%

31

 

10.00 to < 20.00

731

115

63%

782

12.09%

75

15.64%

3

624

79.84%

18

 

20.00 to < 30.00

591

288

81%

576

22.66%

40

14.36%

3

335

58.14%

14

 

30.00 to < 100.00

-

-

-

-

-

-

-

-

-

-

-

 

100.00 (default)

1,321

70

80%

1,119

100.00%

89

56.43%

2

612

54.69%

563

 

Subtotal

50,146

24,340

47%

54,516

3.86%

3,202

15.79%

3

15,604

28.62%

689

(758)

Corporate – Other

0.00 to < 0.15

31,928

87,658

47%

66,826

0.07%

4,424

32.30%

2

10,440

15.62%

14

 

0.00 to < 0.10

21,039

61,535

48%

46,196

0.04%

2,969

33.22%

2

5,745

12.44%

6

 

0.10 to < 0.15

10,889

26,123

43%

20,630

0.13%

1,455

30.23%

2

4,695

22.76%

8

 

0.15 to < 0.25

46

24

64%

51

0.17%

88

35.19%

2

14

28.01%

0

 

0.25 to < 0.50

12,076

22,129

44%

19,988

0.26%

1,655

29.94%

3

6,805

34.05%

15

 

0.50 to < 0.75

11,704

16,137

45%

17,577

0.50%

2,633

29.16%

2

7,872

44.79%

24

 

0.75 to < 2.50

17,961

15,747

44%

21,646

1.58%

5,775

33.01%

2

13,524

62.48%

86

 

0.75 to < 1.75

8,843

9,230

45%

11,708

1.11%

3,190

29.82%

2

6,741

57.58%

34

 

1.75 to < 2.50

9,118

6,517

43%

9,939

2.14%

2,585

36.76%

2

6,783

68.25%

52

 

2.50 to < 10.00

17,208

10,312

54%

20,077

4.52%

9,323

30.45%

2

19,149

95.38%

227

 

2.50 to < 5.00

14,432

8,514

51%

16,291

3.75%

7,404

29.98%

2

15,420

94.66%

160

 

5.00 to < 10.00

2,775

1,798

66%

3,786

7.83%

1,919

32.46%

2

3,729

98.50%

68

 

10.00 to < 100.00

5,980

2,594

61%

3,685

15.24%

2,572

31.15%

2

4,865

132.01%

155

 

10.00 to < 20.00

2,997

1,057

71%

2,620

12.64%

1,650

32.33%

2

3,410

130.18%

92

 

20.00 to < 30.00

2,954

1,533

54%

1,045

21.41%

870

28.10%

2

1,421

135.96%

61

 

30.00 to < 100.00

29

3

88%

20

33.99%

52

35.60%

3

33

166.71%

2

 

100.00 (default)

2,521

429

60%

2,207

100.00%

1,369

49.44%

2

2,048

92.80%

1,156

 

Subtotal

99,424

155,028

47%

152,058

2.77%

27,839

31.71%

2

64,718

42.56%

1,678

(1,977)

Retail – Secured by real estate SME

0.00 to < 0.15

17

2

100%

19

0.04%

15,671

13.97%

 

0

1.47%

0

 

0.00 to < 0.10

17

2

100%

19

0.04%

15,671

13.97%

 

0

1.47%

0

 

0.10 to < 0.15

-

-

-

-

-

-

-

 

-

-

-

 

0.15 to < 0.25

1

-

-

1

0.24%

13

13.39%

 

0

4.88%

0

 

0.25 to < 0.50

816

9

100%

825

0.27%

4,713

16.19%

 

54

6.56%

0

 

0.50 to < 0.75

1,748

26

100%

1,774

0.62%

32

9.87%

 

122

6.87%

1

 

0.75 to < 2.50

2,139

28

100%

2,167

1.04%

12,056

15.04%

 

330

15.24%

3

 

0.75 to < 1.75

2,138

28

100%

2,166

1.04%

9,511

15.05%

 

330

15.25%

3

 

1.75 to < 2.50

1

-

-

1

2.14%

2,545

5.34%

 

0

8.78%

0

 

2.50 to < 10.00

530

9

100%

539

2.83%

211

15.62%

 

161

29.91%

2

 

2.50 to < 5.00

498

9

100%

506

2.57%

11

15.58%

 

145

28.57%

2

 

5.00 to < 10.00

33

0

100%

33

6.90%

200

16.22%

 

17

50.62%

0

 

10.00 to < 100.00

200

3

100%

203

15.46%

649

10.45%

 

90

44.12%

3

 

10.00 to < 20.00

188

3

100%

191

14.72%

576

10.08%

 

80

42.04%

3

 

20.00 to < 30.00

12

0

100%

12

26.83%

73

16.19%

 

9

76.27%

1

 

30.00 to < 100.00

-

-

-

-

-

-

-

 

-

-

-

 

100.00 (default)

138

0

100%

135

100.00%

601

31.90%

 

171

126.45%

35

 

Subtotal

5,590

76

100%

5,663

3.85%

33,946

13.88%

 

929

16.40%

45

(39)

Retail –
Secured by 
real estate non-SME

0.00 to < 0.15

31,049

1,004

100%

32,049

0.07%

595,987

13.99%

 

824

2.57%

3

 

0.00 to < 0.10

31,049

1,004

100%

32,049

0.07%

541,050

13.99%

 

824

2.57%

3

 

0.10 to < 0.15

0

0

100%

0

0.18%

54,937

20.38%

 

0

8.01%

0

 

0.15 to < 0.25

27,828

867

100%

28,534

0.22%

32,754

14.51%

 

1,855

6.50%

9

 

0.25 to < 0.50

8,769

487

100%

9,045

0.41%

8,769

17.90%

 

1,162

12.84%

7

 

0.50 to < 0.75

14,045

732

100%

14,568

0.62%

122,814

10.78%

 

1,471

10.10%

10

 

0.75 to < 2.50

15,635

680

100%

16,162

1.60%

70,440

11.62%

 

2,924

18.10%

25

 

0.75 to < 1.75

7,108

464

100%

7,440

1.03%

61,072

17.91%

 

1,788

24.03%

14

 

1.75 to < 2.50

8,527

217

100%

8,722

2.08%

9,368

6.26%

 

1,137

13.03%

11

 

2.50 to < 10.00

6,151

195

100%

6,320

4.95%

31,327

12.43%

 

2,540

40.19%

36

 

2.50 to < 5.00

3,308

133

100%

3,419

3.27%

24,534

15.49%

 

1,473

43.07%

17

 

5.00 to < 10.00

2,843

62

100%

2,901

6.94%

6,793

8.82%

 

1,068

36.80%

19

 

10.00 to < 100.00

983

24

100%

1,004

17.80%

4,522

9.33%

 

532

53.00%

18

 

10.00 to < 20.00

848

22

100%

869

16.06%

1,741

8.93%

 

439

50.56%

13

 

20.00 to < 30.00

109

2

100%

109

24.48%

992

10.35%

 

67

61.89%

3

 

30.00 to < 100.00

27

0

100%

27

47.07%

1,789

18.15%

 

26

96.33%

2

 

100.00 (default)

951

3

100%

928

100.00%

7,329

27.89%

 

841

90.64%

212

 

Subtotal

105,411

3,991

100%

108,611

1.74%

873,942

13.65%

 

12,150

11.19%

319

(293)

Retail – Qualifying revolving

0.00 to < 0.15

85

1,139

64%

1,714

0.08%

1,646,029

52.25%

 

47

2.72%

1

 

0.00 to < 0.10

17

122

75%

1,250

0.07%

1,476,350

56.69%

 

33

2.66%

0

 

0.10 to < 0.15

68

1,017

63%

463

0.11%

169,679

40.28%

 

13

2.87%

0

 

0.15 to < 0.25

-

232

64%

92

0.24%

234,758

34.27%

 

4

4.42%

0

 

0.25 to < 0.50

95

187

65%

785

0.45%

177,713

54.71%

 

94

11.97%

2

 

0.50 to < 0.75

100

505

56%

285

0.60%

1,454,219

35.64%

 

28

9.83%

1

 

0.75 to < 2.50

323

407

57%

799

1.38%

1,143,085

45.57%

 

180

22.56%

5

 

0.75 to < 1.75

125

220

63%

533

1.13%

975,328

50.82%

 

119

22.36%

3

 

1.75 to < 2.50

199

186

50%

266

1.89%

167,757

35.05%

 

61

22.94%

2

 

2.50 to < 10.00

613

215

59%

1,042

4.91%

1,548,019

46.91%

 

600

57.56%

24

 

2.50 to < 5.00

280

142

58%

538

3.20%

855,015

46.16%

 

231

43.00%

8

 

5.00 to < 10.00

333

73

62%

504

6.73%

693,004

47.71%

 

368

73.09%

16

 

10.00 to < 100.00

351

22

65%

407

21.92%

549,476

44.17%

 

463

113.70%

38

 

10.00 to < 20.00

230

19

63%

273

14.32%

175,133

45.95%

 

297

108.76%

18

 

20.00 to < 30.00

28

2

72%

29

25.14%

192,314

38.55%

 

33

114.51%

3

 

30.00 to < 100.00

93

1

77%

105

40.80%

182,029

41.09%

 

133

126.35%

17

 

100.00 (default)

277

4

22%

273

100.00%

158,751

60.30%

 

126

46.16%

178

 

Subtotal

1,844

2,710

61%

5,398

8.00%

6,912,050

49.20%

 

1,542

28.57%

248

(226)

Retail –
Other SME

0.00 to < 0.15

89

2

100%

90

0.07%

484

14.45%

 

2

2.59%

0

 

0.00 to < 0.10

81

2

100%

83

0.06%

271

11.75%

 

2

1.85%

0

 

0.10 to < 0.15

8

-

-

8

0.13%

213

43.82%

 

1

10.61%

0

 

0.15 to < 0.25

16

11

99%

28

0.23%

299

30.63%

 

3

10.87%

0

 

0.25 to < 0.50

2,885

465

100%

3,309

0.37%

77,001

21.50%

 

345

10.41%

3

 

0.50 to < 0.75

2,872

32

100%

2,904

0.57%

124,819

21.85%

 

397

13.66%

4

 

0.75 to < 2.50

9,575

620

99%

10,176

1.44%

200,149

24.67%

 

2,336

22.96%

37

 

0.75 to < 1.75

7,809

453

99%

8,222

1.30%

96,806

23.92%

 

1,766

21.48%

26

 

1.75 to < 2.50

1,767

167

99%

1,954

2.05%

103,343

27.84%

 

570

29.17%

11

 

2.50 to < 10.00

4,243

209

99%

4,478

4.99%

120,978

26.03%

 

1,758

39.25%

58

 

2.50 to < 5.00

2,307

141

99%

2,481

3.70%

99,203

25.67%

 

921

37.15%

24

 

5.00 to < 10.00

1,936

67

99%

1,997

6.59%

21,775

26.47%

 

836

41.86%

34

 

10.00 to < 100.00

1,148

100

100%

1,289

18.75%

60,068

29.00%

 

616

47.82%

69

 

10.00 to < 20.00

788

73

100%

890

13.07%

34,721

28.10%

 

369

41.39%

31

 

20.00 to < 30.00

198

21

100%

230

25.32%

13,115

34.76%

 

155

67.32%

20

 

30.00 to < 100.00

161

5

100%

168

39.78%

12,232

25.91%

 

93

55.13%

18

 

100.00 (default)

1,283

5

57%

1,262

100.00%

39,732

41.73%

 

479

37.93%

706

 

Subtotal

22,111

1,443

99%

23,537

8.08%

623,530

25.26%

 

5,935

25.22%

876

(892)

Retail –
Other
non-SME

0.00 to < 0.15

1,772

49

100%

1,815

0.09%

78,675

19.37%

 

85

4.70%

0

 

0.00 to < 0.10

1,472

45

100%

1,518

0.09%

4,181

17.62%

 

63

4.14%

0

 

0.10 to < 0.15

300

4

100%

297

0.10%

74,494

28.30%

 

23

7.58%

0

 

0.15 to < 0.25

7,284

1,260

97%

8,501

0.20%

92,564

13.35%

 

474

5.58%

2

 

0.25 to < 0.50

3,737

535

100%

4,262

0.40%

109,410

34.00%

 

924

21.68%

5

 

0.50 to < 0.75

2,392

167

95%

2,551

0.62%

340,553

34.35%

 

742

29.10%

5

 

0.75 to < 2.50

7,768

798

100%

8,546

1.36%

441,732

31.75%

 

3,229

37.78%

38

 

0.75 to < 1.75

5,911

712

100%

6,601

1.15%

324,999

30.42%

 

2,262

34.26%

23

 

1.75 to < 2.50

1,858

86

100%

1,944

2.06%

116,733

36.27%

 

967

49.75%

14

 

2.50 to < 10.00

5,257

340

100%

5,597

4.23%

329,660

34.67%

 

3,015

53.87%

83

 

2.50 to < 5.00

3,729

308

100%

4,037

3.29%

278,612

33.22%

 

2,050

50.77%

44

 

5.00 to < 10.00

1,528

32

100%

1,560

6.68%

51,048

38.43%

 

966

61.90%

39

 

10.00 to < 100.00

1,204

36

59%

1,225

25.18%

130,307

34.42%

 

960

78.37%

99

 

10.00 to < 20.00

564

34

55%

583

13.58%

54,226

39.60%

 

456

78.23%

31

 

20.00 to < 30.00

239

2

100%

241

23.85%

48,769

32.71%

 

198

82.22%

19

 

30.00 to < 100.00

400

1

100%

401

42.86%

27,312

27.90%

 

306

76.25%

49

 

100.00 (default)

1,545

7

99%

1,545

100.00%

137,827

51.38%

 

643

41.63%

919

 

Subtotal

30,960

3,191

98%

34,041

6.63%

1,660,728

28.44%

 

10,073

29.59%

1,151

(1,167)

TOTAL

 

623,975

215,549

52%

721,058

2.57%

10,206,145

16.21%

 

140,981

19.55%

6,261

(6,673)

TABLE 65: INTERNAL APPROACH – CREDIT RISK EXPOSURES BY EXPOSURE CLASS AND PD RANGE (CR6) – FIRB

(In EURm)

31.12.2022

PD scale

On-

balance

sheet

exposures

Off-

balance

sheet

exposures

pre CCF

Exposure

weighted

average

CCF

Exposure

post CCF

and post

CRM

Exposure

weighted

average

PD

Number

of

obligors

Exposure

weighted

average

LGD

Exposure

weighted

average

maturity

RWA

after SME

supporting

factor

Density

of RWA

Expected

loss

amount

Value

adjust-

ments

and

provi-

sions

Central
governments
and central banks

0.00 to < 0.15

48

-

-

48

0.01%

294

43.02%

3

5

9.42%

0

(0)

0.00 to < 0.10

48

-

-

48

0.01%

294

43.02%

3

5

9.42%

0

(0)

0.10 to < 0.15

-

-

-

0

-

-

41.03%

3

0

6.75%

-

-

0.15 to < 0.25

-

-

-

-

-

-

-

-

-

-

-

-

0.25 to < 0.50

-

-

-

0

-

-

41.45%

3

0

8.66%

0

(0)

0.50 to < 0.75

-

-

-

0

-

-

40.37%

3

0

8.07%

0

(0)

0.75 to < 2.50

-

-

-

1

-

-

41.25%

3

0

7.05%

0

(0)

0.75 to < 1.75

-

-

-

1

-

-

41.37%

3

0

7.01%

0

(0)

1.75 to < 2.50

-

-

-

1

-

-

41.10%

3

0

7.10%

0

(0)

2.50 to < 10.00

0

-

-

7

2.67%

11

41.35%

3

1

11.16%

0

(0)

2.50 to < 5.00

0

-

-

6

3.26%

11

41.33%

3

1

12.10%

0

(0)

5.00 to < 10.00

-

-

-

1

-

-

41.45%

3

0

6.92%

0

(0)

10.00 to < 100.00

-

-

-

2

-

-

41.15%

3

0

6.89%

0

(0)

10.00 to < 20.00

-

-

-

1

-

-

41.15%

3

0

6.97%

0

(0)

20.00 to < 30.00

-

-

-

0

-

-

40.73%

3

0

6.70%

0

(0)

30.00 to < 100.00

-

-

-

0

-

-

42.07%

3

0

6.97%

0

(0)

100.00 (default)

-

-

-

2

-

-

41.35%

3

0

8.92%

0

(0)

Subtotal

48

-

 

61

0.32%

305

42.67%

3

6

9.49%

0

(0)

Institutions

0.00 to < 0.15

1

-

-

1

0.04%

20

44.26%

3

0

36.96%

0

(0)

0.00 to < 0.10

1

-

-

1

0.03%

18

44.25%

3

0

36.62%

0

(0)

0.10 to < 0.15

0

-

-

0

0.13%

2

44.33%

3

0

39.63%

0

(0)

0.15 to < 0.25

-

-

-

-

-

-

-

-

-

-

-

-

0.25 to < 0.50

-

-

-

-

-

-

-

-

-

-

-

-

0.50 to < 0.75

0

-

-

0

0.50%

4

40.45%

3

0

92.80%

0

(0)

0.75 to < 2.50

0

-

-

0

1.19%

2

44.58%

3

0

128.17%

0

(0)

0.75 to < 1.75

0

-

-

0

1.10%

1

45.00%

3

0

128.82%

0

(0)

1.75 to < 2.50

0

-

-

0

2.12%

1

40.00%

3

0

121.07%

0

-

2.50 to < 10.00

0

-

-

0

3.76%

3

43.15%

3

0

168.34%

0

(0)

2.50 to < 5.00

0

-

-

0

3.26%

2

42.92%

3

0

161.97%

0

(0)

5.00 to < 10.00

0

-

-

0

7.76%

1

45.00%

3

0

219.48%

0

(0)

10.00 to < 100.00

0

-

-

0

11.42%

2

40.00%

3

0

221.89%

0

-

10.00 to < 20.00

0

-

-

0

11.42%

2

40.00%

3

0

221.89%

0

-

20.00 to < 30.00

-

-

-

-

-

-

-

-

-

-

-

-

30.00 to < 100.00

-

-

-

-

-

-

-

-

-

-

-

-

100.00 (default)

-

-

-

-

-

-

-

-

-

-

-

-

Subtotal

1

-

 

1

0.55%

31

43.53%

3

1

58.69%

0

(0)

Corporate – SME

0.00 to < 0.15

153

15

75%

164

0.21%

658

41.40%

3

46

28.31%

0

(0)

0.00 to < 0.10

1

-

-

1

0.27%

3

40.01%

3

0

29.31%

0

(0)

0.10 to < 0.15

152

15

75%

163

0.21%

655

41.40%

3

46

28.31%

0

(0)

0.15 to < 0.25

23

2

75%

25

0.16%

120

40.87%

3

6

24.55%

0

(0)

0.25 to < 0.50

164

13

75%

174

0.41%

700

41.42%

3

70

39.99%

0

(0)

0.50 to < 0.75

311

33

75%

335

0.69%

1,507

41.34%

3

180

53.65%

1

(1)

0.75 to < 2.50

751

77

75%

808

1.86%

3,826

41.65%

3

532

65.85%

6

(3)

0.75 to < 1.75

435

51

75%

473

1.33%

2,248

41.65%

3

290

61.25%

2

(2)

1.75 to < 2.50

316

26

75%

335

2.60%

1,578

41.66%

3

242

72.33%

3

(2)

2.50 to < 10.00

669

65

75%

712

5.06%

4,470

41.89%

3

616

86.51%

14

(10)

2.50 to < 5.00

550

59

75%

589

4.36%

3,606

42.00%

3

492

83.42%

10

(6)

5.00 to < 10.00

120

7

75%

123

8.42%

864

41.39%

3

125

101.33%

4

(4)

10.00 to < 100.00

151

3

75%

149

17.87%

1,434

41.69%

3

170

114.22%

9

(8)

10.00 to < 20.00

109

2

75%

108

13.86%

776

41.83%

3

113

105.11%

5

(5)

20.00 to < 30.00

29

0

75%

29

24.81%

295

41.59%

3

37

129.87%

2

(2)

30.00 to < 100.00

13

0

75%

13

35.91%

363

40.79%

3

20

155.43%

2

(1)

100.00 (default)

103

0

75%

101

100.00%

978

41.94%

3

2

1.72%

42

(47)

Subtotal

2,325

209

75%

2,469

7.39%

13,693

41.65%

3

1,622

65.72%

72

(69)

Corporate – Other

0.00 to < 0.15

1,009

6

75%

1,014

0.06%

500

41.51%

3

228

22.49%

0

(0)

0.00 to < 0.10

836

3

75%

838

0.05%

282

41.45%

3

168

20.07%

0

(0)

0.10 to < 0.15

174

4

75%

176

0.13%

218

41.78%

3

60

33.97%

0

(0)

0.15 to < 0.25

8

0

75%

8

0.16%

45

40.48%

3

3

37.37%

0

(0)

0.25 to < 0.50

241

10

75%

248

0.26%

357

42.04%

3

123

49.64%

0

(0)

0.50 to < 0.75

445

7

75%

451

0.52%

515

41.82%

3

323

71.67%

1

(1)

0.75 to < 2.50

694

31

75%

712

1.37%

1,192

42.20%

3

669

93.84%

4

(7)

0.75 to < 1.75

428

19

75%

438

0.84%

643

42.35%

3

357

81.66%

1

(5)

1.75 to < 2.50

266

12

75%

275

2.21%

549

41.96%

3

311

113.22%

2

(1)

2.50 to < 10.00

680

21

75%

694

4.18%

2,384

41.70%

3

912

131.42%

11

(11)

2.50 to < 5.00

608

19

75%

621

3.75%

2,049

41.70%

3

791

127.50%

9

(9)

5.00 to < 10.00

72

2

75%

74

7.77%

335

41.68%

3

121

164.47%

2

(3)

10.00 to < 100.00

143

2

75%

147

15.60%

493

40.78%

3

302

205.57%

9

(11)

10.00 to < 20.00

106

2

75%

110

12.40%

306

40.78%

3

218

197.61%

6

(6)

20.00 to < 30.00

36

0

75%

36

24.95%

172

40.78%

3

82

229.38%

4

(4)

30.00 to < 100.00

1

-

-

1

35.20%

15

40.00%

3

2

231.80%

0

(0)

100.00 (default)

63

0

75%

62

100.00%

205

41.60%

3

-

-

26

(21)

Subtotal

3,282

78

75%

3,338

3.82%

5,691

41.75%

3

2,561

76.72%

52

(50)

TOTAL

 

5,658

287

75%

5,868

5.28%

19,720

41.72%

 

4,190

71.39%

124

(120)

(In EURm)

31.12.2021

PD scale

On-

balance

sheet

exposures

Off-

balance

sheet

exposures

pre CCF

Exposure

weighted

average

CCF

Exposure

post CCF

and post

CRM

Exposure

weighted

average

PD

Number

of

obligors

Exposure

weighted

average

LGD

Exposure

weighted

average

maturity

RWA

after SME

supporting

factor

Density

of RWA

Expected

loss

amount

Value

adjust-

ments

and

provi-

sions

Central
governments
and central banks

0.00 to < 0.15

19

-

 

19

0.01%

10

44.90%

3

2

9.72%

0

 

0.00 to < 0.10

19

-

 

19

0.01%

10

44.90%

3

2

9.72%

0

 

0.10 to < 0.15

-

-

 

0

-

-

41.52%

3

0

8.96%

-

 

0.15 to < 0.25

-

-

 

-

 

-

 

-

-

 

-

 

0.25 to < 0.50

-

-

 

0

-

-

41.38%

3

0

6.86%

-

 

0.50 to < 0.75

-

-

 

2

-

-

2.78%

3

0

0.46%

-

 

0.75 to < 2.50

-

-

 

1

0.01%

-

41.38%

3

0

7.50%

0

 

0.75 to < 1.75

-

-

 

0

0.01%

-

41.38%

3

0

7.62%

0

 

1.75 to < 2.50

-

-

 

0

0.01%

-

41.38%

3

0

7.30%

0

 

2.50 to < 10.00

0

-

 

8

2.46%

1

41.49%

3

1

7.54%

0

 

2.50 to < 5.00

0

-

 

6

3.26%

1

41.61%

3

0

7.74%

0

 

5.00 to < 10.00

-

-

 

2

 

-

41.11%

3

0

6.92%

0

 

10.00 to < 100.00

-

-

 

2

 

-

41.32%

3

0

6.93%

0

 

10.00 to < 20.00

-

-

 

1

 

-

41.17%

3

0

6.90%

0

 

20.00 to < 30.00

-

-

 

1

 

-

41.68%

3

0

7.02%

0

 

30.00 to < 100.00

-

-

 

0

 

-

41.66%

3

0

7.01%

-

 

100.00 (default)

-

-

 

2

 

-

41.35%

3

0

8.92%

0

 

Subtotal

19

-

 

32

0.58%

11

41.57%

3

3

8.50%

0

(0)

Institutions

0.00 to < 0.15

0

-

 

0

0.05%

12

43.38%

3

0

24.92%

0

 

0.00 to < 0.10

0

-

 

0

0.03%

9

43.53%

3

0

20.03%

0

 

0.10 to < 0.15

0

-

 

0

0.13%

3

42.82%

3

0

43.68%

0

 

0.15 to < 0.25

-

-

 

-

 

-

 

-

-

 

-

 

0.25 to < 0.50

0

-

 

0

0.26%

2

40.00%

3

0

54.84%

0

 

0.50 to < 0.75

1

-

 

-

0.50%

1

-

-

-

-

-

 

0.75 to < 2.50

0

-

 

0

2.12%

1

40.58%

3

0

122.83%

0

 

0.75 to < 1.75

-

-

 

-

 

-

 

-

-

 

-

 

1.75 to < 2.50

0

-

 

0

2.12%

1

40.58%

3

0

122.83%

0

 

2.50 to < 10.00

0

-

 

0

5.73%

2

45.00%

3

0

197.12%

0

 

2.50 to < 5.00

0

-

 

0

3.26%

1

45.00%

3

0

169.81%

0

 

5.00 to < 10.00

0

-

 

0

7.76%

1

45.00%

3

0

219.49%

0

 

10.00 to < 100.00

-

-

 

-

 

-

 

-

-

 

-

 

10.00 to < 20.00

-

-

 

-

 

-

 

-

-

 

-

 

20.00 to < 30.00

-

-

 

-

 

-

 

-

-

 

-

 

30.00 to < 100.00

-

-

 

-

 

-

 

-

-

 

-

 

100.00 (default)

-

-

 

-

 

-

 

-

-

 

-

 

Subtotal

2

-

 

0

0.40%

18

43.26%

3

0

37.34%

0

(0)

Corporate – SME

0.00 to < 0.15

74

6

100%

78

0.12%

246

41.22%

3

18

22.89%

0

 

0.00 to < 0.10

6

-

 

6

0.04%

11

40.97%

3

1

16.30%

0

 

0.10 to < 0.15

68

6

100%

72

0.13%

235

41.24%

3

17

23.39%

0

 

0.15 to < 0.25

87

10

100%

95

0.16%

466

41.24%

3

24

24.82%

0

 

0.25 to < 0.50

146

17

100%

159

0.29%

603

41.72%

3

60

37.36%

0

 

0.50 to < 0.75

279

21

100%

295

0.55%

1,291

41.25%

3

140

47.59%

1

 

0.75 to < 2.50

630

58

100%

671

1.59%

2,950

41.67%

3

439

65.43%

4

 

0.75 to < 1.75

396

36

100%

421

1.20%

1,893

41.52%

3

263

62.41%

2

 

1.75 to < 2.50

234

21

100%

250

2.24%

1,057

41.92%

3

176

70.52%

2

 

2.50 to < 10.00

728

38

100%

748

4.53%

4,952

41.65%

3

630

84.32%

12

 

2.50 to < 5.00

565

32

100%

585

3.73%

3,768

41.79%

3

468

80.02%

8

 

5.00 to < 10.00

163

6

100%

163

7.40%

1,184

41.16%

3

163

99.73%

4

 

10.00 to < 100.00

182

3

100%

182

17.24%

1,471

41.28%

3

225

123.53%

10

 

10.00 to < 20.00

124

3

100%

125

13.33%

944

41.10%

3

154

123.41%

6

 

20.00 to < 30.00

50

0

100%

50

24.51%

414

41.87%

3

59

119.42%

3

 

30.00 to < 100.00

8

0

100%

8

33.66%

113

40.32%

3

12

151.45%

1

 

100.00 (default)

88

1

100%

87

100.00%

873

42.01%

3

2

2.04%

36

 

Subtotal

2,214

153

100%

2,315

7.13%

12,852

41.56%

3

1,538

66.43%

63

(60)

Corporate – Other

0.00 to < 0.15

1,014

10

100%

1,022

0.07%

537

41.66%

3

231

22.61%

0

 

0.00 to < 0.10

840

6

100%

844

0.06%

289

41.61%

3

171

20.30%

0

 

0.10 to < 0.15

174

4

100%

177

0.13%

248

41.88%

3

60

33.63%

0

 

0.15 to < 0.25

6

1

100%

7

0.17%

36

40.80%

3

2

29.06%

0

 

0.25 to < 0.50

195

7

100%

201

0.26%

347

41.72%

3

95

47.36%

0

 

0.50 to < 0.75

479

9

100%

486

0.51%

550

41.96%

3

323

66.31%

1

 

0.75 to < 2.50

673

34

100%

700

1.77%

1,412

41.51%

3

674

96.29%

5

 

0.75 to < 1.75

323

20

100%

339

1.17%

800

41.56%

3

286

84.39%

1

 

1.75 to < 2.50

351

14

100%

361

2.33%

612

41.47%

3

388

107.46%

3

 

2.50 to < 10.00

733

15

100%

746

4.85%

2,717

41.46%

3

978

131.14%

14

 

2.50 to < 5.00

541

11

100%

547

3.78%

2,211

41.68%

3

675

123.26%

8

 

5.00 to < 10.00

192

5

100%

198

7.80%

506

40.87%

3

303

152.94%

6

 

10.00 to < 100.00

146

3

100%

148

17.07%

681

40.98%

3

278

188.37%

9

 

10.00 to < 20.00

102

1

100%

102

13.17%

445

40.77%

3

194

189.54%

5

 

20.00 to < 30.00

38

1

100%

39

24.64%

214

41.62%

3

71

181.58%

3

 

30.00 to < 100.00

6

-

 

6

33.30%

22

40.36%

3

13

211.28%

1

 

100.00 (default)

44

-

 

43

100.00%

257

41.72%

3

0

0.12%

18

 

Subtotal

3,290

80

100%

3,352

3.60%

6,537

41.60%

3

2,581

76.98%

48

(40)

TOTAL

 

5,525

233

100%

5,700

5.02%

19,418

41.59%

3

4,121

72.30%

111

(100)

TABLE 66: IRB APPROACH – EFFECT ON RWA OF CREDIT DERIVATIVES USED AS CRM TECHNIQUES (CR7)

(In EURm) 

31.12.2022

Pre-credit

derivatives RWA

Actual RWA

EXPOSURES UNDER FIRB

4,190

4,190

Central governments and central banks

5

6

Institutions

1

1

Corporates 

4,184

4,183

of which Corporates – SMEs

1,626

1,622

of which Corporates Specialised lending

-

-

EXPOSURES UNDER AIRB

154,357

154,084

Central governments and central banks

5,847

5,847

Institutions

5,037

5,037

Corporates 

106,446

106,173

of which Corporates – SMEs

21,092

21,092

of which Corporates – Specialised lending

18,946

18,946

Retail

37,027

37,027

of which Retail – SMEs – Secured by immovable property collateral 

827

827

of which Retail – Non-SMEs – Secured by immovable property collateral

15,741

15,741

of which Retail – Qualifying revolving

1,520

1,520

of which Retail – SMEs – Other

7,543

7,543

of which Retail Non-SMEs Other

11,396

11,396

TOTAL

158,546

158,274

(In EURm) 

31.12.2021

Pre-credit

derivatives RWA

Actual RWA

EXPOSURES UNDER FIRB

4,121

4,121

Central governments and central banks

3

3

Institutions

0

0

Corporates 

4,118

4,118

of which Corporates – SMEs

1,538

1,538

of which Corporates Specialised lending

-

-

EXPOSURES UNDER AIRB

142,083

141,733

Central governments and central banks

6,752

6,752

Institutions

4,523

4,523

Corporates 

100,179

99,828

of which Corporates – SMEs

18,755

18,755

of which Corporates – Specialised lending

16,355

16,355

Retail

30,629

30,629

of which Retail – SMEs – Secured by immovable property collateral 

929

929

of which Retail – Non-SMEs – Secured by immovable property collateral

12,150

12,150

of which Retail – Qualifying revolving

1,542

1,542

of which Retail – SMEs – Other

5,935

5,935

of which Retail Non-SMEs Other

10,073

10,073

TOTAL

146,204

145,854

TABLE 67: INTERNAL APPROACH – DISCLOSURE OF THE EXTENT OF THE USE OF CRM TECHNIQUES (CR7-A) – AIRB

(In EURm)

31.12.2022

Total

exposures

 

Credit risk mitigation techniques

 

Part of

exposures

covered by

Financial

collaterals (%)

Part of

exposures

covered by

other eligible

collaterals (%)

Funded credit Protection (FCP)

Part of

exposures

covered by

immovable

property

collaterals (%)

Part of

exposures

covered by

receivables (%)

Part of

exposures

covered by

other physical

collateral (%)

Central governments and central banks

252,423

0.15%

0.21%

-

-

0.21%

Institutions

38,588

0.91%

1.06%

0.26%

0.11%

0.69%

Corporates

281,286

1.51%

18.01%

7.89%

4.89%

5.24%

of which Corporates – SMEs

39,820

1.07%

17.94%

16.77%

0.52%

0.65%

of which Corporates – Specialised lending

70,845

1.32%

31.91%

17.31%

1.84%

12.76%

of which Corporates – Other

170,621

1.69%

12.26%

1.90%

7.18%

3.18%

Retail

193,661

-

74.14%

71.62%

-

2.52%

of which Retail – Immovable property SMEs

5,397

-

95.34%

95.34%

-

-

of which Retail – Immovable property Non-SMEs

126,745

-

99.66%

99.66%

-

-

of which Retail – Qualifying revolving

5,226

-

-

-

-

-

of which Retail – Other SMEs

22,986

-

19.25%

7.92%

-

11.33%

of which Retail Other Non-SMEs

33,307

-

23.13%

16.29%

-

6.84%

TOTAL

765,958

0.65%

25.48%

21.02%

1.80%

2.66%

(In EURm)

31.12.2022

Credit risk

mitigation techniques

Credit risk

mitigation methods in the calculation of RWA

Unfunded credit Protection (UFCP)

RWA without

substitution effects

(reduction effects only)

RWA with substitution

effects (both reduction

and sustitution effects)

Part of exposures

covered by

Guarantees (%)

Part of exposures

covered by

Credit Derivatives (%)

Central governments and central banks

3.67%

-

5,133

5,847

Institutions

9.41%

-

4,891

5,037

Corporates

20.86%

0.45%

107,024

106,173

of which Corporates – SMEs

14.43%

0.01%

21,508

21,092

of which Corporates – Specialised lending

27.11%

-

19,344

18,946

of which Corporates – Other

19.76%

0.74%

66,172

66,135

Retail

0.85%

-

37,035

37,027

of which Retail – Immovable property SMEs

3.46%

-

827

827

of which Retail – Immovable property Non-SMEs

0.39%

-

15,745

15,741

of which Retail – Qualifying revolving

0.01%

-

1,520

1,520

of which Retail – Other SMEs

0.94%

-

7,547

7,543

of which Retail Other Non-SMEs

2.26%

-

11,396

11,396

TOTAL

9.56%

0.16%

154,084

154,084

(In EURm)

30.06.2022

Total

exposures

 

Credit risk mitigation techniques

 

Part of

exposures

covered by

Financial

collaterals (%)

Part of

exposures

covered by

other eligible

collaterals (%)

Funded credit Protection (FCP)

Part of

exposures

covered by

immovable

property

collaterals (%)

Part of

exposures

covered by

receivables (%)

Part of

exposures

covered by

other physical

collateral (%)

Central governments and central banks

248,864

0.15%

0.20%

-

-

0.20%

Institutions

42,331

0.89%

1.01%

0.30%

0.17%

0.54%

Corporates

282,346

1.51%

17.84%

7.71%

5.16%

4.96%

of which Corporates – SMEs

42,532

1.07%

18.41%

17.25%

0.43%

0.73%

of which Corporates – Specialised lending

69,819

1.40%

33.21%

16.07%

3.67%

13.48%

of which Corporates – Other

169,995

1.67%

11.38%

1.90%

6.96%

2.53%

Retail

180,247

-

71.92%

69.17%

-

2.75%

of which Retail – Immovable property SMEs

5,573

-

94.98%

94.98%

-

-

of which Retail – Immovable property Non-SMEs

111,007

-

99.85%

99.85%

-

-

of which Retail – Qualifying revolving

5,339

-

-

-

-

-

of which Retail – Other SMEs

23,743

-

19.35%

8.55%

-

10.81%

of which Retail Other Non-SMEs

34,586

-

25.75%

18.85%

-

6.89%

TOTAL

753,789

0.66%

24.00%

19.45%

1.94%

2.61%

(In EURm)

30.06.2022

Credit risk

mitigation techniques

Credit risk

mitigation methods in the calculation of RWA

Unfunded credit Protection (UFCP)

RWA without

substitution effects

(reduction effects only)

RWA with substitution

effects (both reduction

and sustitution effects)

Part of exposures

covered by

Guarantees (%)

Part of exposures

covered by

Credit Derivatives (%)

Central governments and central banks

3.41%

-

4,886

5,579

Institutions

7.58%

-

6,106

6,265

Corporates

19.90%

0.57%

108,138

107,367

of which Corporates – SMEs

17.69%

0.01%

22,809

22,376

of which Corporates – Specialised lending

26.47%

-

19,065

18,656

of which Corporates – Other

17.75%

0.94%

66,264

66,335

Retail

0.90%

-

33,887

33,806

of which Retail – Immovable property SMEs

3.86%

-

879

879

of which Retail – Immovable property Non-SMEs

0.31%

-

12,574

12,500

of which Retail – Qualifying revolving

-

-

1,757

1,757

of which Retail – Other SMEs

1.26%

-

7,479

7,472

of which Retail Other Non-SMEs

2.20%

-

11,198

11,198

TOTAL

9.22%

0.21%

153,018

153,018

TABLE 68: INTERNAL APPROACH – DISCLOSURE OF THE EXTENT OF THE USE OF CRM TECHNIQUES (CR7-A) – FIRB

(In EURm)

31.12.2022

Total

exposures

 

Credit risk mitigation techniques

 

Part of

exposures

covered by

Financial

collaterals (%)

Part of

exposures

covered by

other eligible

collaterals (%)

Funded credit Protection (FCP)

Part of

exposures

covered by

Immovable

property

collaterals (%)

Part of

exposures

covered by

receivables (%)

Part of

exposures

covered by

other physical

collateral (%)

Central governments and central banks

48

-

58.30%

-

-

58.30%

Institutions

1

-

29.54%

-

-

29.54%

Corporates

5,819

-

66.73%

-

-

66.73%

of which Corporates – SMEs

2,482

-

68.08%

-

-

68.08%

of which Corporates – Specialised lending

-

-

-

-

-

-

of which Corporates Other

3,336

-

65.73%

-

-

65.73%

TOTAL

5,868

-

66.65%

-

-

66.65%

(In EURm)

31.12.2022

Credit risk

mitigation techniques

Credit risk

mitigation methods in the calculation of RWA

Unfunded credit Protection (UFCP)

RWA without

substitution effects

(reduction effects only)

RWA with substitution

effects (both reduction

and sustitution effects)

Part of exposures

covered by

Guarantees (%)

Part of exposures

covered by

Credit Derivatives (%)

Central governments and central banks

-

-

5

6

Institutions

-

-

1

1

Corporates

0.48%

-

4,184

4,183

of which Corporates – SMEs

0.67%

-

1,626

1,622

of which Corporates – Specialised lending

-

-

-

-

of which Corporates Other

0.34%

-

2,558

2,561

TOTAL

0.48%

-

4,190

4,190

(In EURm)

30.06.2022

Total

exposures

 

Credit risk mitigation techniques

 

Part of

exposures

covered by

Financial

collaterals (%)

Part of

exposures

covered by

other eligible

collaterals (%)

Funded credit Protection (FCP)

Part of

exposures

covered by

Immovable

property

collaterals (%)

Part of

exposures

covered by

receivables (%)

Part of

exposures

covered by

other physical

collateral (%)

Central governments and central banks

13

-

67.42%

-

-

67.42%

Institutions

2

-

17.22%

-

-

17.22%

Corporates

5,748

-

67.95%

-

-

67.95%

of which Corporates – SMEs

2,523

-

67.14%

-

-

67.14%

of which Corporates – Specialised lending

-

-

-

-

-

-

of which Corporates Other

3,225

-

68.58%

-

-

68.58%

TOTAL

5,764

-

67.93%

-

-

67.93%

(In EURm)

30.06.2022

Credit risk

mitigation techniques

Credit risk

mitigation methods in the calculation of RWA

Unfunded credit Protection (UFCP)

RWA without

substitution effects

(reduction effects only)

RWA with substitution

effects (both reduction

and sustitution effects)

Part of exposures

covered by

Guarantees (%)

Part of exposures

covered by

Credit Derivatives (%)

Central governments and central banks

-

-

1

2

Institutions

-

-

1

1

Corporates

0.54%

-

4,291

4,290

of which Corporates – SMEs

0.81%

-

1,649

1,645

of which Corporates – Specialised lending

-

-

-

-

of which Corporates Other

0.33%

-

2,642

2,646

TOTAL

0.54%

-

4,294

4,294

TABLE 69: RWA FLOW STATEMENT OF CREDIT RISK EXPOSURES UNDER THE IRB APPROACH (CR8)

(In EURm)

Risk-weighted assets

RWA as at the end of the previous reporting period (30.09.2022)

182,856

Asset size (+/-)

1,111

Asset quality (+/-)

(1,199)

Model updates (+/-)

863

Methodology and policy (+/-)

-

Acquisitions and disposals (+/-)

519

Foreign exchange movements (+/-)

(2,555)

Other (+/-)

-

RWA as at the end of the reporting period (31.12.2022)

181,596

TABLE 70: SPECIALISED LENDING EXPOSURES – INTERNAL APPROACH (CR10.1-10.4)

(In EURm)

31.12.2022

Specialised lending: income-producing real estate and high volatility commercial real estate (Slotting approach)

Regulatory categories

Remaining maturity

On-balance
sheet
exposure

Off-balance
sheet
exposure

Risk weight

Exposure
value

RWA

Expected loss amount

Category 1

Less than 2.5 years

173

1,109

50%

492

235

-

Equal to or more than 2.5 years

-

78

70%

16

11

0

Category 2

Less than 2.5 years

387

459

70%

574

340

2

Equal to or more than 2.5 years

-

22

90%

4

4

0

Category 3

Less than 2.5 years

27

76

115%

53

52

1

Equal to or more than 2.5 years

-

-

115%

-

-

-

Category 4

Less than 2.5 years

7

10

250%

11

24

1

Equal to or more than 2.5 years

0

-

250%

0

1

0

Category 5

Less than 2.5 years

14

3

-

15

-

7

Equal to or more than 2.5 years

-

-

-

-

-

-

TOTAL

Less than 2.5 years

609

1,657

 

1,144

651

12

Equal to or more than 2.5 years

0

100

 

21

15

0

(In EURm)

31.12.2021

Specialised lending: income-producing real estate and high volatility commercial real estate (Slotting approach)

Regulatory categories

Remaining maturity

On-balance
sheet
exposure

Off-balance
sheet
exposure

Risk weight

Exposure
value

RWA

Expected loss amount

Category 1

Less than 2.5 years

190

1,517

50%

657

315

-

Equal to or more than 2.5 years

12

61

70%

32

22

0

Category 2

Less than 2.5 years

378

378

70%

537

331

2

Equal to or more than 2.5 years

10

3

90%

11

8

0

Category 3

Less than 2.5 years

31

53

115%

52

53

1

Equal to or more than 2.5 years

1

-

115%

1

0

0

Category 4

Less than 2.5 years

3

9

250%

7

15

0

Equal to or more than 2.5 years

1

2

250%

3

7

0

Category 5

Less than 2.5 years

15

2

-

16

-

7

Equal to or more than 2.5 years

-

-

-

-

-

-

TOTAL

Less than 2.5 years

618

1,959

 

1,269

713

11

Equal to or more than 2.5 years

24

66

 

46

38

0

TABLE 71: EQUITY EXPOSURES UNDER THE SIMPLE RISK-WEIGHTED APPROACH (CR10.5)

(In EURm)

31.12.2022

Equity exposures under the simple risk-weighted approach

Categories

On-balance
sheet
exposure

Off-balance
sheet
exposure

Risk weight

Exposure
value

RWA

Expected loss amount

Private equity exposures

1,051

-

190%

1,051

1,996

8

Exchange-traded equity exposures

56

-

290%

56

162

0

Other equity exposures

161

-

370%

161

594

4

TOTAL

1,267

-

 

1,267

2,753

13

(In EURm)

31.12.2021

Equity exposures under the simple risk-weighted approach

Categories

On-balance
sheet
exposure

Off-balance
sheet
exposure

Risk weight

Exposure
value

RWA

Expected loss amount

Private equity exposures

354

-

190%

354

673

3

Exchange-traded equity exposures

21

-

290%

21

62

0

Other equity exposures

751

-

370%

751

2,780

18

TOTAL

1,127

-

 

1,127

3,515

21

 

7 COUNTERPARTY CREDIT RISK

 

IN BRIEF

Counterparty credit risk is the risk of losses stemming from market operations, should a counterparty fail to meet its payment obligations. The future market value of the exposure and the counterparty’s credit quality are uncertain and may vary over time as underlying market parameters change.

Counterparty credit risk covers the replacement risk resulting from the default of a counterparty, the CVA (Credit Valuation Adjustment) risk related to the adjustment to the value of the Group portfolio, and the risk over central counterparties (CCP) following the clearing of market transactions. It is also affected by the wrong-way risk.

Counterparty credit risk RWA at end 2022:

€23.8bn

(Counterparty credit risk RWA at end 2021: €27.5bn)

7.1 DETERMINING LIMITS AND MONITORING FRAMEWORK

Counterparty credit risk (CCR) is driven by market transactions. Counterparty credit risk is therefore a multidimensional risk, combining credit and market risks, in the sense that the future value of the exposure to a counterparty and its credit quality are uncertain and variable in time (credit component), whilst also being impacted by changes in market parameters (market component). It can be broken down into the following categories:

default risk: it corresponds to the replacement risk to which the Societe Generale Group is exposed in the event of a counterparty’s failure to comply with its payment obligations. In this case, following the counterparty’s default SG must replace this transaction with a new transaction. Potentially, this must be done under stressed market conditions, with reduced liquidity and sometimes even facing a Wrong Way Risk (WWR);

Credit Valuation Adjustment (CVA) risk: it corresponds to the variability of the value adjustment due to counterparty credit risk, which is the market value of the CCR for derivatives and repos, that is an adjustment to the transaction price factoring in the credit quality of the counterparty. It is measured as the difference between the price of a contract with a risk-free counterparty and the price of the same contract factoring in the counterparty’s default risk;

risk on CCPs : it is related to the default of another clearing member of the central clearing house, which could result in losses for the Group on its contribution to the default fund.

Transactions involving counterparty credit risk include delivered pensions, securities lending and borrowing, and derivative contracts, whether they are dealt with principal activity or on behalf of third parties (agency activities or client clearing) in the context of market activites.

Main principles

Counterparty credit risk is framed through a set of limits that reflect the Group’s appetite for risk.

Counterparty credit risk management mainly relies on dedicated first and second lines of defence as described below:

the first lines of defence (LoD1) notably include the business lines that are subject to counterparty credit risk, the Primary Client Responsibility Unit that is in charge of handling the overall relationship with the client and the group to which it belongs, dedicated teams within the Global Banking and Advisory and the Global Markets Business Units responsible for monitoring and managing the risks within their respective scope of activities;

the Risk Department acts as a second line of defence (LoD2) through the setup of a counterparty credit risk control system, which is based on standardised risk measures, to ensure the permanent and independent monitoring of counterparty credit risks.

The fundamental principles of limit granting policy are:

dedicated LoD1 and LoD2 must be independent of each other;

the Risk Department has a division dedicated to counterparty credit risk management in order to monitor and analyze the overall risks of counterparties whilst taking into account the specificities of counterparties;

a system of delegated authorities, mainly based on the internal rating of counterparties, confers decision-making powers to LoD1 and LoD2;

the limits and internal ratings defined for each counterparty are proposed by LoD1 and validated by the dedicated LoD2(1). The limits may be set individually, at the counterparty level, or globally through framing a (sub)set of counterparties (for example: supervision of stress test exposures).

These limits are subject to annual or ad hoc reviews depending on he needs and changing market conditions.

A dedicated team within the Risk Department is in charge of production, reporting and controls on risk metrics, namely:

ensuring the completeness and reliability of the risk calculation by taking into account all the transactions booked by the transaction processing department;

producing daily certification and risk indicator analysis reports;

controlling compliance with defined limits, at the frequency of metrics calculation, most often on a daily basis: breaches of limits are reported to Front Office and dedicated LoD2 for remediation actions.

In addition, a specific monitoring and approval process is implemented for the most sensitive counterparties or the most complex categories of financial instruments.

(1)

For Hedge Funds and PTG (Proprietary Trading Group) counterparties, the rating proposal is delegated to LOD2.

Comitology

While not a substitute for CORISQ or for the Risk Committee of the Board of Directors (see the section on Risk management governance), the Counterparty Credit Risk Committee (CCRC) closely monitors counterparty credit risk through:

a global overview on exposure and counterparty credit risk metrics such as the global stress tests, the Potential Future Exposure PFE, etc., as well as focuses on specific activities such as collateralised financing, or agency business;

dedicated analysis on one or more risks or customer categories or frameworks or in case of identification of emerging risk areas.

This Committee, chaired by the Risk Department on a monthly basis, brings together representatives from the Market Activities and the Global Banking and Advisory Business Units, but also departments that, within the risk management function, are in charge of monitoring counterparty credit risks on market transactions and credit risk. The CCRC also provides an opinion on the changes to the risk frameworks within its authority. The CRCC also identifies key CCR topics that need to be escalated to the management.

Replacement risk

The Group frames the replacement risks by limits that are defined by credit analysts and validated by LoD2 based on the Group’s risk appetite.

The limits are defined at the level of each counterparty and then aggregated at the level of each client group, each category of counterparties and finally consolidated at the entire Societe Generale Group portfolio level.

The limits used for managing counterparty credit risk are:

defined at the counterparty level;

consolidated across all products types authorised with the counterparty;

established by maturity buckets to control future exposure using the Potential Future Exposure (PFE) measure also known as CVaR within Societe Generale;

calibrated according to the credit quality and the nature of the counterparty, the nature/maturity of the financial instruments contemplated (FX transactions, repos transactions, security lending transactions, derivatives, etc.), and the economic understanding, the contractual legal framework agreed and any other risk mitigants.

The Group also considers other measures to monitor replacement risk:

a multifactor stress test on all counterparties, which allows to holistically quantify the potential loss on market activities following market movements which could trigger a wave of defaults on these counterparties;

a set of single-factor stress tests to monitor the general wrong-way risk (see section “Unfavorable correlation risk”).

CVA (Credit Valuation Adjustment) risk

In addition to the replacement risk, the CVA (Credit Valuation Adjustment) measures the adjustment of the value of the Group’s derivatives and repos portfolio in order to take into account the credit quality of the counterparties facing the Group (see section “Credit Valuation Adjustment”).

Positions taken to hedge the volatility of the CVA (credit, interest rate or equity instruments) are monitored through:

sensitivity limits;

stress test limits: scenarios representative of the market risks impacting the CVA (credit spreads, interest rates, exchange rates and equity) are applied to carry out the stress test on CVA.

The different indicators and the stress tests are monitored on the net amount (the sum of the CVA exposure and of their hedges).

Risk on central counterparties

Clearing of transactions is a common market practice for SG, notably in compliance with the EMIR (European Market Infrastructure Regulation) regulations in Europe and the DFA (Dodd-Frank Act) in the United States, which require that the most standardised over-the-counter transactions be compensated via clearing houses approved by the authorities and subject to prudential regulation.

As a member of the clearing houses with which it operates, the Group contributes to their risk management framework through deposits into the defaults funds, in addition to margin calls.

The counterparty credit risk stemming from the clearing of derivatives and repos with central counterparties (CCP) is subject to a specific framework on:

initial margins, both for house and client activities (client clearing);

the Group’s contributions to the CCP default funds (guarantee deposits);

a stress test defined to capture the impact of a scenario where a major CCP member should default.

See table “EAD and RWA on central counterparties” of section 7.4 “Quantitative Information” for more information.

7.2 MITIGATION OF COUNTERPARTY CREDIT RISK ON MARKET TRANSACTIONS

The Group uses various techniques to reduce this risk:

the signing, in the most extensive way possible, of close-out netting agreements for over-the-counter (OTC) transactions and Securities Financing Transactions (SFT);

the collateralisation of market operations, either through clearing houses for eligible products (listed products and certain of the more standardised OTC products), or through a bilateral margin call exchange mechanism which covers both current exposure (variation margins) but also future exposure (initial margins).

Close-out netting agreements

Societe Generale’s standard policy is to conclude master agreements including provisions for close-out netting.

These provisions allow on the one hand the immediate termination (close out) of all transactions governed by these agreements when one of the parties defaults, and on the other hand the settlement of a net amount corresponding to the total value of the portfolio, after netting of mutual debts and claims. This balance may be the subject of a guarantee or collateralisation. It results in a single net claim owed by or to the counterparty.

In order to reduce the legal risk associated with documentation and to comply with key international standards, the Group documents these agreements under the main international standards as published by national or international professional associations such as International Swaps and Derivatives Association (ISDA), International Capital Market Association (ICMA), International Securities Lending Association (ISLA), French Banking Federation (FBF), etc.

These contracts establish a set of contractual terms generally recognised as standard and give way to the modification or addition of more specific provisions between the parties in the final contract, for example regarding the triggering events. This standardisation reduces implementation times and secures operations. The clauses negotiated by clients outside the bank’s standards are approved by the decision-making bodies in charge of the master agreements standards – Normative Committee and/or Arbitration Committee – made up of representatives of the Risk Division, the Business Units, the Legal Division and other decision-making departments of the bank. In accordance with regulatory requirements, the clauses authorising global close-out netting and collateralisation are analysed by the bank’s legal departments to ensure that they are enforceable under the legal provisions applicable to clients.

Most of over-the-counter transactions are collateralised. There are two types of collateral exchanges:

initial margin (IM) or Independent Amount (IA(1)): an initial amount of collateral aiming at covering potential future exposure, i.e. the unfavourable change in the Mark-to-Market of positions in the time period between the last collection of margins and the liquidation of positions following the counterparty default;

variation margin (VM): collateral collected to cover current exposure arising from Mark-to-Market changes, used as an approximation of the actual loss resulting from the default of one of the counterparties.

All aspects of the margining regime are defined in collateral arrangements, such as credit support annexes (CSA(2)). The main features defined are:

the scope covered (i.e. the nature of transactions allowed);

the eligible collateral and the applicable haircut: main types of collateral exchanged are cash or high-quality and liquid assets according to the Group’s policy, and are subject to a haircut, which is the valuation percentage applicable to each type of collateral, based on liquidity and price volatility of the underlying during both normal and stressed market conditions;

the timing and frequency of the calculation of the margin call and exchanges, usually daily;

the margin call thresholds if not under regulatory obligation;

the Minimum Transfer Amount (MTA).

In addition, specific parameters or optional features can be defined depending on the type of counterparty/transaction, such as an additional guarantee amount (flat-rate increase of the exposure allowing the party making a margin call to be “over-collateralised”), or rating-dependent clauses, typically mutual in nature, where additional collateral is requested in case of a party’s rating downgrade.

The Group monitors given and received collateral exchanges. In case of discrepancies between the parties with respect to margin call amounts, dedicated teams from the Operations and the Risk Departments are in charge of analysing the impacted transactions to ensure they are correctly valued and of addressing the issue.

BILATERAL COLLATERAL EXCHANGE

The initial margin, historically very rare except with hedge funds, was generalised by EMIR and DFA regulations which introduced the mandatory use of master agreements and related CSA, prior to or when entering into an uncleared OTC derivatives transactions. It is now mandatory for the Group to exchange IM and VM for non-cleared OTC derivatives transactions with a large number of its counterparties (its financial counterparties and some non-financial counterparties above certain thresholds defined by the regulation, with compliance dates depending on the volume of transactions).

The Regulatory Technical Standards (RTS) on Initial Margin Model Validation (IMMV) under EMIR allows counterparties subject to mandatory bilateral collateral exchange requirements to waive these rules in certain circumstances. The Group has incorporated a waiver application process for intra-group entities into its risk management policies. The eligibility criteria for this waiver are framed and monitored as required by the Delegated Regulation.

(1)

IA (Independent Amount) is the same concept as initial margin, but applies to different perimeters (OTC swaps not cleared for IA).

(2)

The Credit Support Annex (CSA) is a legal document under ISDA contract that regulates the management of collateral between two counterparties.

CLEARING HOUSES

EMIR and DFA regulations have also required that the most standard over-the-counter derivatives transactions be compensated through clearing houses. The Group thus compensates its own operations (principal activity), but also client clearing activities (agency-type activity), which are subject to systematic margin calls to mitigate counterparty credit risk (customers posting daily variation margins and initial margins to Societe Generale, in order to cover current exposure and future exposure).

OTHER MEASURES

In addition to margin requirements for some counterparties or mandatory clearing for the most standardised derivatives transactions, DFA and EMIR provide for an extensive framework for the regulation and transparency of OTC derivatives markets, such as reporting of OTC derivatives, timely confirmation or trade acknowledgement.

7.3 COUNTERPARTY CREDIT RISK MEASURES

REPLACEMENT RISK

The measure of replacement risk is based on an internal model that determines the Group’s exposure profiles. As the value of the exposure to a counterparty is uncertain and variable over time, we estimate the potential future replacement costs over the lifetime of the transactions.

Principles of the model

The future fair value of market transactions with each counterparty is estimated from Monte Carlo models based on a historical analysis of market risk factors.

The principle of the model is to represent the possible future financial markets conditions by simulating the evolutions of the main risk factors to which the institution’s portfolio is sensitive. For these simulations, the model uses different diffusion models to account for the characteristics inherent in the risk factors considered and uses a 10-year history for calibration.

The transactions with the various counterparties are then revalued according to these different scenarios at the different future dates until the maturity of the transactions, taking into account the terms and conditions defined in the contractual legal framework agreed and the credit mitigants, notably in terms of netting and collateralisation only to the extent we believe that the credit mitigants provisions are legally valid and enforceable.

The distribution of the counterparty exposures thus obtained allows the calculation of regulatory capital for counterparty credit risk and the economic monitoring of positions.

The Risk Department responsible for Model Risk Management at Group level, assesses the theoretical robustness (review of the design and development quality), the compliance of the implementation, the suitability of the use of the model and continuous monitoring of the relevance of the model over time. This independent review process ends with (i) a report that describes the scope of the review, the tests carried out, the results of the review, the conclusions or recommendations and (ii) review and approval Committees. This model review process gives rise to (i) recurring reports to the Risk Management Department within the framework of various Committees and processes (Group Model Risk Management Committee, Risk Appetite Statement/Risk Appetite Framework, monitoring of recommendations, etc.) and (ii) a yearly report to the Board of Directors (CORISQ).

Regulatory indicator

With respect to the calculation of capital requirements for counterparty credit risk, the ECB, following the Targeted Review of Internal Models, has renewed the approval for using the internal model described above to determine the Effective Expected Positive Exposure (EEPE) indicator.

For products not covered by the internal model as well as for entities in the Societe Generale Group that have not been authorised by the supervisor to use the internal model, the Group uses the market-price valuation method for derivatives(1) and the general financial security-based method for securities financing transactions (SFT(2)).

The effects of compensation agreements and collateralisation are taken into account either by their simulation in the internal model when such credit risk mitigant or guarantees meet regulatory criteria, or by applying the rules as defined in the market-price valuation method or the financial security-based method, by subtracting the value of the collateral.

These exposures are then weighted by rates resulting from the credit quality of the counterparty to compute the Risk Weighted Assets (RWA). These rates can be determined by the standard approach or the advanced approach (IRBA).

As a general rule, when EAD is modelled in EEPE and weighted according to IRB approach, there is no adjustment of the LGD according to the collateral received as it is already taken into account in the EEPE calculation.

The RWA breakdown for each approach is available in the “Analysis of Counterparty Credit Risk Exposure by Approach” table in Section 7.4 “Quantitative Information”.

(1)

In this method, the EAD (Exposure At Default) relating to the Bank’s counterparty credit risk is determined by aggregating the positive market values of all transactions (replacement cost) supplemented by an add-on factor.

(2)

Securities Financing Transactions.

Economic indicator

For the economic monitoring of positions, Societe Generale relies mainly on a maximum exposure indicator determined from the Monte Carlo simulation, called internally Credit Value-at-Risk (CVaR) or PFE (Potential Future Exposure). This is the maximum amount of loss that could occur after eliminating 1% of the most adverse occurrences. This indicator is calculated at different future dates, which are then aggregated into segments, each of them being framed by limits.

The Group has also developed a set of stress test scenarios to determine the exposure that would result from changes in the fair value of transactions with all its counterparties in the event of an extreme shock affecting the market parameters.

CREDIT VALUATION ADJUSTMENT

Main Principles

The CVA (Credit Valuation Adjustment) is an adjustment to marked-to-market of the derivatives and repos portfolio to take into account the credit quality of each counterparty facing the Group in the valuation. This adjustment is equivalent to the counterparty credit risk hedging cost usually based on in the Credit Default Swap (CDS) market.

For a specific counterparty, the CVA is determined on the basis of:

the positive expected exposure to the counterparty, which is the average of the positive hypothetical future exposure values for a transaction, or a group of transactions, weighted by the probability that a default event will occur. It is mainly determined using risk neutral Monte Carlo simulations of risk factors that may affect the valuation of the derivatives transactions. The transactions are revalued through time according to the different scenarios, taking into account the terms and conditions defined in the contractual legal framework agreed, notably in terms of netting and collateralisation (i.e. that transactions with appropriate credit mitigants will generate lower expected exposure compared to transactions without credit mitigants);

the probability of default of the counterparty, which is linked to the level of CDS spreads;

the amount of losses in the event of default (LGD – Loss Given Default taking into account the recovery rate).

The Group calculates this adjustment for all counterparties which are not subject to a daily margin call or for which collateral only partially covers the exposure.

Capital requirement for CVA Risk

The financial institutions are subject to the calculation of a capital requirement under the CVA, to cover its variation over ten days. The scope of counterparties is reduced to financial counterparties as defined in EMIR (European Market Infrastructure Regulation) or to certain Corporates that may use derivatives beyond certain thresholds and for purposes other than hedging.

The CVA charge is determined by the Group mainly using the advanced method:

the positive expected exposure to the counterparty is mainly determined using the internal model described in section ”Principles of the model”, which estimates the future exposure profiles to a counterparty, taking into account counterparty credit risk mitigants;

the VaR and the Stressed VaR on CVA are determined using a similar methodology to the one developed for the calculation of the market VaR (see market risk chapter). This method consists of an “historical” simulation of the change in the CVA due to fluctuations in the credit spreads observed on the counterparties in portfolio, with a confidence interval of 99%. The calculation is made on the credit spreads variation observed, on the one hand, over a one-year rolling period (VaR on CVA), and, on the other hand, over a fixed one-year historical window corresponding to the period of greatest tension in terms of credit spreads (stressed VaR on CVA);

the capital charge is the sum of two elements: VaR on CVA and Stressed VaR on CVA multiplied by a coefficient set by the regulator, specific to each bank.

The positions not taken into account in the advanced method are subject to a capital charge determined through the standard method by applying a normative weighting factor to the product of the EAD (Exposure At Default) by a maturity calculated according to the rules defined by the CRR (Capital Requirement Regulation); see the “Transactions subject to own funds requirements for CVA risk” table in Section 7.4 “Quantitative Information” for the breakdown of CVA-related RWA between advanced and standard methods.

CVA Risk Management

The management of this exposure and of this regulatory capital charge led the Bank to purchase hedging instruments such as Credit Default Swap (CDS) from large credit institutions on certain identified counterparties or on indices composed of identifiable counterparties. In addition to reducing credit risk, it decreases the variability of the CVA and the associated capital amounts resulting from fluctuations in counterparty credit spreads.

The CVA desk (or the Societe Generale Group) also handles instruments for hedging interest rate or foreign exchange risks, which helps to limit the variability of the CVA’s share from positive exposure.

UNFAVORABLECORRELATION RISK (WRONG-WAY RISK)

Wrong-way risk is the risk of the Group’s exposure to a counterparty increasing significantly, combined with a simultaneous increase in the probability of the counterparty defaulting.

There are two different cases:

general wrong-way risk arises when the likelihood of default by counterparties is positively correlated with general market risk factors;

specific wrong-way risk arises when future exposure to a specific counterparty is positively correlated with the counterparty’s probability of default due to the nature of the transaction with the counterparty.

Specific wrong-way risk, in the case of a legal link between the counterparty and the underlying of a transaction concluded with the counterparty, is subject to dedicated regulatory capital requirements, calculated on the perimeter of transactions carrying such risk. Furthermore, for counterparties subject to such a specific risk, the Potential Future Exposure (PFE) is also increased, so that the transactions allowed by the limits in place will be more constrained than in the absence of specific risk.

The general wrong-way risk is controlled via a set of stress tests applied to transactions made with a given counterparty, based on scenarios common with the market stress tests. This set-up is based on:

a quarterly analysis of stress tests on all counterparties (financial institutions, corporates, sovereigns, hedge funds and proprietary trading groups) for principal and agency (client clearing) businesses, allowing to understand the most adverse scenarios related to a joint deterioration in the quality of counterparties and the associated positions;

a weekly monitoring of dedicated single-factor stress tests for hedge fund counterparties and Proprietary Trading Groups, subject to limits at the counterparty level.

7.4 QUANTITATIVE INFORMATION

TABLE 72: COUNTERPARTY CREDIT RISK EXPOSURE, EAD AND RWA BY EXPOSURE CLASS AND APPROACH

Counterparty credit risk is broken down as follows:

(In EURm)

31.12.2022

IRB

Standard

Total

Exposure classes

Exposure

EAD

RWA

Exposure

EAD

RWA

Exposure

EAD

RWA

Sovereign

44,698

44,696

235

2,551

2,551

33

47,249

47,247

267

Institutions

18,979

18,994

3,574

31,948

32,019

613

50,927

51,013

4,187

Corporates

55,555

55,543

13,027

2,972

2,901

2,808

58,527

58,444

15,835

Retail

68

68

7

21

21

14

89

89

21

Other

-

-

-

3,514

3,514

688

3,514

3,514

688

TOTAL

119,300

119,300

16,842

41,006

41,006

4,155

160,306

160,306

20,998

(In EURm)

31.12.2021

IRB

Standard

Total

Exposure classes

Exposure

EAD

RWA

Exposure

EAD

RWA

Exposure

EAD

RWA

Sovereign

24,471

24,511

395

177

177

4

24,648

24,688

399

Institutions

16,653

16,727

3,664

38,068

38,363

960

54,721

55,090

4,624

Corporates

56,698

56,583

14,554

4,441

4,147

4,051

61,139

60,730

18,605

Retail

83

83

8

23

23

14

106

106

21

Other

7

7

2

4,295

4,295

1,022

4,302

4,302

1,023

TOTAL

97,912

97,912

18,622

47,004

47,004

6,051

144,916

144,916

24,673

The tables above feature amounts excluding the CVA (Credit Valuation Adjustment) which represents EUR 2.8 billion of risk-weighted assets (RWA) at 31 December 2022 (vs. EUR 2.8 billion at 31 December 2021).

TABLE 73: ANALYSIS OF COUNTERPARTY CREDIT RISK EXPOSURE BY APPROACH (CCR1)

(In EURm)

31.12.2022

Replacement

cost (RC)

Potential

future

exposure

(PFE)

EEPE

Alpha

used for

computing

regulatory

exposure

value

Exposure

value

pre-CRM

Exposure

value

post-CRM

Exposure

value

RWA

Original Exposure Method (for derivatives)

-

-

 

1

-

-

-

-

Simplified SA-CCR (for derivatives)

-

-

 

1

-

-

-

-

SA-CCR (for derivatives)

1,938

35,665

 

1

92,752

52,644

52,645

6,649

IMM (for derivatives and SFTs)

 

 

38,283

2

444,207

63,311

63,348

12,381

of which securities financing transactions netting sets

 

 

18,727

 

370,235

29,089

29,089

2,137

of which derivatives and long settlement transactions netting sets

 

 

19,493

 

72,565

34,113

34,151

10,239

of which from contractual cross-product netting sets

 

 

62

 

1,407

109

109

5

Financial collateral simple method
(for SFTs)

 

 

 

 

-

-

-

-

Financial collateral comprehensive method (for SFTs)

 

 

 

 

23,324

11,291

11,291

1,050

VaR for SFTs

 

 

 

 

-

-

-

-

TOTAL

 

 

 

 

560,282

127,246

127,284

20,080

(In EURm)

31.12.2021

 

Replacement cost (RC)

Potential future exposure (PFE)

EEPE

Alpha used for computing regulatory exposure value

Exposure value pre-CRM

Exposure value post-CRM

Exposure value

RWA

Original Exposure Method (for derivatives)

-

-

 

1

-

-

-

-

Simplified SA-CCR (for derivatives)

-

-

 

1

-

-

-

-

SA-CCR (for derivatives)

2,027

20,727

 

1

67,282

31,808

31,794

9,304

IMM (for derivatives and SFTs)

 

 

35,417

2

472,121

62,416

62,322

13,088

of which securities financing transactions netting sets

 

 

16,892

 

395,150

28,067

28,067

2,142

of which derivatives and long settlement transactions netting sets

 

 

18,453

 

76,847

34,217

34,123

10,946

of which from contractual cross-product netting sets

 

 

71

 

124

132

132

-

Financial collateral simple method
(for SFTs)

 

 

 

 

-

-

-

-

Financial collateral comprehensive method (for SFTs)

 

 

 

 

27,145

11,245

11,245

994

VaR for SFTs

 

 

 

 

-

-

-

-

TOTAL

 

 

 

 

566,548

105,470

105,361

23,385

TABLE 74: EXPOSURES TO CENTRAL COUNTERPARTIES (CCR8)

(In EURm)

31.12.2022

31.12.2021

Exposure value

RWA

Exposure value

RWA

Exposures to QCCPs (total)

 

918

 

1,273

Exposures for trades at QCCPs (excluding initial margin and default fund contributions), of which:

7,443

149

7,083

142

(i) OTC derivatives

2,190

44

759

15

(ii) Exchange-traded derivatives

4,025

81

5,866

117

(iii) SFTs

1,022

20

457

9

(iv) Netting sets where cross-product netting has been approved

206

4

-

-

Segregated initial margin

18,063

 

22,466

 

Non-segregated initial margin

4,002

80

5,555

111

Pre-funded default fund contributions

3,199

688

3,992

1,020

Unfunded default fund contributions

-

-

-

-

Exposures to non-QCCPs

 

-

 

-

Exposures for trades at non-QCCPs (excluding initial margin and default fund contributions), of which:

-

-

-

-

(i) OTC derivatives

-

-

-

-

(ii) Exchange-traded derivatives

-

-

-

-

(iii) SFTs

-

-

-

-

(iv) Netting sets where cross-product netting has been approved

-

-

-

-

Segregated initial margin

-

 

-

 

Non-segregated initial margin

-

-

-

-

Pre-funded default fund contributions

-

-

-

-

Unfunded default fund contributions

-

-

-

-

TABLE 75: COMPOSITION OF COLLATERAL FOR COUNTERPARTY CREDIT RISK EXPOSURES (CCR5)

(In EURm)

31.12.2022

Collateral used
in derivative transactions

Collateral used
in SFTs

Fair value
of collateral received

Fair value
of posted collateral

Fair value
of collateral received

Fair value
of posted collateral

Segragated

Unsegragated

Segragated

Unsegragated

Segragated

Unsegragated

Segragated

Unsegragated

Cash – domestic currency

24,446

24,805

12,873

23,346

-

45,204

-

51,338

Cash – other currencies

92,277

42,543

24,813

72,493

-

6,874

-

16,033

Domestic sovereign debt

-

1

-

-

-

196

-

99

Other sovereign debt

20

-

-

-

-

8,763

-

4,446

Government agency debt

15,260

4,684

144

1,796

-

312,749

-

299,469

Corporate bonds

2

132

-

-

-

6,873

-

6,652

Equity securities

690

13

0

37

-

31,642

-

60,190

Other collateral

519

122

-

3

-

19,574

-

20,122

TOTAL

133,214

72,300

37,830

97,675

-

431,875

-

458,348

(In EURm)

31.12.2021

Collateral used
in derivative transactions

Collateral used
in SFTs

Fair value
of collateral received

Fair value
of posted collateral

Fair value
of collateral received

Fair value
of posted collateral

Segragated

Unsegragated

Segragated

Unsegragated

Segragated

Unsegragated

Segragated

Unsegragated

Cash – domestic currency

26,297

24,408

10,412

24,984

-

28,639

-

35,368

Cash – other currencies

98,096

53,981

44,928

69,676

-

4,483

-

8,383

Domestic sovereign debt

-

-

-

-

-

15

-

1

Other sovereign debt

15

-

-

-

-

4,931

-

6,451

Government agency debt

9,487

2,230

38

1,859

-

229,891

-

207,411

Corporate bonds

8

44

-

-

-

6,493

-

5,157

Equity securities

556

-

0

84

-

2,833

-

17,760

Other collateral

438

113

-

12

-

39,818

-

42,783

TOTAL

134,897

80,777

55,378

96,616

-

317,101

-

323,314

(In EURm)

31.12.2022

31.12.2021

Exposure value

RWA

Exposure value

RWA

Total transactions subject to the Advanced Method

36,947

2,222

33,066

2,218

(i) VaR component (including the 3×multiplier)

 

329

 

193

(ii) Stressed VaR component (including the 3×multiplier)

 

1,893

 

2,025

Transactions subject to the Standardised Method

8,665

582

6,812

589

Transactions subject to the Alternative approach
(based on Original Exposure Method)

-

-

-

-

Total transactions subject to own funds requirements for CVA risk

45,612

2,805

39,878

2,807

TABLE 77: INTERNAL APPROACH – COUNTERPARTY CREDIT RISK EXPOSURES BY EXPOSURE CLASS AND PD SCALE (CCR4)

The table below presents Group exposures subject to counterparty credit risk and for which an internal model is used with a view to calculating RWA. In accordance with EBA instructions, CVA charges and exposures cleared through CCPs have been excluded.

(In EURm)

31.12.2022

PD scale

Exposure

value

Exposure

weighted

average

PD (%)

Number of

obligors

Exposure

weighted

average

LGD (%)

Exposure

weighted

average

maturity

(years)

RWA

RWA

density

Central governments
and central banks

0.00 to < 0.15

44,390

0.01%

105

0.76%

1

61

0.14%

0.15 to < 0.25

-

-

-

-

0

-

-

0.25 to < 0.50

122

0.26%

9

23.98%

1

35

28.31%

0.50 to < 0.75

-

-

-

-

-

-

-

0.75 to < 2.50

110

2.06%

2

19.41%

1

49

44.70%

2.50 to < 10.00

5

4.22%

9

42.72%

1

5

106.19%

10.00 to < 100.00

69

17.90%

8

28.34%

0

85

122.92%

100.00 (default)

-

-

-

-

-

-

-

Subtotal

44,696

0.04%

133

0.92%

1

235

0.53%

Institutions

0.00 to < 0.15

16,561

0.05%

691

33.29%

1

2,001

12.08%

0.15 to < 0.25

-

-

-

-

-

-

-

0.25 to < 0.50

933

0.25%

95

37.75%

1

379

40.59%

0.50 to < 0.75

434

0.49%

77

43.86%

2

364

83.72%

0.75 to < 2.50

310

1.46%

112

40.88%

2

296

95.51%

2.50 to < 10.00

620

3.48%

117

25.45%

1

467

75.37%

10.00 to < 100.00

39

13.14%

62

34.91%

0

67

170.42%

100.00 (default)

96

100.00%

5

100.00%

2

-

-

Subtotal

18,994

0.73%

1,159

33.96%

1

3,574

18.82%

Corporate

0.00 to < 0.15

43,665

0.06%

4,783

34.69%

1

5,025

11.51%

0.15 to < 0.25

2

0.17%

12

38.61%

1

0

23.30%

0.25 to < 0.50

3,003

0.28%

790

30.88%

2

1,033

34.41%

0.50 to < 0.75

2,295

0.51%

1,002

34.15%

2

1,749

76.21%

0.75 to < 2.50

3,803

1.58%

1,767

31.60%

2

2,482

65.27%

2.50 to < 10.00

2,551

4.22%

2,318

31.46%

2

2,357

92.38%

10.00 to < 100.00

151

14.29%

328

32.12%

2

232

153.53%

100.00 (default)

72

92.30%

80

50.44%

2

148

206.45%

Subtotal

55,543

0.54%

11,080

34.11%

1

13,027

23.45%

Retail

0.00 to < 0.15

-

-

-

-

-

-

-

0.15 to < 0.25

-

-

-

-

-

-

-

0.25 to < 0.50

66

-

955

28.62%

-

6

8.87%

0.50 to < 0.75

0

-

230

37.50%

-

0

53.05%

0.75 to < 2.50

-

-

-

-

-

-

-

2.50 to < 10.00

-

-

-

-

-

-

-

10.00 to < 100.00

1

-

1

24.00%

-

1

63.71%

100.00 (default)

-

-

-

-

-

-

-

Subtotal

68

-

1,186

28.57%

-

7

9.99%

TOTAL

 

119,300

0.38%

13,558

21.65%

1

16,842

14.12%

(In EURm)

31.12.2021

PD scale

Exposure

value

Exposure

weighted

average

PD (%)

Number of

obligors

Exposure

weighted

average

LGD (%)

Exposure

weighted

average

maturity

(years)

RWA

RWA

density

Central governments
and central banks

0.00 to < 0.15

24,235

0.02%

102

2.83%

1

231

0.95%

0.15 to < 0.25

-

 

-

 

 

-

 

0.25 to < 0.50

73

0.26%

7

27.53%

2

22

29.73%

0.50 to < 0.75

18

-

1

-

5

-

-

0.75 to < 2.50

127

2.12%

1

20.00%

1

58

46.07%

2.50 to < 10.00

24

5.59%

14

31.79%

2

45

187.34%

10.00 to < 100.00

35

16.13%

7

23.20%

1

39

112.82%

100.00 (default)

-

 

-

 

 

-

 

Subtotal

24,511

0.06%

132

3.05%

1

395

1.61%

Institutions

0.00 to < 0.15

13,501

0.05%

693

34.00%

2

1,936

14.34%

0.15 to < 0.25

-

 

-

 

 

-

 

0.25 to < 0.50

788

0.26%

101

40.62%

2

386

49.00%

0.50 to < 0.75

657

0.50%

79

43.09%

2

446

67.88%

0.75 to < 2.50

1,232

1.97%

109

10.97%

1

304

24.70%

2.50 to < 10.00

505

3.85%

125

31.09%

1

512

101.29%

10.00 to < 100.00

44

13.19%

59

33.49%

1

80

180.28%

100.00 (default)

-

 

-

 

 

-

 

Subtotal

16,727

0.37%

1,166

32.88%

2

3,664

21.90%

Corporate

0.00 to < 0.15

41,669

0.05%

4,625

33.99%

1

5,306

12.73%

0.15 to < 0.25

13

0.20%

28

15.85%

1

1

10.84%

0.25 to < 0.50

3,408

0.26%

789

28.09%

3

1,097

32.18%

0.50 to < 0.75

4,234

0.52%

956

29.61%

3

1,823

43.05%

0.75 to < 2.50

3,816

1.56%

1,657

27.81%

3

2,422

63.49%

2.50 to < 10.00

2,851

4.13%

1,915

31.37%

2

3,053

107.09%

10.00 to < 100.00

444

13.70%

364

32.18%

3

696

156.95%

100.00 (default)

149

100.00%

70

43.30%

3

155

104.10%

Subtotal

56,583

0.77%

10,404

32.76%

1

14,554

25.72%

Retail

0.00 to < 0.15

-

 

-

 

 

-

 

0.15 to < 0.25

10

0.20%

975

11.50%

-

0

4.94%

0.25 to < 0.50

72

0.27%

82

17.36%

-

6

8.84%

0.50 to < 0.75

0

0.53%

47

28.75%

-

0

22.64%

0.75 to < 2.50

-

 

-

 

 

-

 

2.50 to < 10.00

-

 

-

 

 

-

 

10.00 to < 100.00

2

27.25%

1

24.00%

-

1

65.96%

100.00 (default)

-

 

-

 

 

-

 

Subtotal

83

0.75%

1,105

16.82%

-

8

9.45%

TOTAL

 

97,905

0.52%

12,807

25.33%

1

18,620

19.02%

TABLE 78: STANDARDISED APPROACH – COUNTERPARTY CREDIT RISK EXPOSURES BY REGULATORY EXPOSURE CLASS AND RISK WEIGHTS (CCR3)

In accordance with EBA instructions, the amounts are presented without securitisation.

(In EURm)

31.12.2022

Risk weight

Exposure

Classes

0%

2%

4%

10%

20%

50%

70%

75%

100%

150%

Others

Total

exposure

value

Central governments
or central banks 

2,529

-

-

-

-

-

-

-

-

 22

-

2,551

Regional government or local authorities 

-

-

-

-

 7

-

-

-

-

-

-

 7

Public sector entities

-

-

-

-

 80

-

-

-

 8

-

 0

 88

Multilateral development banks

-

-

-

-

-

-

-

-

-

-

-

-

International organisations

-

-

-

-

-

-

-

-

-

-

-

-

Institutions

18,066

12,707

 0

-

 835

 243

-

-

 43

-

 30

31,925

Corporates

 0

 86

-

-

 1

 22

-

-

2,772

 21

 0

2,901

Retail

-

-

-

-

-

-

-

 21

 0

-

 0

 21

Institutions and corporates with
a short-term credit assessment

-

-

-

-

-

-

-

-

-

-

-

-

Other items

-

-

-

-

-

-

-

-

-

 0

-

 0

TOTAL

20,595

12 793

 0

-

 922

 266

-

 21

2,823

 43

 31

37,492

(In EURm)

31.12.2021

Risk weight

Exposure

Classes

0%

2%

4%

10%

20%

50%

70%

75%

100%

150%

Others

Total

exposure

value

Central governments
or central banks 

172

-

-

-

-

-

-

-

4

-

-

176

Regional government or local authorities 

-

-

-

-

-

-

-

-

-

-

-

-

Public sector entities

-

-

-

-

83

0

-

-

28

-

0

112

Multilateral development banks

-

-

-

-

-

-

-

-

0

-

-

0

International organisations

-

-

-

-

-

-

-

-

-

-

-

-

Institutions

22,466

13,767

0

-

1,485

373

-

-

156

-

4

38,251

Corporates

-

74

-

-

-

40

-

-

4,032

-

1

4,147

Retail

-

-

-

-

-

-

-

23

0

-

0

23

Institutions and corporates with
a short-term credit assessment

-

-

-

-

-

-

-

-

-

-

-

-

Other items

-

-

-

-

-

-

-

-

-

1

0

1

TOTAL

22,638

13,841

0

-

1,568

413

-

23

4,220

1

5

42,710

TABLE 79: CREDIT DERIVATIVES EXPOSURES (CCR6)

(In EURm)

31.12.2022

Credit derivative hedges

Protection bought

Protection sold

Notionals

 

 

Single-name credit default swaps

32,105

45,529

Index credit default swaps

21,592

15,343

Total return swaps

6,226

-

Credit options

1,091

 740

Other credit derivatives

6,099

3,303

TOTAL NOTIONALS

67,113

64,915

Fair values

 

 

Positive fair value (asset)

1,319

 848

Negative fair value (liability)

(991)

(741)

(In EURm)

31.12.2021

Credit derivative hedges

Protection bought

Protection sold

Notionals

 

 

Single-name credit default swaps

40,954

53,351

Index credit default swaps

27,164

22,736

Total return swaps

3,059

-

Credit options

734

954

Other credit derivatives

10,519

3,326

TOTAL NOTIONALS

82,429

80,366

Fair values

 

 

Positive fair value (asset)

374

2,105

Negative fair value (liability)

(2,100)

(420)

TABLE 80: RWA FLOW STATEMENT OF COUNTERPARTY CREDIT RISK EXPOSURES UNDER THE IMM (CCR7)

IMM is the internal model method applied to calculate exposures to counterparty credit risk. The banking models used are subject to approval of the supervisor.

The application of these internal models has an impact on the method used to calculate the EAD of market transactions but also on the Basel maturity calculation method.

(In EURm)

RWA

RWA as at end of previous reporting period (30.09.2022)

17,226

Asset size

(829)

Credit quality of counterparties

(36)

Model updates (IMM only)

-

Methodology and policy (IMM only)

-

Acquisitions and disposals

-

Foreign exchange movements

(3,886)

Other

-

RWA as at end of reporting period (31.12.2022)

12,475

The table above displays data without CVA (Credit Valuation Adjustment) which amounts to EUR 2.2 billion in advanced method.

 

8 SECURITISATION

 

IN BRIEF

This section provides information on Societe Generale’s securitisation positions, which have already been incorporated into the relevant sections (credit risk and market risk).

They are subject to specific capital requirements according to European regulations.

Regulatory capital requirements for securitisations in the Banking Book at end 2022

€583.3m

(Amount at end 2021: €509m)

Regulatory capital requirements for securitisations in the Trading Book at end 2022

€12m

(Amount at end 2021: €45m)

8.1 SECURITISATIONS AND REGULATORY FRAMEWORK

This section presents information on Societe Generale’s securitisation activities, acquired or carried out for proprietary purposes or for its customers. It describes the risks associated with these activities and the management of those risks. Finally, it contains quantitative information to describe these activities during 2021, as well as the capital requirements for the Group’s regulatory banking book and trading book within the scope defined by prudential regulations.

As defined in prudential regulations, the term securitisation refers to a transaction or scheme, whereby the credit risk associated with an exposure or pool of exposures is divided into tranches, having the following characteristics :

the transaction achieves significant risk transfer, in case of origination;

payments in the transaction or scheme are contingent on the performance of the exposure or pool of exposures;

subordination of some tranches determines the distribution of losses during the ongoing life of the transaction or risk transfer scheme.

The securitisation transactions are subject to the regulatory treatment defined:

in Regulation (EU) No 2017/2401 amending Regulation (EU) No 575/2013 relating to the capital requirements applicable to credit institutions and to credit and investment firms;

in Regulation (EU) No 2017/2402 creating a general framework for securitisation as well as a specific framework for simple, transparent, and standardised securitisations (STS).

Regulation No 2017/2401 presents the hierarchy of methods for weighting securitisation positions (see section 8.6). The floor weighting rate is 15% (10% for STS securitisations).

Regulation No 2017/2402 defines the criteria for the identification of “simple, transparent and standardised” (STS) securitisations to which specific and lower capital charges are applicable. The text also specifies the authorisation procedure for third-party organisations that will be involved in ensuring compliance with requirements relating to STS securitisations. The risk retention requirement for the transferor is set at a minimum level of 5%.

The securitisatin framework has been amended by 2 new regulations published on April 6th, 2021:

regulation (EU) 2021/557 amending regulation (EU) 2017/2402 and creating a specific STS framework for synthetic on-balance sheet securitisations;

regulation (EU) 2021/558 amending regulation (EU) no 575/2013, a specific prudential framework for non-performing exposures (NPE) securitisations.

Guidelines or Regulatory Technical Standards issued by the technical authorities, ESMA and the EBA, clarify some aspects of the level 1 European regulations.

8.2 ACCOUNTING METHODS

The securitisation transactions that Societe Generale invests in (i.e. the Group invests directly in certain securitisation positions, is a liquidity provider or a counterparty of derivative exposures) are recognised in accordance with Group accounting principles, as set forth in the notes to the consolidated financial statements included in the 2021 Universal Registration Document.

In the financial statements, the classification of securitisation positions depends on their contractual characteristics and the way the entity manages those financial instruments.

When analysing the contractual cash flow of financial assets issued by a securitisation vehicle, the entity must analyse the contractual terms, as well as the credit risk of each tranche and the exposure to credit risk in the underlying pool of financial instruments. To that end, the entity must apply a “look-through approach” to identify the underlying instruments that are creating the cash flows.

Contractual flows that represent solely payments of principal and interest on the principal amount outstanding are consistent with a basic lending arrangement (SPPI flows: Solely Payments of Principal and Interest).

In the financial statements, the basic securitisation positions (SPPI) are classified into two categories, depending on the business model used to managed them:

when they are managed under a “Collect and Sell” business model, the positions are classified as “Financial assets at fair value through other comprehensive income”. Accrued or earned income on these positions is recorded in profit or loss based on the effective interest rate, under Interest and similar income. At the reporting date, these instruments are measured at fair value, and changes in fair value, excluding income, are recorded under Unrealised or deferred gains and losses. Furthermore, as these financial assets are subject to impairment for credit risk, changes in expected credit losses are recorded in profit or losses under Cost of risk with a corresponding entry to Unrealised or deferred gains and losses;

when they are managed under a “Hold to Collect” business model, the positions are measured at amortised cost. Subsequent to initial recognition, these positions are measured at amortised cost using the effective interest method, and their accrued or earned income is recorded in the income statement under Interest and similar income. Furthermore, as these financial assets are subject to impairment for credit risk, changes in expected credit losses are recorded in profit or loss under Cost of risk with a corresponding impairment of amortised cost under balance sheet assets.

The securitisation positions that are not basic (non–SPPI) will be measured at fair value through profit or loss, regardless of the business model for managing them.

At the balance sheet date, these assets are recorded in the balance sheet under Financial assets at fair value through profit or loss and changes in the fair value of these instruments (excluding interest income) are recorded in the income statement under Net gains or losses on financial instruments at fair value through profit or loss.

Interest income and expense are recorded in the income statement under Interest and similar income and Interest and similar expense.

Securitisation positions classified among the financial assets at amortised cost or among the financial assets at fair value through other comprehensive income, are systematically subject to impairment or a loss allowance for expected credit losses. These impairments and loss allowances are booked on initial recognition of the assets, without waiting for objective evidence of impairment to occur.

To determine the amount of impairment to be recorded at each reporting date, these assets are classified into one of three categories based on the increase in credit risk observed since initial recognition. Stage 1 exposures are impaired for the amount of credit losses that the Group expects to incur within 12 months; Stages 2 and 3 exposures are impaired for the amount of credit losses that the Group expects to incur over the life of the exposures.

For securitisation positions measured at fair value through profit or loss, their fair value includes already the expected credit loss, as assessed by the market participant, on the residual lifetime of the instrument.

Reclassification of securitisation positions is only required in the exceptional event that the Group changes the business model used to manage these assets.

Synthetic securitisations in the form of Credit Default Swaps follow accounting recognition rules specific to trading derivatives.

The securitisation transactions are derecognised when the contractual rights to the cash flows on the asset expire or when the Group has transferred the contractual rights to receive the cash flows and substantially all the risks and rewards linked to the ownership of the asset. Where the Group has transferred the cash flows of a financial asset but has neither transferred nor retained substantially all the risks and rewards of its ownership and has effectively not retained control of the financial asset, the Group derecognises it and, where necessary, recognises a separate asset or liability to cover any rights and obligations created or retained because of transferring the asset. If the Group has retained control of the asset, it continues to recognise it in the balance sheet to the extent of its continuing involvement in that asset.

Securitisation of securitised assets recognised in the Group balance sheet follow the same accounting treatment described above.

When a financial asset is derecognised in its entirety, a gain or loss on disposal is recorded in the income statement for an amount equal to the difference between the carrying value of the asset and the payment received for it, adjusted where necessary for any unrealised profit or loss previously recognised directly in equity.

8.3 STRUCTURED ENTITIES’ SPECIFIC CASE

A structured entity is an entity that has been designed so that voting or similar rights are not the dominant factor in deciding who controls the entity.

When assessing the existence of a control over a structured entity, all facts and circumstances shall be considered, among which:

the purpose and design of the entity;

the structuring of the entity (especially, the power to direct the relevant activities of the entity);

risks to which the entity is exposed by way of its design and the Group’s exposure to some or all of these risks;

potential returns and benefits for the Group.

Unconsolidated structured entities are those that are not exclusively controlled by the Group.

Within the framework of the consolidation of structured entities that are controlled by the Group, the shares of those entities that are not held by the Group are recognised under “Debt” in the balance sheet.

When customer loans are securitised and partially sold to external investors, the entities carrying the loans are consolidated if the Group retains control and remains exposed to the majority of the risks and benefits associated with these loans.

Any financial support outside of any binding contractual arrangement provided to unconsolidated entities, over securitised assets, would be recognised as a liability on balance sheet if it met the relevant IFRS criteria, or gave rise to a provision under IAS 37, and must be disclosed.

8.4 MANAGEMENT OF SECURITISATION RISKS

The management of risks associated with securitisation operations follows the rules established by the Group depending on whether these assets are recorded in the banking book (credit and counterparty credit risks) or in the trading book (market risk and counterparty credit risk).

The securitisation risk is monitored by the Client Relations and Financing and Advisory Solutions department (Global Banking & Advisory - GLBA) and, in respect of transactions for own account, by the Group Treasury Department of the Financial Department [DFIN / GTR / FUN] in LoD1 and supervised in the credit risk management system by the “Corporate and Investment Banking” division (CIB) of the Risks department in LoD2.

ROLE OF GLOBAL BANKING AND ADVISORY (GLBA)

Only the Asset-Backed Products division of GLBA has the mandate to deal with transactions generating securitisation risk.

These operations consist in:

structuring and/or primary distribution of ABS (Asset-Backed Securities), which can take the form of RMBS (Residential Mortgage-Backed Securities), CMBS (Commercial Mortgage-Backed Securities) and CLOs (Collateralised Loan Obligations), structured or co-arranged by Societe Generale, for the benefit of issuers (companies and specialised financial companies) also called “public securitisation”. These transactions do not generate any securitisation risk for the Group if no exposure is retained by Societe Generale;

financing of customer needs, via commercial paper backed by assets issued by Societe Generale conduits or, marginally, on the balance sheet, also called “private securitisation”. These activities generate credit risk for Societe Generale and are overseen by the “Corporate and Investment Banking” (CIB) division of the Risk Department;

structuring of securitisation transactions for its own (i.e., the underlying portfolio consisting of receivables booked on the Group’s balance sheet). This activity does not generate additional credit risk for the Group; the role of the Corporate and Investment Banking (CIB) division of the Risk Department [RISQ / CIB] is to ensure that the structure is robust;

securitised products are also used as underlying on the secondary market in collateralised financing and trading transactions. These transactions generate both credit risk and market risk for the Group and are overseen by the “Corporate and Investment Banking” (CIB) and the Risks on Market Activities divisions of the Risk Department.

ROLE OF THE RISK DEPARTMENT

The Risk Department, within the framework of various CORISQs chaired by General Management and in compliance with the risk appetite of Societe Generale group, formalises, jointly with the “Global Banking and Advisory” department, the Group’s risk appetite with regard to securitisation activities.

These frameworks are established by type of product (primary securitisation, sale of securitisation products in secondary, collateralised financing, etc.) and aim to define the acceptable level of risk with regard to the Group’s strategic objectives via limits and guidelines for granting credit.

The role and responsibilities of the Risk Department are divided according to the main risk (credit or market).

The Risk Department contributes to the definition of risk policies, taking into account the objectives of the business lines and the corresponding risk issues.

The Risk Department defines or validates the methods and procedures for analysing, measuring, approving and monitoring risks and, ultimately, ensures that they are in line with the needs of the businesses.

The Risk Department validates the operations transactions and certain limits, the others being presented in CORISQ proposed by Business Managers.

The Business Unit does not have signing authority delegations for securitisation risk. Only certain authorised persons within RISQ can approve a transaction generating securitisation risk.

CREDIT RISK

Securitisation exposures subject to credit risk are approved through the Group’s standard credit approval process. New operations are presented by the business lines (LoD1) to the Risk Department, after approval by the business line manager. The Risk Department gives its opinion on these new transactions, which are approved according to the delegations in force. All exhibitions are subject to an annual review by the business line and the Risk Department.

The rating of the transaction and the borrower as well as the LGD are therefore subject to an initial validation and an annual review for each transaction. In particular, the data used within the framework of the IAA (Internal Assessment Approach) securitisation model and the result of the calculations of this model are subject to specific validation. Regular monitoring is carried out independently of the business line and portfolio reviews are produced quarterly specifically on the bank’s securitisation exposures. This monitoring makes it possible to identify any changes in the behaviour of securitised assets.

Portfolio-level limits are granted by the Risk Committee for securitisation exposures. Stress tests are also carried out on these portfolios.

The analysis of the credit risk of securitisation transactions covers the standard elements of credit risk: the performance of the underlying assets as well as that of the assignor/collector. Risk factors are reduced by structural elements of each transaction including default triggers, excess spread, delinquencies, segregated accounts and back-up collector. The monitoring of the credit risk on these transactions, of the performance of the underlying assets and of the covenants, is reviewed at portfolio level by the “Corporate and Investment Banking” division of the Risks department. each quarter during the Quarterly Portfolio Review prepared by the “Global Business Service Unit” with a focus on major events and sent to the “Corporate and Investment Banking” division of the Risk Department with a presentation in session every other quarter. A follow-up at the level of each transaction is carried out in detail each year during the Annual Review with a revalidation of the rating of the transaction.

Resecuritisation exposures go through the same approval and monitoring process.

MARKET RISK

Securitisation exposures subject to market risk are monitored and controlled through Societe Generale’s market risk standard market approval process, with additional controls specific to securitisation.

The analysis of the market risk of securitisation transactions covers the standard elements of market risk: credit, spread, liquidity risk, interest rate risk (hedged with standard liquid interest rate instruments (US Treasuries, Eurodollar futures, interest rate swaps)).

Securitisation exposures are subject to strict supervision through the setting of limits on specific assets in the securitisation field (CMBS, CLO, RMBS, ABS), according to several types of indicators:

Value at risk (VaR) and Stressed value at risk (SVaR): synthetic indicators, allowing day-to-day monitoring of market risk;

stress test measurements, based on ten-year risk type indicators. These metrics make it possible to limit the Group’s exposure to systemic risks and cases of exceptional market shocks impacting securitisation activities;

“sensitivity” and “nominal” indicators, which allow the size of positions to be controlled;

other specific indicators: nominal limits on the sizes of ABS market-making inventories, cash at risk and stress test limits on financing activities collateralised by ABS, which makes it possible in particular to monitor the behaviour of the underlying assets under stress and supervise the Group’s exposure in the event of market shocks.

The Risk Department on Market Operations is in charge of examining limit requests made by the front office. These limits make it possible to ensure that the Group respects the appetite for the market validated by the Board of Directors, on a proposal from General Management.

The daily monitoring of compliance with the limits by the front office is carried out by the Risk Department on market transactions. This continuous monitoring of the risk profile is the subject of frequent exchanges between the risk and business teams, which may result in various positions hedging actions by the front office aimed at reducing the level of risk of complying with the framework defined. In the event of an overrun, the front office must detail the reasons for the management concerned, and take the necessary measures to return to the defined framework, or otherwise request a temporary or permanent increase in the limit if customer demand, market conditions or risk assessment justify it.

Resecuritisation exposures go through the same approval and monitoring process.

STRUCTURAL RISKS

The management of structural interest rate and change risks in securitisation activities does not differ from that of other Group assets.

The management of the structural interest rate risk is described in Chapter 11 of this document.

The liquidity risk linked to securitisation activities is monitored both at the level of the responsible business lines but also, centrally, at the level of the Finance Department, with in particular the measurement of the impact of these activities on liquidity ratios, stress tests and the Group’s liquidity gaps. The organisation and management of liquidity risk are covered in Chapter 12 of this document.

OPERATIONAL RISK

The monitoring of operational risk on securitisation activities is taken into account in the Group’s operational risk management systems. Thus, the operational risks on these activities are notably regulated by the limits of the appetite for operational risk, identified and assessed by the Risk Control Self-Assessment exercise and any incidents are collected and analysed according to Group standards. The management of operational risk is described in Chapter 10 of this document.

8.5 SOCIETE GENERALE’S SECURITISATION ACTIVITIES

Securitisation activities allow the Group to raise liquidity or manage risk exposures, for proprietary purposes or on behalf of customers. Within the framework of these activities, the Group can act as originator, sponsor/arranger or investor:

as an originator, the Group directly or indirectly participates in the initial agreement on assets which subsequently serve as underlying in securitisation transactions, primarily for refinancing purposes;

as a sponsor, the Group establishes and manages a securitisation programme used to refinance customers’ assets, mainly via the Antalis and Barton conduits and via certain other special purpose vehicles;

as an investor, the Group invests directly in certain securitisation positions, is a liquidity provider or a counterparty of derivative exposures.

This information must be considered within the context of the specific structure of each transaction and vehicle, which cannot be described in this report.

Securitisation initiatives are part of the portfolio management program. They are efficient tools for optimizing capital management and managing credit risk exposure while maintaining a strong level of commercial dynamic. Several transactions with significant risk transfer (SRT) have been executed since mid-2019, mostly under a synthetic format and on different portfolios, to manage underlying credit risks and associated capital requirement. The SRT policy is documented in terms of internal governance, control framework as well as ongoing monitoring and reporting.

Taken separately, the level of payments past due or in default does not provide sufficient information on the types of exposures securitised by the Group, mainly because the default criteria may vary from one transaction to another. Furthermore, these data reflect the situation of the underlying assets.

In securitisation transactions, past due exposures are generally managed via structural mechanisms that protect the most senior positions.

Impaired exposures belong mainly to CDOs of US subprime residential mortgages, dating back to 2014.

As part of its securitisation activities, the Group does not provide any implicit support in accordance with Article 250 of revised CRR (regulation (UE) 2017/2401).

Since the protection purchased is financed, there is no counterparty credit risk on the vendor of the insurance. The Group does not intend to purchase unfunded protection at this stage.

TABLEAU 81: QUALITY OF SECURITISATION POSITIONS RETAINED OR ACQUIRED

Positions in the securitisation trading book are exclusively high ranking and mezzanine tranches, and 85.9% are high ranking positions as of 31 December 2022.

(in EUR m)

 

31.12.2022

Exposure At Default (EAD)

Highest-ranking tranche

Mezzanine tranche

Initial Loss tranche

STS

Non STS

STS

Non STS

STS

Non STS

Banking book

 

 

 

 

 

 

 

Securitisation

 

18,704

31,053

880

327

7

72

 

Originator

13,435

4,383

 880

 317

 7

 72

 

Investor

 202

2,281

-

-

-

-

 

Sponsor

5,067

24,388

-

 9

-

-

Re-Securitisation

 

-

-

-

-

-

-

Trading book

 

 

 

 

 

 

 

Securitisation

 

37

1,875

5

309

0

0

 

Investor

 37

1 875

 5

 309

-

-

Re-Securitisation

 

0

2

0

0

0

0

 

Investor

-

2

-

-

-

-

(in EUR m)

 

31.12.2021

Exposure At Default (EAD)

 

 

 

STS

Non STS

STS

Non STS

STS

Non STS

Banking book

 

 

 

 

 

 

 

Securitisation

 

9,411

38,443

130

1,389

19

60

 

Originator

4 224

11 489

 130

 803

 5

 55

 

Investor

-

 7

-

-

-

-

 

Sponsor

5 028

22 337

-

 9

-

-

Re-Securitisation

 

-

-

-

-

-

-

Trading book

 

 

 

 

 

 

 

Securitisation

 

41

3,643

-

526

-

-

 

Investor

 41

3 643

-

 526

-

-

Re-Securitisation

 

-

-

-

-

-

-

 

Investor

-

-

-

-

-

-

SOCIETE GENERALE AS ORIGINATOR

As part of its refinancing activities, the Group undertakes securitisations of some of its portfolios of receivables originated with individuals or corporate customers. The securities created in these transactions can be either sold to external investors, thus providing funding to the Group, or retained by the Group to be used as collateral in repurchase transactions, notably with the European Central Bank.

In 2022, the following securitsation transactions were carried out:

Two securitisation operations of EUR 10.1 billion and EUR 2.6 billion of real estate loans in France, fully subscribed by Société Générale or its subsidiaries and used as collateral for Eurosystem refinancing operations;

EUR 0.6 billion auto loan securitisation transaction in Germany, placed on the market. This securitisation served, on the one hand, to refinance the Group and, on the other hand, to reduce RWA consumption;

A securitisation transaction of approximately EUR 0.5 billion in car rental receivables (which may include residual value risk) deriving from long-term leasing contracts, placed to the tune of EUR 0.4 billion.

Given that there is no significant risk transfer as regards the Group securitisation transactions on its funding, those transactions have no impact on the Group’s regulatory capital, and consequently are not included in the tables of this section.

The vehicules bearing the transferred receivables are consolidated by the Group. This last one remains exposed to most of the risks and advantages on these receivables. Moreover, they cannot be used as guarantee or collateral or sold within the framework of other operations.

The total outstanding of the receivables securitised without significant risk transfer amounted to EUR 18.3 billion as at 31 December 2022, including EUR 11.6 billion of French home loans, EUR 4.1 billion of German auto loans, EUR 2.6 billion of French consumer loans.

Besides, the Group also detains several synthetic securitisation programmes in which the risk transfer is made by using credit derivatives or financial guarantees and where the portfolio is kept in the balance sheet of the Group.

The securitised stock of these transactions stood at EUR 18.4 billion as at 31 December 2022, mainly composed of loans to corporates.

Societe Generale did not securitise revolving exposures subject to early amortisation treatment in which the level of credit risk to which the originator is exposed may increase following the execution of the early amortisation provision.

SOCIETE GENERALE AS SPONSOR

The Societe Generale group carries out transactions on behalf of its customers or investors. As at 31 December 2021, there were two consolidated multi-seller vehicles in operation (Barton and Antalis), structured by the Group on behalf of clients. This ABCP (Asset-Backed Commercial Paper) activity funds the working capital requirements of some of the Group’s customers by backing short-term financing with traditional assets such as trade receivables or consumer loans. Total assets held by these vehicles and financed through the issuance of commercial paper amounted to EUR 18.5 billion on 31 December 2022 (EUR 15.5 billion on 31 December 2021).

As part of the implementation of the new IFRS 10 standards on 1 January 2014, Societe Generale has consolidated these two vehicles, Barton and Antalis, from this date onwards.

ABCP activity remained solid in 2022, with newly securitised outstanding amounts predominantly comprising trade receivables, leasing, or consumer loans.

SOCIETE GENERALE AS INVESTOR

Societe Generale also acts as a market-maker for securitised assets, resulting in securitisation positions in the Group’s trading book. Since 31 December 2011, CRD3 has required the same prudential treatment regardless of prudential classification. The following tables show the securitisation exposures retained or purchased by the Group, by type of underlying assets, by role and by type of securitisation, etc. Separately for the banking book and for the trading book. These tables only feature the exposures with an impact on the Group’s regulatory capital.

TABLE 82: SECURITISATION EXPOSURES IN THE NON-TRADING BOOK (SEC1)

(In EURm)

31.12.2022

Institution acts as originator

Institution acts as sponsor

Institution acts as investor

Traditional

Synthetic

Sub-total

Traditional

Synthetic

Sub-total

Traditional

Synthetic

Sub-total

STS

Non-STS

 

of

which

SRT

STS

Non-STS

STS

Non-STS

 

of

which

SRT

 

of

which

SRT

TOTAL EXPOSURES

2,413

2,413

273

273

18,129

18,129

20,816

5,312

23,090

-

28,402

202

1,396

-

1,597

Retail (total)

2,413

2,413

-

-

-

-

2,413

346

13,264

-

13,610

202

157

-

358

Residential mortgage

-

-

-

 

-

-

-

-

-

 

 

 

 

 

 

Credit card

-

-

-

 

-

-

-

-

2,935

-

2,935

-

40

-

40

Other retail exposures 

2,413

2,413

-

 

-

-

2,413

346

10,330

-

10,676

202

117

-

318

Re-securitisation

-

-

-

 

-

-

-

-

-

-

-

-

 

-

-

Wholesale (total)

-

 

273

273

18,129

18,129

18,403

4,966

9,826

-

14,792

-

1,239

-

1,239

Loans to corporates

-

 

273

273

18,129

18,129

18,403

150

4,596

-

4,746

-

1,112

-

1,112

Commercial mortgage 

-

-

-

-

-

-

-

-

-

-

 

-

-

-

 

Lease and receivables

-

-

-

-

-

-

-

4,816

3,965

-

8,781

-

7

-

7

Other wholesale

-

-

-

-

-

-

-

-

1,265

-

1,265

-

120

-

120

Re-securitisation

-

-

-

-

-

-

-

-

-

-

 

-

-

-

 

As of end of December 2022, securitisation exposures in the banking book amounted to EUR 50.8 billion. The bulk of the amount consists predominantly of liquidity lines linked to the Group’s sponsor conduit activity. The main underlying assets are corporate loans, consumer loans and trade receivables. In 2022, banking book exposures increased by EUR 8 billion, up 18% year-on-year.

As of December 31st 2022, 56% of banking book securitization exposures were STS. Since 2022, several synthetic programmes have been qualified as STS.

(In EURm)

31.12.2021

Institution acts as originator

Institution acts as sponsor

Institution acts as investor

Traditional

Synthetic

Sub-total

Traditional

Synthetic

Sub-total

Traditional

Synthetic

Sub-total

STS

Non-STS

 

of

which

SRT

STS

Non-STS

STS

Non-STS

 

of

which

SRT

 

of

which

SRT

TOTAL EXPOSURES

2,902

2, 902

 282

 282

14,983

14,983

18,168

4,823

19,828

-

24,651

-

 7

-

 7

Retail (total)

2,902

2, 902

-

-

-

-

2,902

 245

11,108

-

11,353

-

 0

-

 0

Residential mortgage

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

Credit card

-

-

-

-

-

-

-

-

2 243

-

2,243

-

 0

-

 0

Other retail exposures 

2,902

2,902

-

-

-

-

2,902

 245

8,865

-

9,110

-

 0

-

 0

Re-securitisation

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

Wholesale (total)

-

-

 282

 282

14983

14,983

15,265

4,578

8,720

-

13,298

-

 7

-

 7

Loans to corporates

-

-

 282

 282

14,983

14,983

15,265

 250

3,888

-

4 138

-

-

-

-

Commercial mortgage 

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

Lease and receivables

-

-

-

-

-

-

-

4,328

3,753

-

8,080

-

 7

-

 7

Other wholesale

-

-

-

-

-

-

-

-

1,079

-

1,079

-

 0

-

 0

Re-securitisation

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

TABLE 83: SECURITISATION EXPOSURES IN THE TRADING BOOK (SEC2)

(In EURm)

31.12.2022

Institution acts as originator

Institution acts as sponsor

Institution acts as investor

Traditional

Synthetic

Sub-total

Traditional

Synthetic

Sub-total

Traditional

Synthetic

Sub-total

STS

Non-STS

STS

Non-STS

STS

Non-STS

TOTAL EXPOSURES

-

-

-

-

-

-

-

-

  41

  203

 1,983

 2,228

Retail (total)

-

-

-

-

-

-

-

-

  41

  41

  40

  122

Residential mortgage

-

-

-

-

-

-

-

-

-

  26

  40

  65

Credit card

-

-

-

-

-

-

-

-

-

-

-

-

Other retail exposures 

-

-

-

-

-

-

-

-

  41

  14

-

  55

Re-securitisation

-

-

-

-

-

-

-

-

  2

-

  2

Wholesale (total)

-

-

-

-

-

-

-

-

-

  162

 1,944

 2,105

Loans to corporates

-

-

-

-

-

-

-

-

-

  55

  55

Commercial mortgage 

-

-

-

-

-

-

-

-

-

  106

 1,944

 2,050

Lease and receivables

-

-

-

-

-

-

-

-

-

-

-

-

Other wholesale

-

-

-

-

-

-

-

-

-

-

-

-

Re-securitisation

-

-

-

-

-

-

-

-

-

-

-

-

The securitisation positions on the trading book are exclusively investor positions for a total of EUR 2.2 billion nominal. Most of the positions relate to corporate financing, especially on commercial mortgage loans.

For the Trading portfolio, 98% of the transactions are non-STS as of 31 December 2022.

(In EURm)

31.12.2021

Institution acts as originator

Institution acts as sponsor

Institution acts as investor

Traditional

Synthetic

Sub-total

Traditional

Synthetic

Sub-total

Traditional

Synthetic

Sub-total

STS

Non-STS

STS

Non-STS

STS

Non-STS

TOTAL EXPOSURES

-

-

-

-

-

-

-

-

 41

 547

3,621

4,210

Retail (total)

-

-

-

-

-

-

-

-

 1

 116

 41

 158

Residential mortgage

-

-

-

-

-

-

-

-

 1

 115

 41

 156

Credit card

-

-

-

-

-

-

-

-

-

 1

-

 1

Other retail exposures 

-

-

-

-

-

-

-

-

-

 0

-

 0

Re-securitisation

-

-

-

-

-

-

-

-

-

-

-

-

Wholesale (total)

-

-

-

-

-

-

-

-

 40

 431

3,581

4,052

Loans to corporates

-

-

-

-

-

-

-

-

-

 204

-

 204

Commercial mortgage 

-

-

-

-

-

-

-

-

-

 88

3,566

3,654

Lease and receivables

-

-

-

-

-

-

-

-

 4

 5

-

 8

Other wholesale

-

-

-

-

-

-

-

-

 36

 134

 15

 185

Re-securitisation

-

-

-

-

-

-

-

-

-

-

-

-

TABLE 84: EXPOSURES SECURITISED BY THE INSTITUTION – EXPOSURES IN DEFAULT AND SPECIFIC CREDIT RISK ADJUSTMENTS (SEC5)

(In EURm)

31.12.2022

Exposures securitised by the institution – Institution acts as originator or as sponsor

Total outstanding nominal amount

Total amount of specific

credit risk adjustments

made during the period

 

of which exposures in default

TOTAL EXPOSURES

49,218

272

7

Retail (total)

16,024

14

7

Residential mortgage

-

-

-

Credit card

2,935

-

-

Other retail exposures 

13,089

14

7

Re-securitisation

-

-

-

Wholesale (total)

33,195

258

-

Loans to corporates

23,148

258

-

Commercial mortgage 

-

-

-

Lease and receivables

8,781

-

-

Other wholesale

1,265

-

-

Re-securitisation

-

-

-

(In EURm)

31.12.2022

Exposures securitised by the institution – Institution acts as originator or as sponsor

Total outstanding nominal amount

Total amount of specific

credit risk adjustments

made during the period

 

of which exposures in default

TOTAL EXPOSURES

42,818

3,030

5

Retail (total)

14,255

923

5

Residential mortgage

-

-

-

Credit card

2,243

-

-

Other retail exposures 

12,012

 923

 5

Re-securitisation

-

-

-

Wholesale (total)

28,563

2,107

-

Loans to corporates

19,404

2,107

-

Commercial mortgage 

-

-

-

Lease and receivables

8,080

-

-

Other wholesale

1,079

-

-

Re-securitisation

-

-

-

8.6 PRUDENTIAL TREATMENT OF SECURITISATION POSITIONS

APPROACH FOR CALCULATING RISK-WEIGHTED EXPOSURES

Whenever traditional or synthetic securitisations, for which sponsorship, origination, structuring or management of Societe Generale is involved, achieve a substantial and documented risk transfer compliant with the regulatory framework, the underlying assets are excluded from the bank’s calculation of risk-weighted exposures for traditional credit risk.

For the securitisation positions that Societe Generale decides to hold either on- or off-balance sheet, capital requirements are determined based on the bank’s exposure, irrespective of its underlying strategy or role.

Institutions use one of the methods described in the hierarchy below to calculate the weighted exposure amounts:

SEC-IRBA (approach based on internal ratings), when certain conditions are met;

when the SEC-IRBA cannot be used, the intitution uses the SEC-SA (standardised approach);

when the SEC-SA cannot be used, the institution uses the SEC-ERBA (approach based on external ratings) for positions with an external credit rating or those for which it is possible to infer such a note.

The unrated liquidity lines granted to ABCP programmes can be determined using the Internal Assessment Approach (IAA). Regarding the liquidity lines that the bank grants to the securitisation conduits it sponsors, Societe Generale obtained approval in 2009 to use the internal assessment approach. As such, Societe Generale has developed a rating model (IAA approach), which estimates the expected loss (Expected Loss - EL) for each Group’s exposure to securitisation conduits, which automatically leads to a capital weighting by application of a correspondence table defined by the regulations. The IAA model mainly applies to underlying assets such as trade receivables, auto loans and auto lease. An annual review of the model makes it possible to verify that the performance and conservatism of the model. Also, in-depth analyses are carried out on inputs (transaction details such as default, dilution, or reserve rates), model parameters (transition matrices, PD, LGD) and an EL backtest. The backtest of the outputs themselves being not feasible due to the limited number of transactions, the backtest of the IAA model consists in the backtest of the inputs (including for example default rate and default rate standard deviation) and the parameters as well as a model behavoir analysis. Methodological benchmarks are also regularly carried out in order to validate our internal approach in comparison with the best practices of the market. The relevance of the IAA approach is regularly monitored and reviewed by the Risk Department responsible for Model Risk Management at Group level, as second line of defense. The independent review process ends with (i) review and approval Committees and (ii) an independent review report detailing the scope of the review, the tests performed and their outcomes, the recommendations, and the conclusion of the review. The model control mechanism gives rise to recurrent reporting to the appropriate authorities.

In the other cases, the securitisation positions receive a risk weight of 1,250%.

EXTERNAL CREDIT ASSESSMENT INSTITUTIONS USED BY SOCIETE GENERALE

Assets securitised by Societe Generale are usually rated by one or more ECAIs (External Credit Assessment Institutions), the list of which is established by the French prudential supervisory authority ACPR (Autorité de Contrôle Prudentiel et de Résolution). The agencies used are DBRS, FitchRatings, Moody’s Investors Service and Standard & Poor’s. All four rating agencies have been registered with and supervised by the European Securities and Market Authority (ESMA) since 31 October 2011. The capital requirements for securitisation positions valued using the standardised approach are calculated based on the lowest external rating of the securitisation exposure.

An equivalence (see table 29, p. 84) between external ratings and Societe Generale’s internal rating scale is provided, presenting Societe Generale’s internal rating scale and the corresponding scales of the main ECAIs, as well as the corresponding average estimated probabilities of default.

TABLE85: CREDIT RATING AGENCIES USED IN SECURITISATIONS BY TYPE OF UNDERLYING ASSETS

Underlying assets

MOODY’S

FITCH

S&P

DBRS

Residential mortgages

Commercial mortgages

 

Credit card receivables

 

 

Leasing

 

Loans to corporates and SMEs

 

Consumer loans

Trade receivables

 

Other assets

 

Covered bonds

 

 

 

 

Other liabilites

 

 

 

 

REGULATORY CAPITAL REQUIREMENTS

The following tables present, by type of securitisation position, the approaches for calculating the weighted exposure amounts that Société Générale applies to its securitisation activities.

The following tables show the bank’s securitisation exposures and corresponding regulatory capital requirements for the Banking Book as at 31 December 2022.

TABLE 86: SECURITISATION EXPOSURES IN THE NON-TRADING BOOK AND ASSOCIATED REGULATORY CAPITAL REQUIREMENTS – INSTITUTION ACTING AS ORIGINATOR OR AS SPONSOR (SEC3)

(In EURm)

31.12.2022

Exposure values

(by RW bands/deductions)

≤ 20%

RW

 > 20% to 50%

RW

 > 50% to 100%

RW

 > 100% to < 1,250%

RW

1,250% RW/

deductions

TOTAL EXPOSURES

46,683

1,529

230

64

54

Traditional transactions 

30,534

1,432

21

64

17

Securitisation

30,534

1,432

21

64

17

Retail underlying

15,761

593

-

-

17

of which STS

2,741

-

-

-

17

Wholesale

14,773

839

21

64

-

of which STS

4,712

-

-

-

-

Re-securitisation

-

-

-

-

-

Synthetic transactions 

16,148

97

209

-

37

Securitisation

16,148

97

209

-

37

Retail underlying

-

-

-

-

-

Wholesale

16,148

97

209

 

37

Re-securitisation

-

-

 

-

-

(In EURm)

31.12.2022

Exposure values

(by regulatory approach)

RWA

(by regulatory approach)

Capital charge

after cap

SEC-IRBA

SEC-ERBA

(including

IAA)

SEC-SA

1,250%/

deductions

SEC-IRBA

SEC-ERBA

(including

IAA)

SEC-SA

1,250%/

deductions

SEC-IRBA

SEC-ERBA

(including

IAA)

SEC-SA

1,250%/

deductions

TOTAL EXPOSURES

17,231

25,300

5,974

54

2,706

3,889

706

-

216

311

56

-

Traditional transactions 

777

25,300

5,974

17

44

3,889

706

-

4

311

56

-

Securitisation

777

25,300

5,974

17

44

3,889

706

-

4

311

56

-

Retail underlying

576

13,967

1,810

17

-

2,298

-

-

-

184

-

-

of which STS

576

355

1,810

17

-

35

-

-

 

3

-

-

Wholesale

200

11,333

4,164

-

44

1,591

706

-

4

127

56

-

of which STS

-

4,712

-

-

-

471

-

-

-

38

-

-

Re-securitisation

-

-

-

-

-

-

-

-

-

-

-

-

Synthetic transactions 

16,455

-

-

37

2,662

-

-

-

213

-

-

-

Securitisation

16,455

-

-

37

2,662

-

-

-

213

-

-

-

Retail underlying

-

-

-

-

-

-

-

-

-

-

-

-

Wholesale

16,455

-

-

37

2,662

-

-

-

213

-

-

-

Re-securitisation

-

-

-

-

-

-

-

-

-

-

-

-

 

Most of the STS EAD transactions of the banking book (EUR 26.1 billion) are in IAA methodology (SG sponsor EUR 16 billion) and in SEC-IRBA methodology (SG originator EUR 4.7 billion).

(In EURm)

31.12.2021

Exposure values

(by RW bands/deductions)

≤ 20%

RW

 > 20% to 50%

RW

 > 50% to 100%

RW

 > 100% to < 1,250%

RW

1,250% RW/

deductions

TOTAL EXPOSURES

42,510

1,261

 170

 94

 43

Traditional transactions 

29,174

1,090

 170

 94

 18

Securitisation

29,174

1,090

 170

 94

 18

Retail underlying

13,534

 944

-

-

 18

of which STS

3,095

-

-

-

 18

Wholesale

15,640

 146

 170

 94

-

of which STS

4,807

-

-

-

-

Re-securitisation

-

-

-

-

-

Synthetic transactions 

13,336

 171

-

-

 25

Securitisation

13,336

 171

-

-

 25

Retail underlying

-

-

-

-

-

Wholesale

13,336

 171

-

-

 25

Re-securitisation

 

 

 

 

 

(In EURm)

31.12.2021

Exposure values

(by regulatory approach)

RWA

(by regulatory approach)

Capital charge

after cap

SEC-IRBA

SEC-ERBA

(including

IAA)

SEC-SA

1,250%/

deductions

SEC-IRBA

SEC-ERBA

(including

IAA)

SEC-SA

1,250%/

deductions

SEC-IRBA

SEC-ERBA

(including

IAA)

SEC-SA

1,250%/

deductions

TOTAL EXPOSURES

14,988

25,631

3,416

 43

2,082

3,977

 308

-

 167

 318

 25

-

Traditional transactions 

1,481

25,631

3,416

 18

 89

3,977

 308

-

 7

 318

 25

-

Securitisation

1,481

25,631

3,416

 18

 89

3,977

 308

-

 7

 318

 25

-

Retail underlying

 912

11,204

2,363

 18

-

1,887

 59

-

-

 151

 5

-

of which STS

 912

 90

2,093

 18

-

 12

 13

-

-

 1

 1

-

Wholesale

 570

14,427

1,053

-

 89

2,090

 249

-

 7

 167

 20

-

of which STS

-

4,807

-

-

-

 486

-

-

-

 39

-

-

Re-securitisation

-

-

-

-

-

-

-

-

-

-

-

-

Synthetic transactions 

13,507

-

-

 25

1,993

-

-

-

 159

-

-

-

Securitisation

13,507

-

-

 25

1,993

-

-

-

 159

-

-

-

Retail underlying

-

-

-

-

-

-

-

-

-

-

-

-

Wholesale

13,507

-

-

 25

1,993

-

-

-

 159

-

-

-

Re-securitisation

 

 

 

 

 

 

 

 

 

 

 

 

TABLE 87: SECURITISATION EXPOSURES IN THE NON-TRADING BOOK AND ASSOCIATED REGULATORY CAPITAL REQUIREMENTS – INSTITUTION ACTING AS INVESTOR (SEC4)

(In EURm)

31.12.2022

Exposure values

(by RW bands/deductions)

≤ 20%

RW

 > 20% to 50%

RW

 > 50% to 100%

RW

 > 100% to < 1,250%

RW

1,250% RW/

deductions

TOTAL EXPOSURES

2,184

117

181

-

-

Traditional securitisation 

2,184

117

181

-

-

Securitisation

2,184

117

181

-

-

Retail underlying

429

113

61

-

-

of which STS

202

-

-

-

-

Wholesale

1,755

5

120

-

-

of which STS

-

-

-

-

-

Re-securitisation

-

-

-

-

-

Synthetic securitisation 

-

-

-

-

-

Securitisation

-

-

-

-

-

Retail underlying

-

-

-

-

-

Wholesale

-

-

-

-

-

Re-securitisation

-

-

-

-

-

(In EURm)

31.12.2022

Exposure values

(by regulatory approach)

RWA

(by regulatory approach)

Capital charge

after cap

SEC-IRBA

SEC-ERBA

(including

IAA)

SEC-SA

1,250%/

deductions

SEC-IRBA

SEC-ERBA

(including

IAA)

SEC-SA

1,250%/

deductions

SEC-IRBA

SEC-ERBA

(including

IAA)

SEC-SA

1,250%/

deductions

TOTAL EXPOSURES

-

426

2,057

-

-

134

366

-

-

11

29

-

Traditional securitisation 

-

426

2,057

-

-

134

366

-

-

11

29

-

Securitisation

-

426

2,057

-

-

134

366

-

-

11

29

-

Retail underlying

-

6

597

-

-

1

143

-

-

-

11

-

of which STS

-

0

202

-

-

0

20

-

-

-

2

-

Wholesale

-

419

1,460

-

-

133

223

-

-

11

18

-

of which STS

-

-

-

-

-

-

-

-

-

-

-

-

Re-securitisation

-

-

-

-

-

-

-

-

-

-

-

-

Synthetic securitisation 

-

-

-

-

-

-

-

-

-

-

-

-

Securitisation

-

-

-

-

-

-

-

-

-

-

-

-

Retail underlying

-

-

-

-

-

-

-

-

-

-

-

-

Wholesale

-

-

-

-

-

-

-

-

-

-

-

-

Re-securitisation

-

-

-

-

 

-

-

-

-

-

-

-

(In EURm)

31.12.2021

Exposure values

(by RW bands/deductions)

≤ 20%

RW

 > 20% to 50%

RW

 > 50% to 100%

RW

 > 100% to < 1,250%

RW

1,250% RW/

deductions

TOTAL EXPOSURES

7

-

-

-

-

Traditional securitisation 

7

-

-

-

-

Securitisation

-

7

-

-

-

Retail underlying

-

-

-

-

-

of which STS

-

-

-

-

-

Wholesale

7

-

-

-

-

of which STS

-

-

-

-

-

Re-securitisation

-

-

-

-

-

Synthetic securitisation 

-

-

-

-

-

Securitisation

-

-

-

-

-

Retail underlying

-

-

-

-

-

Wholesale

-

-

-

-

-

Re-securitisation

-

-

-

-

-

(In EURm)

30.06.2022

Exposure values

(by regulatory approach)

RWA

(by regulatory approach)

Capital charge

after cap

SEC-IRBA

SEC-ERBA

(including

IAA)

SEC-SA

1,250%/

deductions

SEC-IRBA

SEC-ERBA

(including

IAA)

SEC-SA

1,250%/

deductions

SEC-IRBA

SEC-ERBA

(including

IAA)

SEC-SA

1,250%/

deductions

TOTAL EXPOSURES

-

7

-

-

-

2

-

-

-

-

-

-

Traditional securitisation 

-

7

-

-

-

2

-

-

-

-

-

-

Securitisation

-

7

-

-

-

2

-

-

-

-

-

-

Retail underlying

-

-

-

-

-

-

-

-

-

-

-

-

of which STS

-

-

-

-

-

-

-

-

-

-

-

-

Wholesale

-

7

-

-

-

1

-

-

-

-

-

-

of which STS

-

-

-

-

-

-

-

-

-

-

-

-

Re-securitisation

-

-

-

-

-

-

-

-

-

-

-

-

Synthetic securitisation 

-

-

-

-

-

-

-

-

-

-

-

-

Securitisation

-

-

-

-

-

-

-

-

-

-

-

-

Retail underlying

-

-

-

-

-

-

-

-

-

-

-

-

Wholesale

-

-

-

-

-

-

-

-

-

-

-

-

Re-securitisation

-

-

-

-

-

-

-

-

-

-

-

-

8.7 PERIMETER OF SECURITISATION VEHICLES

List of SSPEs which acquire exposures originated by the institutions(1):

Business Line

Originator

SPPE

Description of types of

institutions’ exposures(2)

Retail Banking and International Financial Services

BANK DEUTSCHES KRAFTFAHRZEUGGEWERBE GMBH (BDK)

RED & BLACK AUTO GERMANY 6 UG

Auto loans

BANK DEUTSCHES KRAFTFAHRZEUGGEWERBE GMBH (BDK)

RED & BLACK AUTO GERMANY 7 UG

Auto loans

BANK DEUTSCHES KRAFTFAHRZEUGGEWERBE GMBH (BDK)

RED & BLACK AUTO GERMANY 8 UG

Auto loans

BANK DEUTSCHES KRAFTFAHRZEUGGEWERBE GMBH (BDK)

RED & BLACK AUTO GERMANY 9 UG

Auto loans

FIDITALIA SPA

RED & BLACK AUTO ITALY SRL

Auto loans

Retail banking

SOCIETE GENERALE

RED & BLACK CONSUMER FRANCE 2013

Consumer loans

SOGEFINANCEMENT

RED & BLACK HOME LOANS FRANCE 2

Residential loans

BOURSORAMA

BOURSORAMA MASTER HOME LOANS FRANCE

Residential loans

ALDA

TEMSYS

RED & BLACK AUTO LEASE FRANCE 1

Auto leases

AXUS NETHERLAND B.V.

RED & BLACK AUTO LEASE GERMANY 3 S.A.

Auto leases

(1)

Public securitisations.

(2)

Société Générale or an affiliate of the Group may provide cash reserves to the SSPE in certain circumstances and hold the junior tranches.

List of SSPEs sponsored by the institutions:

Business Line

Country

SSPE

Global Banking & Investor Solutions

France

ANTALIS SA

Luxembourg

BARTON CAPITAL SA

United States

MOUNTCLIFF FUNDING LLC

Jersey

INSTITUTIONAL SECURED FUNDING LTD

List of SSPEs and other legal entities for which the institutions provide securitisation-related services, such as advisory, asset servicing or management services:

Business Line

Country

Management company

Global Banking & Investor Solutions

France

CLARESCO FINANCE

DELTA ALTERNATIVE MANAGEMENT

EQUITIS GESTION

EUROTITRISATION

FRANCE TITRISATION

GTI ASSET MANAGEMENT

PARIS TITRISATION

SIENNA AM FRANCE

Luxembourg

VAULT

On SGSS side, other asset managers are providing different categories of funds other that securitisation.

List of legal entities affiliated with the institutions and that invest in securitisations originated by the institutions or in securitisation positions issued by SSPEs sponsored by the institutions:

 

Country

Legal entities

Germany

BANK DEUTSCHES KRAFTFAHRZEUGGEWERBE GMBH (BDK)

ALD AUTOLEASING GMBH

Belgium

AXUS SA/NV

Spain

SOCGEN FINANCIACIONES IBERIA, SL

France

BOURSORAMA

CREDIT DU NORD

SOCIETE GENERALE

SOGELEASE FRANCE

TEMSYS

Great Britain

ALD AUTOMATIVE LIMITED

Ireland

SGBT FINANCE IRELAND DESIGNATED ACTIVITY COMPANY

Italie

FIDITALIA SPA

Luxembourg

SGBTCI

SGBT ASSET BASED FUNDING SA

SOCIETE GENERALE FINANCING AND DISTRIBUTION

Netherlands

AXUS NEDERLAND B.V

List of SPPEs included in the institutions’regulatory scope of consolidation

Country

SSPE

Germany

RED & BLACK AUTO GERMANY 6 UG

RED & BLACK AUTO GERMANY 7 UG

RED & BLACK AUTO GERMANY 8 UG

RED & BLACK AUTO GERMANY 9 UG

Belgium

AXUS FINANCE SA/NV

France

ANTALIS SA

BOURSORAMA MASTER HOME LOANS FRANCE 

RED & BLACK CONSUMER FRANCE 2013

RED & BLACK HOME LOANS FRANCE 2

RED & BLACK AUTO LEASE FRANCE 1

FCT LA ROCHE

Great Britain

RED & BLACK AUTO LEASE UK 1 PLC

Italy

RED & BLACK AUTO ITALY SRL

Luxembourg

BARTON CAPITAL SA

RED & BLACK AUTO LEASE GERMANY 3 S.A.

ZEUS FINANCE LEASING SA

Netherlands

AXUS FINANCE NL B.V.

 

9 MARKET RISK

 

IN BRIEF

Market risk is the risk of loss of value on financial instruments arising from changes in market parameters, the volatility of these parameters and the correlations between them. These parameters include, but are not limited to, exchange rates, interest rates, the price of securities (equities or bonds), commodities, derivatives and other assets.

Market risk RWA at end 2022

€13.8bn

(Amount at end 2021: €11.6bn)

Annual average VaR

(1 day, 99%) - 2022

€18m

(Annual average VaR 2021: €15m)

 

Share of RWA calculated via the internal model 

86%

 

Market risk is the risk of loss of value on financial instruments arising from changes in market parameters, the volatility of these parameters, and the correlations between them. These parameters include, but are not limited to, exchange rates, interest rates, the price of securities (equities or bonds), commodities, derivatives and other assets.

9.1 ORGANISATION OF MARKET RISK MANAGEMENT

Main functions

Although primary responsibility for managing risk exposure relies on the front office managers, the supervision system comes under the Market Risk Department of the Risk Department, which is independent from the businesses.

The main missions of this department are:

the definition and proposal of the Group’s market risk appetite;

the proposal of appropriate market risk limits by Group activity to the Group Risk Committee (CORISQ);

the assessment of the limit requests submitted by the different businesses within the framework of the overall limits authorised by the Board of Directors and General Management, and based on the use of these limits;

the permanent verification of the existence of an effective market risk monitoring framework based on suitable limits;

the definition of the indicators used to monitor market risk;

the daily calculation and certification of the market risk indicators, of the P&L resulting from market activities, based on formal and secure procedures, and then of the reporting and the analysis of these indicators;

the daily monitoring of the limits set for each activity.

In order to perform its tasks, the department also defines the architecture and the functionalities of the information system used to produce the risk and P&L indicators for market transactions, and ensures it meets the needs of the different businesses and of the Market Risk Department.

This department contributes to the detection of possible rogue trading operations through a monitoring mechanism based on alert levels (on gross nominal value of positions for example) applied to all instruments and desks.

Governance

Market risks oversight is provided by various Committees at different levels of the Group:

the Risk Committee of the Board of Directors(1) is informed of the Group’s major market risks; in addition, it issues a recommendation on the most substantial proposed changes in terms of market risk measurement and framework (after prior approval by the CORISQ); this recommendation is then referred to the Board of Directors for a decision;

the Group Risk Committee(2) (CORISQ), chaired by the Chief Executive Officer of the Group (DGLE), is regularly informed of Group-level market risks. Moreover, upon a proposal from the Risk Department, it validates the main choices with regard to market risk measurement, as well as the key developments on the architecture and implementation of the market risk framework at Group level. The global market risk limits with a Board or DGLE delegation level are reviewed in CORISQ at least twice a year;

the market risks related to the Global Markets Division are reviewed during the Market Risk Committee(3) (MRC) led by the Market Risk Department and co-chaired by the Risk Department and by the Global Markets Division. This Committee provides information on risk levels for the main risk indicators as well as for some specific activities pointed out depending on market or business driven events. It also provides an opinion on the market risk framework changes falling under the remit of the Risk Department and Global Markets Division. Thus, the global market risk limits with a MARK/DIR – RISQ/DIR delegation level are reviewed in MRC at least twice a year.

During these Committees, the market activities P&L and several metrics for monitoring market risks are reported:

stress test measurements: Global Stress Test on market activities and Market Stress Test;

regulatory metrics: Value-at-Risk (VAR) and Stressed Value-at-Risk (SVAR).

In addition to these Committees, detailed and summary market risk reports, produced on a daily, weekly, monthly or quarterly basis, either related to various Group levels or geographic areas, are sent to the relevant business line and risk function managers.

In terms of governance, within the Market Risk Department, the main functional and transversal subjects are dealt with during Committees organised by value chains (market risk, P&L, etc.). These Committees are decision-making bodies, composed of senior representatives from each relevant Department teams and regions.

(1)

Gathered ten times in 2022 on topics related to market activities.

(2)

Seven CORISQ dedicated to market activities took place in 2022.

(3)

Gathered 11 times in 2022.

9.2 MARKET RISK MONITORING PROCESS

Market risk appetite

The business development strategy of the Group for market activities is primarily focused on meeting clients’ needs, with a comprehensive range of products and solutions. The risk resulting from these market activities is strictly managed through a set of limits for several indicators:

the Value-at-Risks (VaR) and stressed Value-at-Risks (sVaR): these global indicators are used for market risk calculations for RWA and for the day-to-day monitoring of the market risks incurred by the Group within the scope of its trading activities;

stress test measurements, based on decennial shock-type indicators, which make it possible to restrict the Group’s exposure to systemic risk and exceptional market shocks. These measurements can be global, multi-risk factor (based on historic or hypothetical scenarios), by activity or risk factor in order to take into account extreme risks on a specific market, or event-driven, to temporarily monitor a particular situation;

sensitivity and nominal indicators used to manage the size of positions:

-

sensitivities are used to monitor the risk incurred locally on a given type of position (e.g. sensitivity of an option to changes in the underlying asset),

-

while nominal indicators are used for significant positions in terms of risk;

additional indicators such as concentration risk or holding period, maximum maturity, etc.

The Market Risk Department is responsible for the assessment and validation of the limit requests submitted by the different business lines. These limits ensure that the Group complies with the market risk appetite approved by the Board of Directors.

Determining and monitoring limits

The choice and calibration of these limits ensure the operational transposition of the Group’s market risk appetite through its organisation:

these limits are allocated at various levels of the Group’s structure and/or by risk factor;

their calibration is determined using a detailed analysis of the risks related to the portfolio managed. This analysis may include various elements such as market conditions, specifically liquidity, position maneuverability, risk/rewards analysis, ESG criteria, etc.;

regular reviews make it possible to manage risks according to the prevailing market conditions;

specific limits, or even bans, may be put in place to manage risks for which the Group has little or no risk appetite.

The desk mandates and Group policies stipulate that the traders must have a sound and prudent management of positions and must respect the defined frameworks. The allowed transactions, as well as risk hedging strategies, are also described in the desk mandates. The limits set for each activity are monitored daily by the Market Risk Department. This continuous monitoring of the market risk profile is the object of regular discussions between the risk and business teams, further to which various risk hedging or mitigation initiatives may be taken by the front office in order to remain within the defined limits. In the event of a breach of the risk framework, and in compliance with the limits follow-up procedure, the front office must detail the reasons, and take the necessary measures to return within the defined framework, or otherwise request a temporary or permanent increase of limit if the client’s request and if market conditions justify such a course of action.

In addition to the governance structure in place between the various departments of the Risk function and business lines, the monitoring of limits usage, due to the products/solutions provided to clients and the market-making activities, also contributes to ensuring that market risk to which the Group is exposed are properly managed and understood.

9.3 MAIN MARKET RISK MEASURES

Stress test assessment

Societe Generale monitors its exposure using stress test simulations to take into account exceptional market disruptions.

A stress test estimates the loss resulting from an extreme change in market parameters over a period corresponding to the time required to unwind or hedge the positions affected.

Two major metrics are defined and used:

the Global Stress Test on market activities, which estimates the losses linked to market risks, market/counterparty cross-risk, and dislocation and carry risk on exotic activities, that could arise simultaneously in the event of a severe but plausible systemic crisis. This stress test is modeled on five scenarios;

the Market Stress Test, which focuses solely on market risks, applying the same scenarios as the Global Stress Test and additional scenarios corresponding to different market conditions.

The various scenarios for those stress tests are reviewed by the Risk Division on a regular basis. These reviews are presented during dedicated biannual Committees, chaired by the Market Risk Department and attended by economists and representatives of Societe Generale’s trading activities. These Committees cover the following topics: changes in scenarios (introduction, removal, shock review), appropriate coverage of the risk factors by the scenarios, review of the approximations made in terms of calculation, correct documentation of the whole process. The delegation level needed to validate the changes in stress test methodology depends on the impact of the change in question.

The Global Stress Test on market activities limits and the Market Stress Test limits play a central role in the definition and the calibration of the Group’s appetite for market risk: these indicators cover all activities and the main market risk factors and associated risks associated with a severe market crisis, this allows both to limit the overall amount of risk and to take into account any diversification effects.

This framework is complemented by stress-testing frameworks on four risk factors on which the Group has significant exposures, in order to reduce the overall risk appetite: equities, interest rates, credit spread and emerging markets.

GLOBAL STRESS TEST ON MARKET ACTIVITIES

The Global Stress Test on market activities is the main risk indicator used on this scope. It covers all the risks on market activities that would occur simultaneously in case of a severe, but plausible, market crisis. The impact is measured over a short period of time with an expected occurrence of once per decade. The Global Stress Test uses five market scenarios and has three components, each of which are considered in each of the five scenarios in order to ensure consistency within the same scenario:

market risk;

dislocation and carry risks on exotic activities related to concentration effects and crowded trades;

market/counterparty cross-risks arising in transactions with weak counterparties (hedge funds and proprietary trading groups).

The Global Stress Test corresponds to the least favorable results arising from the five scenarios and their respective components.

Market risk component

It corresponds to:

the results of the Market Stress Test(1) restricted to scenarios that could cause dislocation effects on market positions and default by weak counterparties. These scenarios all simulate a sharp fall in the equity markets and a widening in credit spreads which could trigger dislocation effects. Following the last review of the scenarios at the end of 2020, it was decided to use for the calculation of the stress test three theoretical scenarios (generalised (i.e. financial crisis scenario), eurozone crisis, general decline in risk assets) and two historical scenarios focusing respectively on the period of early October 2008 and early March 2020;

the impact of the stress test scenario on CVA (Credit Value Adjustment) and FVA (Funding Value Adjustment) reserves, as their variations affect trading results.

Dislocation and carry risk component

Additional market risks to those assessed in the Market Stress Test can occur in market situation in which one or more participants – generally structured products sellers – have concentrated or crowded trades. Dynamic risk hedging strategies can cause larger market dislocations than those calibrated in the Market Stress Test, and these dislocations can extend beyond the shock timeline used due to an imbalance between supply and demand.

Equity, credit, fixed income, currency and commodity trading activities are regularly reviewed to identify these areas of risk and to define a scenario that takes into account the specific features of each activity and position. Each scenario associated with an identified area of risk is added to the market risk component if – and only if – it is compatible with the market scenario in question.

Market/counterparty cross-risk component on weak counterparties

Some counterparties may be significantly affected by a major crisis on the financial markets and their probability of default may increase. The third component of the Global Stress Test therefore aims to take into account this increased risk on certain types of weak counterparties (hedge funds and proprietary trading groups).

Four measurements are used:

the collateralised financing stress test: this stress test focuses on collateralised financing activities and more specifically on weak counterparties. It applies a dislocation shock to several asset classes with the assumption of extremely tight liquidity conditions. Collateral and counterparty default rates are stressed concomitantly, taking into account any consanguinity with the collateral posted;

the adverse stress test on hedge funds and proprietary trading groups (PTG): this stress test applies three pairs of stress scenarios to all market transactions generating replacement regarding this type of counterparty. Each set of scenarios consists of a short-term scenario (scenario derived from the Market Stress Test) applied to positions with margin calls, and a long-term scenario (whose shocks are generally more severe) for positions without margin calls. Stressed current exposures are weighted by the probability of default of each counterparty and by the loss given default (LGD), then aggregated;

the adverse stress test on products whose underlying is a hedge fund: this type of underlying poses a risk of illiquidity in the event of a crisis, the purpose of this stress test is to estimate the corresponding potential loss on transactions with this type of underlying and presenting a “gap risk”;

the Clearing House (CCP) Member stress test: it estimates the potential loss in the event of a default of a CCP member of which Societe Generale is also a member.

(1)

Measurement of the impact in the Net Banking Product in case of shocks on all risk factors (refer to description below).

AVERAGE CONTRIBUTION OF THE COMPONENTS IN 2022 GLOBAL STRESS TEST ON MARKET ACTIVITIES

MARKET STRESS TEST

This metric focuses on market risk and estimates the loss resulting from shocks on the set of risk factors. This stress test is based on 11 scenarios(1) (four historical and seven hypothetical). The main principles are as follows:

the scenario considered in the market stress test is the worst of the different scenarios defined;

the shocks applied are calibrated on time horizons specific to each risk factor (the time horizon can range from five days for the most liquid risk factors to three months for the least liquid);

risks are calculated every day for each of the Bank’s market activities (all products together), using each of the historical and hypothetical scenarios.

Historical scenarios

This method consists of an analysis of the major economic crises that have affected the financial markets: changes in the prices of financial assets (equities, interest rates, exchange rates, credit spreads, etc.) during each of these crises have been analysed in order to define scenarios for potential variations in these main risk factors which, when applied to the Bank’s trading positions, could generate significant losses. Accordingly, this approach makes it possible to determine the historical scenarios used for the calculation of the stress test. This set of scenarios is also the subject of regular reviews. In 2020, two new historical scenarios related to the Covid-19 crisis were integrated: a crisis scenario (marked by a decline in equity indices and an increase in credit spreads) as well as a rebound scenario (marked by an increase in equity indices and a decrease in credit spreads). Societe Generale is currently using four historical scenarios in the calculation of the stress test, which cover the periods from October to December 2008 and March 2020.

Hypothetical scenarios

The hypothetical scenarios are defined with the Group’s economists and are designed to identify possible sequences of events that could lead to a major crisis in the financial markets (e.g. European crisis, a drop in assets, etc.). The Group’s aim is to select extreme but plausible events which would have major repercussions on all international markets. Accordingly, Societe Generale has defined seven hypothetical scenarios.

Regulatory indicators

99% VALUE-AT-RISK (VAR)

Methodology

The Internal VaR Model was introduced at the end of 1996 and has been approved by the French regulator within the scope of the regulatory capital requirements. This approval was renewed in 2020 at the Target Review of Internal Models (TRIM).

The Value-at-Risk (VaR) assesses the potential losses on positions over a defined time horizon and for a given confidence interval (99% for Societe Generale). The method used is the “historical simulation” method, which implicitly takes into account the correlation between the various markets, as well as general and specific risk. It is based on the following principles:

storage in a database of the risk factors that are representative of Societe Generale’s positions (i.e. interest rates, share prices, exchange rates, commodity prices, volatility, credit spreads, etc.). Controls are regularly performed in order to check that all major risk factors for the trading portfolio of the Group are taken into account by the internal VaR model;

definition of 260 scenarios corresponding to one-day variations in these market parameters over a rolling one-year period; these scenarios are updated daily with the inclusion of a new scenario and the removal of the oldest scenario. There are three coexisting methods for modeling scenarios (relative shocks, absolute shocks and hybrid shocks), the choice between these methods for a given risk factor is determined by its nature and its historical trend;

the application of these 260 scenarios to the market parameters of the day;

revaluation of daily positions, on the basis of the 260 sets of adjusted market parameters: in most cases this calculation involves a full repricing. Nonetheless, for certain risk factors, a sensitivity-based approach may be used.

(1)

Including the scenarios used in the global stress tests on market activities.

Main risk factors

Description

Interest rates

Risk resulting from changes in interest rates and their volatility on the value of a financial instrument sensitive to interest rates, such as bonds, interest rate swaps, etc.

Share prices

Risk resulting from variations in prices and volatility of shares and equity indices, in the level
of dividends, etc.

Exchange rates

Risk resulting from the variation of exchange rates between currencies and of their volatility.

Commodity prices

Risk resulting from changes in prices and volatility of commodities and commodity indices.

Credit Spreads

Risk resulting from an improvement or a deterioration in the credit quality of an issuer on the value of
a financial instrument sensitive to this risk factor such as bonds, credit derivatives (credit default swaps for example).

Within the framework described above, the one-day 99% VaR, calculated according to the 260 scenarios, corresponds to the weighted average(1) of the second and third largest losses computed, without applying any weighting to the other scenarios.

The day-to-day follow-up of market risk is performed via the one-day VaR, which is calculated on a daily basis at various granularity levels. Regulatory capital requirements, however, oblige us to take into account a ten-day horizon, thus we also calculate a ten-day VaR, which is obtained by multiplying the one-day VaR aggregated at Group level by the square root of ten. This methodology complies with regulatory requirements and has been reviewed and validated by the regulator.

The VaR assessment is based on a model and a certain number of conventional assumptions, the main limitations of which are as follows:

by definition, the use of a 99% confidence interval does not take into account losses arising beyond this point; VaR is therefore an indicator of the risk of loss under normal market conditions and does not take into account exceptionally significant fluctuations;

VaR is computed using closing prices, meaning that intraday fluctuations are not taken into account;

the use of a historical model is based on the assumption that past events are representative of future events and may not capture all potential events.

The Market Risk Department monitors the limitations of the VaR model by measuring the impacts of integrating a risk factor absent from the model (RNIME(2) process). Depending on the materiality of these missing factors, they may be capitalized. Other complementary measures also allow to control the limitations of the model.

The same model is used for the VaR computation for almost all of Global Banking & Investor Solution’s activities (including those related to the most complex products) and the main market activities of Retail Banking and Private Banking. The few activities not covered by the VaR method, either for technical reasons or because the stakes are too low, are monitored using stress tests, and capital charges are calculated using the standard method or through alternative in-house methods. For example, the currency risk of positions in the banking book is not calculated with an internal model because this risk is not subject to a daily revaluation and therefore cannot be taken into account in a VaR calculation.

Backtesting

The relevance of the model is checked through continuous backtesting in order to verify whether the number of days for which the negative result exceeds the VaR complies with the 99% confidence interval. The results of the backtesting are audited by the Risk Department in charge of the validation of internal models, which, as second line of defence, also assesses the theoretical robustness (from a design and development standpoint), the correctness of the implementation and the adequacy of the model use. The independent review process ends with (i) review and approval Committees and (ii) an Audit Report detailing the scope of the review, the tests performed and their outcomes, the recommendations and the conclusion of the review. The model control mechanism gives rise to reporting to the appropriate authorities.

In compliance with regulations, backtesting compares the VaR to the (i) actual and (ii) hypothetical change in the portfolio’s value:

in the first case (backtesting against “actual P&L”), the daily P&L(3) includes the change in book value, the impact of new transactions and of transactions modified during the day (including their sales margins) as well as provisions and values adjustments made for market risk;

in the second case (backtesting against “hypothetical P&L”), the daily P&L(4) includes only the change in book value related to changes in market parameters and excludes all other factors.

In 2022, we observed:

four VaR backtesting, against actual P&L breaches (two in Q2, one in Q3 and one in Q4);

eight VaR backtesting breaches, against hypothetical P&L (two breaches each quarter).

(1)

39% of the second highest risk and 61% of the third highest risk.

(2)

Risk Not In Model Engine.

(3)

“Actual P&L” by agreement hereinafter.

(4)

“Hypothetical P&L” by agreement hereinafter.

BREAKDOWN OF THE DAILY(1) P&L OF MARKET ACTIVITIES (2022, IN EURM)

TRADING VAR (ONE-DAY, 99%), DAILY ACTUAL(2) P&L AND DAILY HYPOTHETICAL(3) P&L OF THE TRADING PORTFOLIO (2022, IN EURM)

(1)

Actual P&L.

(2)

Daily result used for backtesting the VaR against the effective value of the portfolio as defined in the paragraph “Value-at-Risk 99% (VaR)”.

(3)

Daily result used for backtesting the VaR against the hypothetical value of the portfolio as defined in the paragraph “Value-at-Risk 99% (VaR)”.

VaR Changes

TABLE 88: REGULATORY TEN-DAY 99% VAR AND ONE-DAY 99% VAR

(In EURm)

31.12.2022

31.12.2021

VaR

(10 days, 99%)(1)

VaR

(1 day, 99%)(1)

VaR

(10 days, 99%)(1)

VaR

(1 day, 99%)(1)

Period start

25

8

75

24

Maximum value

95

30

98

31

Average value

56

18

49

15

Minimum value

22

7

18

6

Period end

75

24

25

8

(1)

Over the scope for which capital requirements are assessed by internal model.

BREAKDOWN BY RISK FACTOR OF TRADING VAR (ONE-DAY, 99%) – CHANGES IN QUARTERLY AVERAGE OVER THE 2021-2022 PERIOD (IN EURM)

The VaR was riskier in 2022 (EUR 18 million versus EUR 15 million in 2021 on average), mainly due to the entry of new and more volatile scenarios following the deterioration of market conditions related to the war in Ukraine. The increase in risk is particularly evident in the Rates and Credit activities.

STRESSED VAR (SVAR)

The Internal Stressed VaR model (SVaR) was introduced at the end of 2011 and has been approved by the Regulator within the scope of the regulatory capital requirements on the same scope as the VaR. As with the VaR model, this approval was renewed in 2020 at the Target Review of Internal Models (TRIM).

The calculation method used for the 99% one-day SVaR is the same as as the one for the VaR. It consists in carrying out a historical simulation with one-day shocks and a 99% confidence interval. Contrary to VaR, which uses 260 scenarios for one-day fluctuations over a rolling one-year period, SVaR uses a fixed one-year historical window corresponding to a period of significant financial tension.

Following a validation of the ECB obtained at the end of 2021, a new method for determining the fixed historical stress window is used. It consists in calculating an approximate SVaR for various risk factors selected as representative of the Societe Generale portfolio (related to equity, fixed income, foreign exchange, credit and commodity risks): these historical shocks are weighted according to the portfolio’s sensitivity to each of these risk factors and aggregated to determine the period of highest stress for the entire portfolio(1). The historical window used is reviewed annually. In 2022, this window was “September 2008-September 2009”.

The ten-day SVaR used for the computation of the regulatory capital is obtained, as for VaR, by multiplying the one-day SVaR by the square root of ten.

As for the VaR, the Market Risk Department controls the limitations of the SVaR model by measuring the impact of integrating a risk factor absent from the model (RNIME process). Depending on the materiality of these missing factors, they may be capitalized. Other complementary measures also control the limitations of the model. The continuous backtesting performed on VaR model cannot be replicated to the SVaR model as, by definition, it is not sensitive to the current market conditions. However, as the VaR and the SVaR models rely on the same approach, they have the same advantages and limitations.

The relevance of the SVaR is regularly monitored and reviewed by the Risk Department in charge of the validation of internal models, as second line of defence. The independent review process ends with (i) review and approval Committees and (ii) an Audit Report detailing the scope of the review, the tests performed and their outcomes, the recommendations and the conclusion of the review. The model control mechanism gives rise to recurrent reporting to the appropriate authorities.

SVaR decreased slightly on average in 2022 (EUR 32 million versus EUR 37 million in 2021 on average). Without any particular trend over the year, the SVaR has evolved at levels similar to those of 2021 and with comparable variability. The level of the SVaR remains explained by the indexing and financing action activities, and by the interest rate scopes, while the exotic scopes partially offset the risk.

TABLE 89: REGULATORY TEN-DAY 99% SVAR AND ONE-DAY 99% SVAR

(In EURm)

31.12.2022

31.12.2021

Stressed VaR

(10 days, 99%)(1)

Stressed VaR

(1 day, 99%)(1)

Stressed VaR

(10 days, 99%)(1)

Stressed VaR

(1 day, 99%)(1)

Period start

96

30

135

43

Maximum value

165

52

191

60

Average value

101

32

117

37

Minimum value

55

17

72

23

Period end

145

46

108

34

(1)

Over the scope for which capital requirements are assessed by internal model.

IRC AND CRM

At end-2011, Societe Generale received approval from the Regulator to expand its internal market risk modeling system by including IRC (Incremental Risk Charge) and CRM (Comprehensive Risk Measure), for the same scope as for VaR. As with the VaR model, the approval of the IRC(2) model was renewed in 2020 at the Target Review of Internal Models (TRIM).

They estimate the capital charge on debt instruments that is related to rating migration and issuer default risks. These capital charges are incremental, meaning they are added to the charges calculated based on VaR and SVaR.

In terms of scope, in compliance with regulatory requirements:

IRC is applied to debt instruments, other than securitisations and the credit correlation portfolio. In particular, this includes bonds, CDS and related derivatives;

CRM exclusively covers the correlation portfolio, i.e. CDO tranches and First-to-Default products (FtD), as well as their hedging using CDS and indices.

Societe Generale estimates these capital charges using internal models(3). These models determine the loss that would be incurred following especially adverse scenarios in terms of rating changes or issuer defaults for the year that follows the calculation date, without ageing the positions. IRC and CRM are calculated with a confidence interval of 99.9%: they represent the highest risk of loss obtained after eliminating 0.1% of the most unfavorable scenarios simulated.

The internal IRC model simulates rating transitions (including default) for each issuer in the portfolio, over a one-year horizon(4). Issuers are classified into five categories: US-based companies, European companies, companies from other regions, financial institutions and sovereigns. The behaviours of the issuers in each category are correlated with one other through a systemic factor specific to each category. In addition, a correlation between these five systemic factors is integrated to the model. These correlations, along with the rating transition probabilities, are calibrated from historical data observed over the course of a full economic cycle. In case of change in an issuer’s rating, the decline or improvement in its financial health is modeled by a shock in its credit spread: negative if the rating improves and positive in the opposite case. The price variation associated with each IRC scenario is determined after revaluation of positions via a sensitivity approach, using the delta, the gamma as well as the level of loss in the event of default (Jump to Default), calculated with the market recovery rate for each position.

(1)

At the request of the ECB, a posteriori check is carried out to verify the relevance of this historical window by making calculations for full revaluation.

(2)

The CRM model was not within the scope of the Target Review of Internal Models.

(3)

The same internal model is used for all portfolios for which an IRC calculation is required. The same is true for the portfolios on which a CRM calculation is performed. Note that the scope covered with internal models (IRC and CRM) is included in the VaR scope: only entities authorised for a VaR calculation via an internal model can use an internal model for IRC and CRM calculation.

(4)

The use of a constant one-year liquidity horizon means that shocks that are applied to the positions to calculate IRC and CRM, are instantaneous one-year shocks. This hypothesis appears to be the most prudent choice in terms of models and capital, rather than shorter liquidity horizons.

The CRM model simulates issuer’s rating transitions in the same way as the internal IRC model. In addition, the dissemination of the following risk factors is taken into account by the model:

credit spreads;

basis correlations;

recovery rate excluding default (uncertainty about the value of this rate if the issuer has not defaulted);

recovery rate in the event of default (uncertainty about the value of this rate in case of issuer default);

First-to-Default valuation correlation (correlation of the times of default used for the valuation of the First-to-Default basket).

These dissemination models are calibrated from historical data, over a maximum period of ten years. The price variation associated with each CRM scenario is determined thanks to a full repricing of the positions. In addition, the capital charge computed with the CRM model cannot be less than a minimum of 8% of the capital charge determined with the standard method for securitisation positions.

The internal IRC and CRM models are subject to similar governance to that of other internal models meeting the Pillar 1 regulatory requirements. More specifically, an ongoing monitoring allows to follow the adequacy of IRC and CRM models and of their calibration. This monitoring is based on the review of the modeling hypotheses at least once a year. This review includes:

a check of the adequacy of the structure of the rating transition matrices used for IRC and CRM models;

a backtesting of the probabilities of default used for these two models;

a check of the adequacy of the models for the dissemination of recovery rates, spread dissemination and dissemination of basic correlations used in the CRM calculation.

Regarding the checks on the accuracy of these metrics:

the IRC calculation being based on the sensitivities of each instrument – delta, gamma – as well as on the level of loss in the event of default (Jump to Default) calculated with the market recovery rate, the accuracy of this approach is checked against a full repricing every six months;

such a check on CRM is not necessary as its computation is performed following a full repricing;

these metrics are compared to normative stress tests defined by the regulator. In particular, the EBA stress test and the risk appetite exercise are performed regularly on the IRC metric. These stress tests consist of applying unfavorable rating migrations to issuers, shocking credit spreads and shocking rating transition matrices. Other stress tests are also carried out on an ad hoc basis to justify the correlation hypotheses between issuers and those made on the rating transition matrix;

a weekly analysis of these metrics is carried out by the production and certification team for market risk metrics;

the methodology and its implementation have been initially validated by the French Prudential and Resolution Supervisory Authority (Autorité de contrôle prudentiel et de résolution – ACPR). Thereafter, a review of the IRC and the CRM is regularly carried out by the Risk Department in charge of the validation of internal models as second line of defence. This independent review process ends with (i) review and approval Committees and (ii) an Audit Report detailing the scope of the review, the tests performed and their outcomes, the recommendations and the conclusion of the review. The model control mechanism gives rise to recurrent reporting to the appropriate authorities.

Moreover, regular operational checks are performed on the completeness of the scope’s coverage as well as the quality of the data describing the positions.

TABLE 90: IRC (99.9%) AND CRM (99.9%)

(In EURm)

31.12.2022

31.12.2021

Incremental Risk Charge (99.9%)

 

 

Period start

67

101

Maximum value

114

205

Average value

71

116

Minimum value

50

51

Period end

53

67

Comprehensive Risk Measure (99.9%)

 

 

Period start

41

66

Maximum value

133

102

Average value

51

64

Minimum value

39

40

Period end

42

57

9.4 RISK-WEIGHTED ASSETS AND CAPITAL REQUIREMENTS

Allocation of exposures in the trading book

The on- and off-balance sheet items must be allocated to one of the two portfolios defined by prudential regulations: the banking book or the trading book.

The banking book is defined by elimination: all on- and off-balance sheet items not included in the trading book are included by default in the banking book.

The trading book consists of all positions in financial instruments and commodities held by an institution either for trading purposes or in order to hedge other positions in the trading book. The trading interest is documented as part of the traders’ mandates.

The prudential classification of instruments and positions is governed as follows:

the Finance Department’s prudential regulation experts are responsible for translating the regulations into procedures, together with the Risk Department for procedures related to holding period and liquidity. They also analyse specific cases and exceptions. They share these procedures to the business lines;

the business lines comply with these procedures. In particular, they document the trading interest of the positions taken by traders;

the Finance and Risk Departments are in charge of the control framework.

The following controls are implemented in order to ensure that activities are managed in accordance with their prudential classification:

new product process: any new product or activity is subject to an approval process that covers its prudential classification and regulatory capital treatment for transactions subject to validation;

holding period: the Market Risk Department has designed a control framework for the holding period of certain instruments;

liquidity: on a case-by-case basis or on demand, the Market Risk Department performs liquidity controls based on certain criteria (negotiability/transferability, bid/ask size, market volumes, etc.);

strict process for any change in prudential classification, involving the business line and the Finance and Risk Divisions;

internal audit: through its various periodic assignments, Internal Audit verifies or questions the consistency of the prudential classification with policies/procedures as well as the suitability of the prudential treatment in light of existing regulations.

Quantitative information

Around 85% of Societe Generale capital requirements related to market risk are determined using an internal model approach. The standard approach is mainly used for the Collective Investment Units (CIU), for securitisation positions, but also for the positions presenting a foreign exchange risk, which are not part of the trading book, as well as for the Group’s subsidiaries that do not have access to the core IT tools developed internally. The main entities concerned are some International Retail Banking and Financial Services entities such as SG Maroc, BRD, SG Tunisie, SG Algérie, SG Côte d’Ivoire, etc.

Capital requirements for market risk increased in 2022. This increase is reflected in the VaR and the risks calculated under the standard approach:

the VaR gradually increased over 2022, from a historically low level at the end of 2021. This increase is reflected in all activities, notably credit and interest rates;

risks calculated under the standard approach are on the rise, mainly due to the currency portion. This increase is partially offset by a reduction in the securitization positions of the trading book.

TABLE 91: MARKET RISK CAPITAL REQUIREMENTS AND RWA BY RISK FACTOR

 

Risk-weighted assets

Capital requirement

(In EURm)

31.12.2022

31.12.2021

Change

31.12.2022

31.12.2021

Change

VaR

3,504

1,343

2,160

280

107

173

Stressed VaR

6,886

7,227

(340)

551

578

(27)

Incremental Risk Charge (IRC)

811

840

(29)

65

67

(2)

Correlation portfolio (CRM)

615

815

(200)

49

65

(16)

Total market risk assessed by internal model

11,816

10,225

1,591

945

818

127

Specific risk related to securitisation positions in the trading portfolio

150

562

(412)

12

45

(33)

Risk assessed for currency positions

987

-

987

79

-

79

Risks assessed for interest rates (excl. securitisation)

421

285

136

34

23

11

Risk assessed for ownership positions

374

572

(199)

30

46

(16)

Risk assessed for commodities

0

0

0

0

0

0

Total market risk assessed by standard approach

1,932

1,419

513

155

114

41

TOTAL

13,747

11,643

2,104

1,100

931

168

TABLE 92: MARKET RISK CAPITAL REQUIREMENTS AND RWA BY TYPE OF RISK

 

Risk-weighted assets

Capital requirement

(In EURm)

31.12.2022

31.12.2021

31.12.2022

31.12.2021

Risk assessed for currency positions

1,336

349

107

28

Risk assessed for credit (excl. deductions)

3,816

3,984

305

319

Risk assessed for commodities

24

39

2

3

Risk assessed for ownership positions

5,403

4,474

432

358

Risk assessed for interest rates

3,168

2,797

253

224

TOTAL

13,747

11,643

1,100

931

9.5 FINANCIAL INSTRUMENTS VALUATION

Management risk related to the valuation of financial products relies jointly on the Markets Department and the team of valuation experts (Valuation Group) within the Finance Department that both embody the first line of defence and by the team of independent review of valuation methodologies within the Market Risk Department.

Governance

Governance on valuation topics is enforced through three valuation Committees, both attended by representatives of the Global Markets Division, the Market Risk Department and the Finance Division:

the Valuation Risk Committee meets at least once a year to monitor and approve changes in the valuation risk management framework; monitor indicators on this risk and propose or set a risk appetite; evaluate the control system and the progress of recommendations; and finally, prioritize the tasks. This Committee is chaired by the Risk Department and organized by its independent review team of valuation methodologies;

the Valuation Methodology Committee gathers whenever necessary, at least every quarter, to approve financial products valuation methodologies. This Committee, chaired by the Risk Department and organized by its independent review team of valuation methodologies, has global accountability with respect to the approval of the valuation policies;

the MARK P&L Explanation Committee monthly analyses the main sources of economic P&L as well as changes in reserves and other accounting valuation adjustments. The analytical review of adjustments is carried out by the Valuation Group, which also provides a quarterly analytical review of adjustments under regulatory requirements for prudent valuation.

Lastly, a corpus of documents describes the valuation governance and specify the breakdown of responsibilities between the stakeholders.

Valuation principles and associated controls

Market products at fair value are marked to market, when such market prices exist; otherwise, they are valued using parameter-based models, in compliance with the IFRS 13 principles defining fair value.

On the one hand, each model designed by the front office is subject to independent validation by the Market Risks Department as second line of defence that especially checks the conceptual relevance of the model, its performance (especially in case of stressed conditions) and its implementation in systems. Following this review, the validation status of the model, its scope of use and the recommendations to be dealt with are formalised in a report.

On the other hand, the parameters used in the valuation models, whether they come from observable data on the markets or not, are described in marking policies(1) written by the front office and validated by the Market Risk Department. This system is complemented by specific controls carried out by LOD1 (in particular the Independent Price Verification process performed by the Finance Department).

If necessary the resulting valuations are supplemented by reserves or adjustments (mainly covering liquidity, parameter or model uncertainties) the calculation methodologies of which are developed jointly by the Valuation Group and the front office and reviewed by the Market Risk Department. These adjustments are made under fair value accounting requirements or prudent valuation regulatory requirements. The latter aim to capture valuation uncertainty in accordance with the procedures prescribed by the regulations through additional valuation adjustments in relation to the fair value (Additional Valuation Adjustments or AVA) directly deducted from Common Equity Tier 1 capital.

(1)

Document describing the parameter determination methodology.

9.6 ADDITIONAL QUANTITATIVE INFORMATION ON MARKET RISK

TABLE 93: MARKET RISK UNDER THE STANDARDISED APPROACH (MR1)

 

Risk-weighted assets

(In EURm)

31.12.2022

31.12.2021

Outright products

 

 

Interest rate risk (general and specific)

 421

731

Equity risk (general and specific)

 374

122

Foreign exchange risk

 987

-

Commodity risk

 0

0

Options

 

 

Simplified approach

-

-

Delta-plus method

 

5

Scenario approach

-

-

Securitisation (specific risk)

 150

562

TOTAL

1,932

1,419

Outright products refer to positions in products that are not optional.

TABLE 94: MARKET RISK UNDER THE INTERNAL MODEL APPROACH (MR2-A)

 

Risk-weighted assets

Capital requirements

(In EURm)

31.12.2022

31.12.2021

31.12.2022

31.12.2021

1

VaR (higher of values a and b)

3,504

1,343

280

107

(a)

Previous day’s VaR (Article 365(1) (VaRt-1))

 

 

75

23

(b)

Average of the daily VaR (Article 365(1)) on each of the preceding sixty business days (VaRavg) x multiplication factor ((mc)
in accordance with Article 366)

 

 

280

107

2

SVaR (higher of values a and b)

6,886

7,227

551

578

(a)

Latest SVaR (Article 365(2) (SVaRt-1))

 

 

145

227

(b)

Average of the SVaR (Article 365(2) during the preceding sixty
business days (SVaRavg) x multiplication factor (ms) (Article 366)

 

 

551

578

3

Incremental risk charge – IRC
(higher of values a and b)

811

840

65

67

(a)

Most recent IRC value (incremental default and
migration risks section 3 calculated in accordance
with Section 3 articles 370/371)

 

 

53

67

(b)

Average of the IRC number over the preceding 12 weeks

 

 

65

66

4

Comprehensive Risk Measure – CRM
(higher of values a, b and c)

615

815

49

65

(a)

Most recent risk number for the correlation trading portfolio
(article 377)

 

 

42

40

(b)

Average of the risk number for the correlation trading portfolio
over the preceding 12-weeks

 

 

49

65

(c)

8% of the own funds requirement in SA on most recent risk number for the correlation trading portfolio (Article 338(4))

 

 

46

57

5

Other

-

-

-

-

6

TOTAL

11,816

10,225

945

818

TABLE 95: INTERNAL MODEL APPROACH VALUES FOR TRADING PORTFOLIOS (MR3)

(In EURm)

31.12.2022

31.12.2021

VaR (10 days, 99%)(1)

Maximum value

95

98

Average value

56

49

Minimum value

22

18

Period end

75

25

Stressed VaR (10 days, 99%)(1)

Maximum value

165

191

Average value

101

117

Minimum value

55

72

Period end

145

108

Incremental Risk Charge (99.9%)

Maximum value

114

205

Average value

71

116

Minimum value

50

51

Period end

53

67

Comprehensive Risk capital charge (99.9%)

Maximum value

133

102

Average value

51

64

Minimum value

39

40

Period end

42

57

(1)

On the perimeter for which the capital requirements are assessed by internal model.

TABLE 96: RWA FLOW STATEMENT OF MARKET RISK EXPOSURES UNDER THE INTERNAL MODEL APPROACH (MR2-B)

(In EURm)

VaR

SVaR

IRC

CRM

Other

Total RWA

Total own funds

requirements

RWA at end of previous reporting period (30.09.2022)

3,308

7,789

971

728

-

12,796

1,024

Regulatory adjustment

(2,363)

(6,294)

-

(62)

-

(8,719)

(697)

RWA at the previous quarter-end (end of the day)

945

1,496

971

666

-

4,078

326

Movement in risk levels

(472)

(662)

(307)

(145)

-

(1,585)

(127)

Model updates/changes

455

964

-

-

 

1,420

114

Methodology and policy

 

 

 

 

 

-

-

Acquisitions and disposals

 

 

 

 

 

-

-

Foreign exchange movements

8

10

 

 

 

18

1

Other

 

 

 

 

 

-

-

RWA at the end of the disclosure period (end of the day)

936

1,808

665

521

-

3,930

314

Regulatory adjustment

2,567

5,078

147

94

-

7,885

631

RWA at end of reporting period (31.12.2022)

3,504

6,886

811

615

-

11,816

945

Effects are defined as follows:

regulatory adjustment: difference between RWA used for the purpose of regulatory RWA calculation on the one hand and RWA of the last day or of the last week of the period on the other hand;

movement in risk levels: changes due to position changes;

model updates/changes: significant updates to the model to reflect recent experience (e.g. recalibration), as well as significant changes in model scope;

methodology and policy: methodology changes to the calculations driven by regulatory policy changes;

acquisitions and disposals: modifications due to acquisition or disposal of business/product lines or entities;

foreign exchange movements: changes arising from foreign currency fluctuations.

 

10 OPERATIONAL RISK

 

IN BRIEF

Operational risk is defined as the risk of loss resulting from inadequate or failed internal processes, people and systems or from external events.

Operational risk RWA at end 2022

€46bn

(Amount at end 2021: €46.8bn)

Share of RWA calculated via the advanced approach at end 2022

97%

In line with the Group’s Risk taxonomy, operational risk is one of the non-financial risks monitored by the Group. Operational risk is the risk of losses resulting from inadequacies or failures in processes, personnel or information systems, or from external events.

Societe Generale’s operational risk classification is divided into eight event categories:

commercial litigation;

disputes with authorities;

errors in pricing or risk evaluation including model risk;

execution errors;

fraud and other criminal activities;

rogue trading;

loss of operating resources;

IT system interruptions.

This classification ensures consistency throughout the system and enabling cross-business analyses throughout the Group (see section 4.10.2), particularly on the following risks:

risks related to information and communication technologies and security (cybercrime, IT systems failures, etc.);

risks related to outsourcing of services and business continuity;

risks related to the launch of new products/services/activities for customers;

non-compliance risk (including legal and tax risks) represents the risk of legal, administrative or regulatory sanctions, material financial loss, or loss to reputation a bank may suffer as a result of its failure to comply with national or European laws, regulations, rules, related self-regulatory organisation standards, and Codes of conduct applicable to its banking activities;

reputational risk arises from a negative perception on the part of customers, counterparties, shareholders, investors or regulators that could negatively impact the Group’s ability to maintain or engage in business relationships and to sustain access to sources of financing;

misconduct risk: risk resulting from actions (or inactions) or behavior of the Bank or its employees inconsistent with the Group’s Code of Conduct, which may lead to adverse consequences for our stakeholders, or place the Bank’s sustainability or reputation at risk.

The framework relating to the risks of non-compliance, reputation and inappropriate conduct is detailed in Chapter 13 “Compliance risk, litigation”.

10.1 ORGANISATION OF OPERATIONAL RISK MANAGEMENT

The Group operational risk management framework, other than non-compliance risks detailed in Chapter 13 “Compliance risk, litigation” is structured around a three-level system with the following participants:

a first line of defence in each core Business Units/Service Units, responsible for applying the framework and putting in place controls that ensure risks are identified, analysed, measured, monitored, managed, reported and contained with the limits set by the Group-defined risk appetite;

a second line of defence: the Operational Risk Department within the Group’s Risk Division.

In particular, the Operational Risk Department:

-

conducts a critical examination of the BU/SUs management of operational risks (including fraud risk, risks related to information systems and information security, and risks related to business continuity and crisis management),

-

sets regulations and procedures for operational risk systems and production of cross Group analyses,

-

produces risk and oversight indicators for operational risk frameworks.

To cover the whole Group, the Operational Risk Department has a central team supported by regional hubs. The regional hubs report back to the department, providing all information necessary for a consolidated overview of the Bank’s risk profile that is holistic, prospective and valid for both internal oversight purposes and regulatory reporting.

The regional hubs are responsible for implementing the Operational Risk Division’s briefs in accordance with the demands of their local regulators.

The Operational Risk Department communicates with the first line of defence through a network of operational risk correspondents in each Business/Service Units.

Concerning risks specifically linked to business continuity, crisis management and information, of persons and property, the Operational Risk Department carries out the critical review of the management of these risks in connection with the Group Security Division. Specifically, regarding IT risks, the Operational Risk Department carries out the critical review of the management of these risks in connection with the Resources and Digital Transformation Department.

a third line of defence in charge of the periodic controls, carried out by the General Inspection and Audit Division.

The implementation and monitoring of the operational risk management framework is part of the Group’s internal control framework:

level 1 control is performed as part of operations within each SG Group BU/SU/entity, including managerial supervision and operational controls. This permanent control framework is supervised by the Normative Controls Library (NCL), which brings together, for the entire Group, the control objectives defined by the expertise functions, the business lines, in connection with the second lines of defence;

level 2 control is carried out by dedicated teams in the Risk Division to carry out this mission on operational risks covering the risks specific to the various businesses (including operational risks related to credit and market risks), as well as the risks associated with purchases, communication, real estate, human resources and information system.

Protecting persons and property, and compliance with the laws and regulations governing security are major objectives for Societe Generale Group. It is the mission of the Group Security Division to manage human, organisational and technical frameworks that guarantee the smooth operational functioning of the Group in France and internationally, by reducing exposure to threats (in terms of security and safety) and reducing their impact in the event of crisis.

The security of persons and property encompasses two very specific areas:

security is all the human, organisational and technical resources brought together to deal with technical, physical, chemical and environmental accidents that can harm people and property;

safety is all the human, organisational and technical resources brought together to deal with spontaneous or thoughtful acts aimed at harming or impairing with the aim of psychic or/and financial profit.

The management of all these risks is based on operational risk systems and the second line of defence is provided by the Risk Department.

Given the importance for the Group of its information system and the data it conveys and the continuous increase in the cybercriminal threat, the risks related to information and communication technologies (ICT) and to security are major for Societe Generale. Their supervision, integrated into the general operational risk management system, is steered as the first line of defence by a dedicated area of expertise (Information and Information Systems Security – ISS) and the second line of defence is provided by the Risk Department. They are subject to specific monitoring by the management bodies through sessions dedicated to Group governance (Risk Committee, CORISQ, CCCIG, DTCO) and a quarterly dashboard which presents the risk situation and action plans on the main information and communication technologies risks.

The Department Security of the Group, housed within the General Secretariat, is responsible for protecting information. The information provided by customers, employees and also the collective knowledge and know-how of the bank constitute Societe Generale’s most valuable information resources. To this end, it is necessary to put in place the human, organisational and technical mechanisms which make it possible to protect the information and ensure that it is handled, disseminated, shared by only the people who need to know.

The person in charge of risks related to information and communication technologies (ICT) and security of information systems is housed at the Corporate Resources and Digital Transformation Division. Under the functional authority of the Director of Group Security, he recommends the strategy to protect digital information and heads up the IT Security Department. The IT security framework is aligned with the market standards (NIST, ISO 27002), and implemented in each Business/Service Unit.

Risk management associated with cybercrime is carried out through the tri-annual Information Systems Security (ISS) master plan.

In order to take into account the evolution of the threat, in particular that related to ransomware, and in line with the Group strategy, the ISS 2021-2023 master plan is structured, with a budget of EUR 650 million over the period 2021-2023, around two pillars that guide actions by 2023:

protect the data of our customers and our ability to operate the banking services, by integrating the threats, the requirements of the regulators, and the need to support the Business Units and Service Units in their digital transformation and the evolution of uses that accompanies it. A risk-based approach allows us to concentrate our efforts on the most critical elements and data, in connection with the work of the Security Department cited above. We are preparing to manage a major cyber crisis by improving in particular our detection capacity, our ability to control our IT links with our partners and subsidiaries, and our ability to rebuild the information system;

increase our operational efficiency by gaining overall consistency, and by increasing our protections and our ability to react. In particular by developing the management of the Cyber Security Department, by optimising our processes and our tools to be able to deploy new protections at constant cost. Finally, by working on the management of human resources in the filiere, in particular on the development of skills and networks of expertise.

At the operational level, the Group relies on a CERT (Computer Emergency Response Team) unit in charge of incident management, security watch and the fight against cybercrime. This team uses multiple sources of information and monitoring, both internal and external. Since 2018, this unit has also been strengthened by the establishment of an internal Red Team whose main tasks are to assess the effectiveness of the security systems deployed and to test the detection and reaction capabilities of the defence teams (Blue Teams) during an exercise simulating a real attack. The services of the Red Team enable the Group to gain a better understanding of the weaknesses in the security of the Societe Generale information system, to help in the implementation of global improvement strategies, and also to train cybersecurity defence teams. CERT works closely with the Security Operation Center (SOC), which is in charge of detecting security events and processing them.

A team at the Resources and Digital Transformation Department is in charge of the consistency of the implementation of operational risk management systems and their consolidation for IT processes. The main tasks of the team are as follows:

identify and evaluate the major IT risks for the Group, including extreme risk scenarios (e.g. cyberattack, failure of a provider), to enable the Bank to improve its knowledge of its risks, be better prepared for extreme risk scenarios and better align their investments with their IT risks;

produce the indicators that feed the IT risks monitoring dashboard, intended for management bodies and Information Systems Directors. They are reviewed regularly with the second line of defence in order to remain aligned with the IS and SSI strategy and their objectives;

more generally, ensure the quality and reliability of all devices addressing IT operational risks. Particular attention is paid to the permanent control system for its IT risks, which is based on the definition of normative IT and security controls and the support of the Group in the deployment of managerial supervision on this topic. As part of the “PCT” program to transform permanent control, the normative controls were reviewed, i.e. around thirty controls on IS/SSI subjects. The IT Department monitors the deployment of these controls across the Group, the progress of which is aligned with the objectives set by the Group.

In terms of awareness, a multilingual online training module on information security is mandatory for all internal Group staff and for all service providers who use or access our information system. It was updated in early 2020 in order to incorporate changes to the new Group Information Security Policy. At the end of August 2021, 98% of Societe Generale Group employees who were notified of the training module had performed it.

The supervision of fraud risk, whether internal or external, is integrated into the general operational risk management framework which allows the identification, assessment, mitigation and monitoring of the risk, whether it is potential or actual.

It is steered in the first line of defense by dedicated expert teams dedicated to fraud risks management in addition to the teams in charge of operational risk management specific to each of the banking businesses. These teams are in charge of the definition and operational implementation of the means of raising awareness, preventing, detecting and dealing with frauds. The second line of defense is provided by the Operational Risks Department with a fraud risk manager. The second line defines and verifies compliance with the principles of fraud risk management in conjunction with the first line teams, and ensures that the appropriate governance is in place.

Finally, the teams, whether they are in the first or second line of defense, work jointly with teams of experts in charge of information security, the fight against cyber crime, customer knowledge, the fight against corruption and money laundering. Likewise, the teams work closely with the teams in charge of credit risk and market risk. The sharing of information contributes to the identification and increased responsiveness in the presence of a situation of proven fraud or weak signals. This active collaboration makes it possible to initiate investigative measures, blocking attempted fraud or initiating the recovery of funds or the activation of guarantees, associated insurance in the event of successful fraud.

10.2 OPERATIONAL RISK MONITORING PROCESS

The Group’s main frameworks for controlling operational risks are as follows:

collection and analysis of internal operational losses and significant incidents that do not have a financial impact;

risk and control self-assessment (RCSA);

oversight of key risk indicators (KRI);

development of scenario analyses;

analysis of external losses;

framework of new products and services;

management of outsourced services;

crisis management and business continuity;

management of risks related to information and communication technologies.

Internal losses and significant incidents without any financial impact are compiled throughout the Group. The process:

monitors the cost of operational risks as they have materialised in the Group and establishes a historical data base for modelling the calculation of capital to be allocated to operational risk;

learns from past events to minimize future losses.

External losses are operational losses data shared within the banking sector. These external data include information on the amount of actual losses, the importance of the activity at the origin of these losses, the causes and circumstances and any additional information that could be used by other establishments to assess the relevance of the event as far as they are concerned and enrich the identification and assessment of the Group’s operational risk.

Under the Risk and Control Self-Assessment (RCSA), each manager assesses the exposure to operational risks of its activities within its scope of responsibility, in order to improve their management.

The method defined by the Group consists of taking a homogeneous approach to identifying and evaluating operational risks and frameworks to control these risks, in order to guarantee consistency of results at Group level. It is based notably on Group repositories of activities and risks in order to facilitate a comprehensive assessment.

The objectives are as follows:

identifying and assessing the major operational risks (in average amount and frequency of potential loss) to which each activity is exposed (the intrinsic risks, i.e. those inherent in the nature of an activity, while disregarding prevention and control systems). Where necessary, risk mapping established by the functions (e.g. Compliance, Information Systems Security, etc.) contributes to this assessment of intrinsic risks;

assessing the quality of major risk prevention and mitigation measures;

assessing the risk exposure of each activity that remains once the risk prevention and mitigation measures are taken into account (the “residual risk”), while disregarding insurance coverage;

remedying any shortcomings in the prevention and control systems, by implementing corrective action plans and defining key risk indicators; if necessary, in the absence of an action plan, risk acceptance will be formally validated by the appropriate hierarchical level;

adapting the risk insurance strategy, if necessary.

The exercise includes, in particular, risks of non-compliance, reputational risk, tax risks, accounting risks, risks related to information systems and their security, as well as those related to human resources.

Key risk indicators (KRIs) supplement the overall operational risk management system by providing a dynamic view (warning system) of changes in business risk profiles.

Their follow-up provides managers of entities with a regular measure of improvements or deteriorations in the risk and the environment of prevention and control of activities within their scope of responsibility.

KRIs help BU/SU/Entities and the Senior Management proactively and prospectively manage their risks, taking into account their tolerance and risk appetite.

An analysis of Group-level KRIs and losses is presented to the Group’s Executive Committee on a quarterly basis in a specific dashboard.

The analyses of scenarios serve two purposes: informing the Group of potential significant areas of risk and contributing to the calculation of the capital required to cover operational risks.

These analyses make it possible to build an expert opinion on a distribution of losses for each operational risk category and thus to measure the exposure to potential losses in scenarios of very severe severity, which can be included in the calculation of the prudential capital requirements.

In practice, various scenarios are reviewed by experts who gauge the severity and frequency of the potential impacts for the Group by factoring in internal and external loss data as well as the internal framework (controls and prevention systems) and the external environment (regulatory, business, etc.). Analyzes are carried out either at Group level (transversal scenarios) or at business level.

Governance is established in particular, to:

allow the approval of the annual scenarios update program by Senior Management through the Group Risk Committee (CORISQ);

allow the approval of the scenarios by the businesses (for example during the internal control coordination Committees of the BU and SU concerned or during ad hoc meetings) and a challenge of scenario analyses by LoD2;

conduct an overall review of the Group’s risk hierarchy and of the suitability of the scenarios through CORISQ.

Each division submits its plans for a new product and services to the New Product Committee. The Committee, jointly coordinated by a representative of the Group Risk Division and a representative of the relevant businesses division, is a decision-making body which decides the production and marketing conditions of new products and services to customers.

The Committee aims to ensure that, before any product launch or service, or before any relevant changes on an existing product or service, all types of induced risks (among them, credit, market, liquidity and refinancing, country, operational, legal, accounting, tax, financial, information systems risks as well as the risks of non-compliance, reputation, protection of personal data, corporate social and environmental responsibility risks, etc.) have been identified, assessed and, if necessary, subjected to mitigation measures allowing the acceptance of residual risks.

Some banking services are outsourced outside the Group or within the Group (e.g. in our shared service centers). These two subcontracting channels are supervised in a manner adapted to the risks they induce.

The management framework for outsourced services ensures that the operational risk linked to outsourcing is controlled, and that the conditions set by the Group’s approval are respected.

The objectives are as follows:

decide on outsourcing with knowledge of the risks taken; the entity remains fully responsible for the risks of the outsourced activity;

monitor outsourced services until they are closed, ensuring that operational risks are controlled;

map the Group’s outsourcing activities with an identification of the activities and BUs concerned in order to prevent excessive concentrations on certain service providers.

Crisis management and business continuity measures aim to minimize as much as possible the impact of potential disasters on customers, staff, activities or infrastructures, and thus to preserve the Group’s reputation and image as well as its financial strength.

Business continuity is managed by developing in each Societe Generale Group entity, organisations, procedures and resources that can deal with natural or accidental damage, or acts of deliberate harm, with a view to protect their personnel, assets and activities and to allow the provision of essential services to continue, if necessary, temporarily in reduced form, then restoring service to normal.

10.3 OPERATIONAL RISK MEASUREMENT

Since 2004, Societe Generale has used the Advanced Measurement Approach (AMA) allowed by the Capital Requirements Directive to measure operational risk. This approach, implemented across the main Group entities, notably makes it possible to:

identify the businesses that have the greatest risk exposures;

identify the types of risk that have the greatest impact on the Group’s risk profile and overall capital requirements;

enhance the Group’s management of operational risks.

The statistical method used by the Group for operational risk modeling is based on the Loss Distribution Approach (LDA) for AMA internal model.

Under this approach, operational risks are modeled using segments, each segment representing a type of risk and a Group core business. The frequency and severity of operational risks, based on past internal losses, external losses, the internal and external environment, and scenario analyses, are estimated and the distribution of annual losses is calculated for each segment. This approach is supplemented by cross-business scenario analyses that measure cross-business risks for core businesses, such as cybercriminality and the flooding of the river Seine.

Aside from the individual risks associated with each segment or cross-business scenario analysis, the model takes into account the diversification between the various types of risk and the core businesses, dependency effects between extreme risks as well as the effect of insurance policies taken out by the Group.

The Group’s regulatory capital requirements for operational risks within the scope covered by the (AMA) internal model are then defined as the 99.9% quantile of the Group’s annual loss distribution.

For some Group entities, notably in retail banking activities abroad, the standard method is applied: the calculation of capital requirements is defined as the average over the last three years of a financial aggregate based on the Product Net Banking multiplied by factors defined by the regulator and corresponding to each category of activity. To make the calculation, all of the Group’s business lines are broken down into the eight regulatory activities.

Societe Generale’s total capital requirements for operational risks were EUR 3.7 billion at the end of 2022, representing EUR 46 billion in risk-weighted assets. This assessment includes the capital requirement of AMA and Standard perimeters.

In accordance with regulations, Societe Generale incorporates risk cover provided by insurance policies when calculating regulatory capital requirements for operational risks, within the limit of 20% of said requirements. These insurance policies cover part of the Group’s major risks, i.e. civil liability, fraud, fire and theft, as well as systems interruptions.

Risk reduction through insurance policies resulted in a 6.5% decrease in total capital requirements for operational risks.

The following charts break down operating losses by risk category for the 2018-2022 period.

Over the past five years, Societe Generale’s operational risks were concentrated on average on five types, accounting for 94% of the Group’s total operating losses:

fraud and other criminal activities represented 33% of the amount of operating losses over the period. They are mainly composed of external frauds on financing files (falsified financial statements by the client, theft or misappropriation of collateral/guarantees, etc.), fraud on manual means of payment (cash, transfer and cheque) and supplier fraud on financed equipment; slight increase in 2022 due in particular to regularizations on old external fraud files;

execution errors represented 24% of total operational losses, thereby constituting the second leading cause of loss for the Group; The decrease trend that began in 2021, continues in 2022 thanks to the proper execution of the remediation plans;

litigation with authorities, the third largest category, represented 15% of the Group’s operational losses over the period; the net amount of provisions for litigation has decreased in 2022 compared to 2021;

pricing or risk assessment errors, including model risk, represent 13% of the total amount of losses. The main cases concern the pricing and ALM models;

commercial disputes represented 9% of total Group operating losses.

The other categories of Group operational risk (activities not authorised on the markets, system interruptions, loss of operating environment/capability) were still relatively insignificant, representing 6% of the Group’s losses on average over the 2018 to 2022 period.

10.4 RISK-WEIGHTED ASSETS AND CAPITAL REQUIREMENTS

Societe Generale’s capital requirements for operational risk are mainly calculated using the Advanced Measurement Approach (AMA) via its internal model (97% in 2022).

The total amount of RWA decreased in 2022 (EUR -0.8 billion, i.e. -1.7%) mainly due to the sale of Russian business.

The following table breaks down the Group’s risk-weighted assets and the corresponding capital requirements at 31 December 2022.

(In EURm)

31.12.2022

Relevant indicator

Own funds

requirements

Risk-weighted

assets

Banking activities

31.12.2020

31.12.2021

31.12.2022

Banking activities subject to basic indicator approach (BIA)

0

0

0

0

0

Banking activities subject to standardised (TSA)/alternative standardised (ASA) approaches

1,184

1,337

1,245

103

1,290

Subject to TSA

1,184

1,337

1,245

 

 

Subject to ASA

0

0

0

 

 

Banking activities subject to advanced measurement approaches AMA

21,964

23,980

27,186

3,579

44,733

(In EURm)

31.12.2021

Relevant indicator

Own funds

requirements

Risk-weighted

assets

Banking activities

31.12.2019

31.12.2020

31.12.2021

Banking activities subject to basic indicator approach (BIA)

-

-

-

-

-

Banking activities subject to standardised (TSA)/alternative standardised (ASA) approaches

1,365

1,437

1,481

193

2,412

Subject to TSA

1,365

1,437

1,481

 

 

Subject to ASA

-

-

-

 

 

Banking activities subject to advanced measurement approaches AMA

23,643

21,964

23,980

3,552

44,394

(1)

Historical data including the updates, reflecting some evolutions in the scope of entities, which occurred across the year.

10.5 OPERATIONAL RISK INSURANCE

Since 1993, Societe Generale has implemented a global policy of hedging Group operational risks through insurance.

This consists in searching the market for the most extensive cover available for the risks incurred and enabling all entities to benefit from such cover wherever possible. Policies are taken out with leading insurers. Where required by local legislation, local policies are taken out, which are then reinsured by insurers that are part of the global program.

In addition, special insurance policies may be taken out by entities that perform specific activities.

A Group internal reinsurance company intervenes in several policies in order to pool high-frequency, low-level risks between entities. This approach contributes to the improvement of the Group’s knowledge and management of its risks.

Buildings and their contents, including IT equipment, are insured at their replacement value. The guarantee covering acts of terrorism abroad has been renewed.

Liability other than professional liability (i.e. relating to operations, Chief Executive Officers and Directors, etc.) are covered. The amounts insured vary from country to country, according to operating requirements.

Insurance is only one of the measures used to offset the consequences of the risks inherent in the Group’s activity. It complements the Group’s risk management policy.

These risks are included in the “Banker’s Blanket Bond” policy that insures all the Group’s financial activities around the world.

Internal fraud (committed by an employee or by a third party acting with the aid of an employee) and external fraud (committed by a third party acting alone), with the intent to obtain illicit personal gain or to harm the Group, are covered.

The consequences of any legal on staff or managers in the Group’s professional activities are insured under a global policy.

A cyber risk insurance policy has been taken out amid an environment not specific to the banking sector which is seeing a rapid development of new forms of crime mainly involving data theft or the compromise or destruction of computer systems.

 

11 STRUCTURAL INTEREST RATE AND EXCHANGE RATE RISKS

 

IN BRIEF

Structural interest rate and exchange rate risks correspond to the risk of losses of interest margin or value of the fixed rate structural position arising from variations in interest or exchange rates. Structural interest rate and exchange rate risks arise from commercial activities and from transactions entered into by the Corporate Centre.

This section describes the monitoring of structural risks and provides information on structural interest rate and exchange rate risks.

Structural exposure to interest rate and exchange rate risks results from commercial transactions, their associated hedging transactions and corporate centre transactions.

The interest rate and exchange rate risks linked to Trading Book activities are excluded from the structural risk measurement scope as they belong to the category of market risks.

Structural and market exposures constitute the Group’s total interest rate and exchange rate exposure.

The general principle for managing structural interest rate and exchange rate risks within consolidated entities is to ensure that adverse movements in interest rates do not significantly threaten the Group’s financial base or its future earnings.

Within the entities, commercial and corporate centre operations must therefore be matched in terms of interest rates and exchange rates as much as possible. At the consolidated level, a structural foreign exchange position is maintained in order to minimise the sensitivity of the Group’s Common Equity Tier 1 (CET1) ratio to exchange rates fluctuations.

11.1 ORGANISATION OF THE MANAGEMENT OF STRUCTURAL INTEREST RATE AND EXCHANGE RATE RISKS

The principles and standards for managing these risks are defined at the Group level. The entities are first and foremost responsible for managing these risks. The ALM (Asset and Liability Management) Department within the Group’s Finance Division leads the control framework of the first line of defense. The ALM department of the Risk Department assumes the role of second line of defense supervision.

The purpose of the Group Finance Committee is to:

validate and ensure the adequacy of the system for monitoring, managing and supervising structural risks;

review changes in the Group’s structural risks through consolidated reporting;

review and validate the measures proposed.

The Finance Committee gives delegation to the Global Rate Forex Committee chaired by the Finance Department and the Risk Division for the validation of frameworks not exceeding defined amounts.

The ALM (Asset and Liability Management) Department is responsible for:

defining the structural risk policies for the Group and formalising risk appetite;

analysing the Group’s structural risk exposure and defining hedging strategies;

monitoring the regulatory environment concerning structural risk;

defining the ALM principles for the Group;

defining the modelling principles applied by the Group’s entities regarding structural risks;

identifying, consolidating and reporting on Group structural risks;

monitoring compliance with structural risk limits.

Within the Risk Division, the ALM Risk Department oversees structural risks and assesses the management system for these risks. As such, this department is in charge of:

defining the steering indicators and overall stress test scenarios of the different types of structural risks and setting the main limits for the business divisions and the entities and Business Units (BU) and Service Units (SU);

defining the normative environment of the structural risk metrics, modelling and framing methods.

In addition, by delegation of MRM, this department ensures the validation of ALM models for which it organizes and chairs the Validation Committee of Models. Finally, he chairs the Model Validation Committee and the ALM Standards Validation Committee and thus ensures that the regulatory framework is correctly interpreted and that the SG environment is properly adapted.

Each entity, each BU/SU, manages its structural risks and is responsible for regularly assessing risks incurred, producing the risk report and developing and implementing hedging options. Each entity, each BU/SU is required to comply with Group standards and to adhere to the limits assigned to it.

As such, the entities and the BUs/SUs apply the standards defined at Group level and develop the models, with the support of the central modelling teams of the Finance Department.

A dedicated ALM manager reporting to the Finance Department in each entity, BU/SU, is responsible for monitoring these risks (first-level control). This manager is responsible for reporting ALM risks to the Group Finance Department. All entities, BU/SU, have an ALM Committee responsible for implementing validated models, managing exposure to interest rate and exchange rate risks and implementing hedging programmes in accordance with the principles set out by the Group and the limits validated by the Finance Committee and the BU/SU ALM Committees.

11.2 STRUCTURAL INTEREST RATE RISK

Structural interest rate risk is generated by commercial transactions and their hedging, as well as the management operations specific to each of the consolidated entities.

The objective of managing structural interest rate risk is to manage exposure of each Group entity.

To this end, the Board of Directors, the Finance Committee and the ALM Committee set sensitivity limits (in terms of value and income) for the Group, the BUs/SUs and the entities respectively.

Societe Generale uses several indicators to measure the Group’s overall interest rate risk.

The three most important indicators are:

the sensitivity of the net present value (NPV) to the risk of interest rate mismatch. It is measured as the sensitivity of the net present value of the static balance sheet to a change in interest rates. This measure is calculated for all currencies to which the Group is exposed;

the sensitivity of the interest margin to changes in interest rates in various interest rate scenarios. It takes into account the sensitivity generated by future commercial production;

the sensitivity of NPV to basis risk (risk associated with decorrelation between different variable rate indices).

Limits on these indicators are applicable to the Group, the BUs/SUs and the various entities. Limits are set for shocks at +/-0.1% and for stressed shocks (+/-1% for value sensitivity and +/-2% for income sensitivity) without floor application. Only the sensitivity of income over the first two years is framed. The measurements are computed monthly 10 months a year (with the exception of the months of January and July for which no Group-level closing is acheved). An additional synthetic measurement of value sensitivity – all currencies – is framed for the Group. To comply with these frameworks, the entities combine several possible approaches:

orientation of the commercial policy so as to offset interest rate positions taken on the asset and liability side;

implementation of a swap operation or – failing this in the absence of such a market – use of a loan/borrowing operation;

purchase/sale of options on the market to cover optional positions taken vis-à-vis our clients.

Assets and liabilities are analysed without a prior allocation of resources to uses. Maturities of outstanding amounts are determined by taking into account the contractual characteristics of the transactions, adjusted for the results of customer behaviour modelling (in particular for demand deposits, savings and early loan repayments), possibly differentiated according to the rate scenario considered, as well as a certain number of disposal agreements, in particular on equity items.

As at 31 December 2022, the main models applicable for the calculation of interest rate risk measurements are : models – sometimes dependent rates– on part of the deposits without a maturity date leading to an average duration of less than 5 years– the schedule may in some cases to reach the maximum maturity of 20 years.

The automatic balance sheet options are taken into account:

either via the Bachelier formula or possibly from Monte-Carlo type calculations for value sensitivity calculations;

or by taking into account the pay-offs depending on the scenario considered in the income sensitivity calculations

Changes in OCI or P&L of instruments recognised at fair value are not included in the controlled income sensitivity measures.

Hedging transactions are mainly documented from an accounting viewpoint: this can be carried out either as micro-hedging (individual hedging of commercial transactions and hedging instruments) or as macro-hedging under the IAS 39 “carve-out” arrangement (global backing of portfolios of similar commercial transactions within a Treasury Department; macro-hedging concerns essentially French retail network entities).

Macro-hedging derivatives are essentially interest rate swaps in order to maintain networks’ net asset value and result sensitivity within limit frameworks, considering hypotheses applied. For macro-hedging documentation, the hedged item is an identified portion of a portfolio of commercial client or interbank operations. Conditions to respect in order to document hedging relationships are reminded in Note 3.2 to the consolidated financial statements.

Macro-hedging derivatives are allocated to separate portfolios according to whether they are used to hedge fixed-rate assets or liabilities in the accounting books. The hedging instrument portfolios allocated to liability elements are net fixed-rate receiver/variable-rate payer whereas the hedging instrument portfolios allocated to asset elements are net fixed-rate payer/variable-rate receiver.

In the context of the macro-hedging, the controls carried out and documented enable to verify that intra-group transactions are returned to the market, to verify the non-over hedging and the non-disappearence of the items hedged and the effectiveness of the hedges (MTM change in hedging instruments / MTM change in hedged items in the 80-125% range).

(In EURm)

31.12.2022

Changes of the economic value

of equity (EVE)

Changes of the net interest income

(NII)

Supervisory shock scenarios

 

 

1

Parallel up

(2,900)

 375

2

Parallel down 

1,011

(1,102)

3

Steepener 

1,875

 

4

Flattener

(2,547)

 

5

Short rates up

(2,747)

 

6

Short rates down

2,862

 

(In EURm)

30.06.2022

Changes of the economic value

of equity (EVE)

Changes of the net interest income

(NII)

Supervisory shock scenarios

 

 

1

Parallel up

(3,080)

991

2

Parallel down 

(1,375)

(470)

3

Steepener 

800

 

4

Flattener

(2,641)

 

5

Short rates up

(2,627)

 

6

Short rates down

810

 

Regulatory metrics are calculated in accordance with the provisions imposed by the regulator (EBA GL 2018/02).

11.3 STRUCTURAL EXCHANGE RATE RISK

Structural exchange rate risk, understood as resulting from all transactions that do not belong to the Trading Book, results from:

exposures related to net investments abroad in foreign currencies, i.e. in subsidiaries and branches. FX positions generated by an imperfect hedge are valued through other comprehensive income;

exposures related to activities made by entities in currencies that are not their reporting currency.

The Group’s policy is to make the CET1 ratio insensitive to fluctuations in exchange rates against the euro.

As such:

Group entities are asked to individually hedge the results related to activities in currencies other than their reporting currency;

the foreign exchange position generated by investments in foreign holdings and branches, as well as by the conversion of their results into euros, is partially covered centrally: at the level of the Group Finance Division. Societe Generale retains a target exposure multiplied by the RWA generated in this currency in each RWA constituent currency equivalent to the level of the CET1 Target Group ratio and covers the balance by borrowings or forward foreign exchange transactions denominated in the currency of investments and recognised as investment hedging instruments (cf. Note 3.2.2 in the consolidated financial statements set out in Chapter 6 of the Universal Registration Document) .

For each currency, the difference between actual and target exposure is governed by limits validated by the General Management in Finance Committee and the Board of Directors.

Similarly, the sensitivities of the CET1 ratio to shocks of +/-10% per currency are framed.

 

Impact of a 10% currency depreciation on the

Common Equity Tier 1 ratio

Impact of a 10% currency appreciation on the

Common Equity Tier 1 ratio

Currency

31.12.2022

31.12.2021

31.12.2022

31.12.2021

CHF

0.2

(0.1)

(0.2)

0.1

CZK

(0.4)

0.4

0.4

(0.4)

MAD

(0.2)

-

0.2

-

RON

0.3

0.4

(0.3)

(0.4)

RUB

0.3

0.5

(0.3)

(0.5)

TND

(0.2)

0.1

0.2

(0.1)

TRY

0.2

-

(0.2)

0.0

USD

0.6

0.8

(0.6)

(0.8)

XAF

(0.6)

0.6

0.6

(0.6)

Autres

(0.8)

0.1

0.8

(0.1)

 

12 LIQUIDITY RISK

 

IN BRIEF

Liquidity risk is defined as the Group’s inability to meet its financial obligations at a reasonable cost. Funding risk is defined as the risk of the Group being unable to finance the development of its activities in line with its commercial objectives and at a competitive cost.

Liquidity reserve at end 2022

€279bn

(Amount at end 2021: €229bn)

Liquidity risk is defined as the risk that the bank does not have the necessary funds to meet its commitments. Funding risk is defined as the risk that the Group will no longer be able to finance its activities with appropriate column of assets and at a reasonable cost.

12.1 OBJECTIVES AND GUIDING PRINCIPLES

The liquidity and funding management set up at Societe Generale aims at ensuring that the Group can (i) fulfil its payment obligations at any moment in time, during normal course of business or under lasting financial stress conditions (management of liquidity risks); (ii) raise funding resources in a sustainable manner, at a competitive cost compared to peers (management of funding risks). Doing so, the liquidity and funding management ensures compliance with risk appetite and regulatory requirements

To achieve these objectives, Societe Generale has adopted the following guiding principles:

liquidity risk management is centralised at Group level, ensuring pooling of resources, optimisation of costs and consistent risk management. Businesses must comply with static liquidity deadlocks in normal situations, within the limits of their supervision and the operation of their activities, by carrying out operations with the “own management” entity, where appropriate, according to an internal refinancing schedule. Assets and liabilities with no contractual maturity are assigned maturities according to agreements or quantitative models proposed by the Finance Department and by the business lines and validated by the Risk Division;

funding resources are based on business development needs and the risk appetite defined by the Board of Directors. See section 2;

financing resources are diversified by currencies, investor pools, maturities and formats (vanilla issues, structured, secured notes, etc.). Most of the debt is issued by the parent company. However, Societe Generale also relies on certain subsidiaries to raise resources in foreign currencies and from pools of investors complementary to those of the parent company;

liquid reserves are built up and maintained in such a way as to respect the stress survival horizon defined by the Board of Directors. Liquid reserves are available in the form of cash held in central banks and securities that can be liquidated quickly and housed either in the banking book, under direct or indirect management of the Group Treasury. in the trading book within the market activities under the supervision of the Group Treasury;

the Group has options that can be activated at any time under stress, through an Emergency Financing Plan (EFP) at Group level (except for insurance activities, which have a separate contingency plan), defining leading indicators for monitoring the evolution of the liquidity situation, operating procedures and remedial actions that can be activated in a crisis situation.

12.2 OPERATIONAL IMPLEMENTATION

The key operational steps of liquidity and funding management are as follows:

risk identification is a process which is set out and documented by the Risk Division, in charge of establishing a mapping of liquidity risks. This process is conducted yearly with each Business Unit and within the Group Treasury Department, aimed at screening all material risks and checking their proper measurement and capturing the control framework. In addition, a Reverse Stress Testing process exists, which aims at identifying and quantifying the risk drivers which may weigh most on the liquidity profile under assumptions even more severe than used in the regular stress test metrics;

definition, implementation and periodic review of liquidity models and conventions used to assess the duration of assets and liabilities and to assess the liquidity profile under stress. Liquidity models are managed along the overall Model Risk Management governance, also applicable to other risk factors (market, credit, operational), controlled by the Group Risk division;

yearly definition of the risk appetite for liquidity and funding risks, whereby the Board of Directors approves financial indicators framing that have been proposed by General Management. Such risk appetite targets are then cascaded down per Business Units. The risk appetite is framed along the following metrics:

-

key regulatory indicators (LCR, Adjusted LCR excess in USD, and NSFR),

-

the footprint of the Group in Short-Term Wholesale funding markets,

-

the survival horizon under an adverse stress scenario, combining a severe market and systemic shock and an idiosyncratic shock. In addition to the main adverse scenario, Societe Generale also checks its survival horizon under an extreme stress scenario. For both scenarios, the idiosyncratic shock is characterised by one of its main consequences, which would be an immediate 3-notch downgrade of Societe Generale’s long-term rating. In such adverse or extreme scenarios, the liquidity position of the Group is assessed over time, taking into account the negative impacts of the scenarios, such as deposit outflows, drawing by clients of the committed facilities provided by Societe Generale, increase in margin calls related to derivatives portfolios, etc. The survival horizon is the moment in time when the net liquidity position under such assumptions becomes negative,

-

the overall transformation position of the Group (static liquidity deadlock in normal situation matured up to a maturity of 5 years),

-

the amount of free collaterals providing an immediate access to central bank funding, in case of an emergency (only collaterals which do not contribute to the numerator of the LCR are considered, i.e. non-HQLA collaterals);

the financial trajectories under baseline and stressed scenarios are determined within the framework of the funding plan to respect the risk appetite. The budget’s baseline scenario reflects the central assumptions for the macro-economic environment and the business strategy of the Group, while the stressed scenario is factoring both an adverse macro-economic environment and idiosyncratic issues;

the funding plan comprises both the long-term funding programme, which frames the issuance of plain vanilla bonds and structured notes, and the plan to raise short-term funding resources in money markets;

the Funds Transfer Pricing (FTP) mechanism, drawn up and maintained within the Group Treasury, provides internal refinancing schedules that enable businesses to recover their excess liquidity and finance their needs through transactions carried out with its own management;

production and broadcasting of periodic liquidity reports, at various frequencies (daily indicators, weekly indicators, monthly indicators), leveraging in most part on the central data repository, operated by a dedicated central production team. The net liquidity position under the combined (idiosyncratic and market/systemic) stress scenario is reassessed on a monthly basis and can be analysed along multiple axes (per product, Business Unit, currency, legal entity). Each key metric (LCR, NSFR, transformation positions, net liquidity position under combined stress) is reviewed formally on a monthly basis by the Group Finance and Risk divisions. Forecasts are made and revised weekly by the Strategic and Financial Steering Department and reviewed during a Weekly Liquidity Committee chaired by the Head of Group Treasury. This Weekly Liquidity Committee gives tactical instructions to Business Units, with the objective to adjust in permanence the liquidity and funding risk profile, within the limits and taking into account business requirements and market conditions;

preparation of a Contingency Funding Plan, which is applicable Group-wide, and provides for: (i) a set of early warning indicators (e.g. market parameters or internal indicators); (ii) the operating model and governance to be adopted in case of an activation of a crisis management mode (and the interplay with other regimes, in particular Recovery management); (iii) the main remediation actions to be considered as part of the crisis management.

These various operational steps are part of the ILAAP (Internal Liquidity Adequacy Assessment Process) framework of Societe Generale.

Every year, Societe Generale produces for its supervisor, the ECB, a self-assessment of the liquidity risk framework in which key liquidity and funding risks are identified, quantified and analysed with both a backward and a multi-year forward-looking perspective. The adequacy self-assessment also describes qualitatively the risk management set up (methods, processes, resources…), supplemented by an assessment of the adequacy of the Group’s liquidity.

12.3 GOVERNANCE

The main liquidity risk governance bodies are as follows:

the Board of Directors, which:

-

sets yearly the level of liquidity risk tolerance as part of the Group’s risk appetite, based on a set of key metrics, which includes both internal and regulatory metrics, in particular the period of time during which the Group can operate under stressed conditions (“survival horizon”),

-

approves financial indicators framing including the scarce resources indicators framing,

-

reviews at least quarterly the Group’s liquidity and funding situation: key liquidity metrics, including stressed liquidity gap metrics as evaluated through Societe Generale group models, the regulatory metrics LCR and NSFR, the pace of execution of the funding plan and the related cost of funds;

General Management, which:

-

allocates liquidity and funding targets to the various Business Units and the Group Treasury entity, upon proposal from the Group Finance division,

-

defines and implements the liquidity and funding risk strategy, based on inputs from the Finance and Risk Divisions and the Business Units. In particular, the General Management chairs the Finance Committee, held every 6 weeks and attended by representatives from the Finance and Risk Divisions and Business Units, which is responsible for monitoring structural risks and managing scarce resources:

validation and monitoring of the set of limits for structural risks, including liquidity risk,

monitoring of budget targets and decisions in case of a deviation from the budget,

definition of principles and methods related to liquidity risk management (e.g. definition of stress scenarios),

assessment of any regulatory changes and their impacts;

the Group Finance Division, which is responsible for the liquidity and funding risks as First Line of Defense, interacting closely with Business Units. Within the Group Finance Division, there are three main departments involved respectively in the preparation and implementation of decisions taken by the abovementioned bodies:

-

the Strategic and Financial Steering Department is responsible for framing and steering the Group’s scarce resources, including liquidity, within the Group’s risk appetite and financial indicators framing,

-

the Group Treasury Department is in charge of all aspects of the operational management of liquidity and funding across the Group, including managing the liquidity position, executing the funding plan, supervising and coordinating treasury functions, providing operational expertise in target setting, managing the liquidity reserves and the collateral used in funding transactions, managing the corporate centre,

-

the Asset and Liability Management Department is in charge of the definition of modelling and monitoring structural risks, including liquidity risk alongside interest rate and foreign exchange risks in the Banking Book.

also sitting with the Group Finance Division, the Metrics Production Department runs the management information system regarding liquidity and funding risks across the Group. For liquidity metrics, the Group relies on a centralised system architecture, with all Business Units feeding a central data repository from which all metrics are produced, either regulatory metrics (e.g. the LCR or the NSFR) or metrics used for internal steering (e.g. stress test indicators);

the ALM Risk Department, which perform as the second line of defense functions, ensure the supervision of liquidity risks and evaluates the management system for these risks. As such, it is in charge of:

-

the definition of liquidity indicators and the setting of the main existing limits within the Group,

-

the definition of the normative framework for measuring, modelling methods and monitoring these risks.

In addition, by delegation of MRM, this department ensures the validation of ALM models for which it organises and chairs the Validation Committee of Models.

Finally, it ensures the correct interpretation of the regulatory framework as well as an adequate implementation in the Societe Generale environment.

12.4 ASSET ENCUMBRANCE

An asset shall be treated as encumbered if it has been pledged or if it is subject to any form of arrangement to secure, collateralise or credit enhance any transaction from which it cannot be freely withdrawn.

Total Group encumbrance amounts to 36% over 2022, measured according to the EBA definition(1). Securities encumbrance is 78%, while loan encumbrance is 16%.

The majority of the Group's encumbered assets (around 76%) is in the form of securities as a result of the relative size of capital market activities, mainly through repos, reverse repos and collateral swaps.

Securities encumbrance is concentrated in SGPM and its branches, where Group market activities are located.

The main sources of encumbrance are repo operations and debt securities issued. Encumbrance on assets in US dollars stems mainly from debt securities.

The level of encumbered loans varies among Group entities mainly due to their respective business models, funding strategies and the type of underlying loans, as well as to the law governing them. The main sources of loans encumbrance are in euros and to a lesser extent in US dollars. A few points are noteworthy:

at SGPM level, the loan encumbrance rate amounts to close to 29%(2) at 2022 year-end, stemming mainly from housing loans. Encumbered loans are affected as collateral for the ECB’s TLTRO operations as well as long-term refinancing mechanisms which are broadly used by banks for covered bonds (SG SFH, SG SCF and CRH), securitisations or specific mechanisms;

at subsidiary level, the loan encumbrance rate stands at 21%(2) overall, with discrepancies between entities due to different funding strategies. The highest levels of secured funding correspond to entities which contribute to the pooling scheme (see below) or having implemented external funding programmes through securitisations such as BDK (Bank Deutsches Kraftfahrzeuggewerbe) and ALD, or other forms of secured funding. Besides, some subsidiaries (Crédit du Nord) have participated directly in TLTRO operations, which in turn impacted their loan encumbrance rate.

As far as the loan encumbrance is concerned, there is a pooling scheme in which Crédit du Nord, Boursorama and to a lesser extent BFCOI (Réunion) bring a share of their housing loans portfolio to the Group. The surplus of loans encumbrance stemming from intra-group transactions represent approximately 13.6% of the total Group loans encumbrance.

In 2022, cover pools of retained covered bonds and securitized portfolios of retained Asset Backed Securities amounted respectively to EUR 46 billion and EUR 14 billion for outstanding amounts of issuances of respectively EUR 38.6 billion and EUR 12.7 billion. Loan encumbrance ratios linked to those portfolios were respectively 77.7% and 74.7%.

Regarding major long-term secured funding mechanisms, over-collateralisation on covered bond vehicles was 127% on SG SCF and 114% on SG SFH as of 31 December 2022.

As far as SG SFH is concerned, underlying assets are mortgage loans guaranteed by Crédit Logement.

Regarding SG SCF, assets consist of exposures on public sector entities.

The unencumbered “Other assets” (excluding loans) include all derivatives and options products (interest rate swaps, cross currency swaps, currency options, warrants, futures, forward contracts…) for an amount of EUR 109 billion as of end 2022 as well as some other assets that cannot be encumbered in the normal course of business too. These assets include goodwill, fixed assets, deferred tax, adjustment accounts, sundry debtors and other assets. Overall, assets that cannot be encumbered (derivatives products and other assets listed above) represent 18% of the total balance sheet as of end 2022.

(1)

Median values on quarterly data.

(2)

According to a methodology consisting of encumbering the least liquid eligible assets (encumbered loans/total loans) first.

(In EURm)

31.12.2022(1)

Carrying amount of encumbered assets

Fair value of encumbered assets

Carrying amount of unencumbered assets

Fair value of unencumbered assets

 

of which
EHQLA & HQLA

 

of which
EHQLA & HQLA

 

of which
EHQLA & HQLA

 

of which EHQLA & HQLA

Assets of the reporting institution

245,260

66,953

 

 

1,170,947

239,564

 

 

Equity instruments

44,314

34,744

44,314

34,744

34,809

10,745

34,809

10,745

Debt securities

37,035

32,946

37,035

32,946

53,416

34,491

53,416

34,491

of which covered bonds

237

116

237

116

213

207

213

207

of which asset-backed securities

198

62

198

62

3,969

44

3,969

44

of which issued by general governments

32,245

31,836

32,245

31,836

27,519

27,519

27,519

27,519

of which issued by financial corporations

4,945

667

4,945

667

11,397

2,586

11,397

2,586

of which issued by non-financial corporations

1,092

416

1,092

416

8,780

241

8,780

241

Other asset

157,853

371

 

 

1,080,829

195,972

 

 

of which Loans on demand

7,533

-

 

 

227,227

191,248

 

 

of which Loans and advances other than loans on demand

148,455

371

 

 

568,399

2,008

 

 

of which other

1,799

-

 

 

264,610

2,498

 

 

(1)

Table's figures are calculated as medians of the four quarters across 2022.

(In EURm)

31.12.2021(1)

Carrying amount of encumbered assets

Fair value of encumbered assets

Carrying amount of unencumbered assets

Fair value of unencumbered assets

 

of which
EHQLA & HQLA

 

of which
EHQLA & HQLA

 

of which
EHQLA & HQLA

 

of which EHQLA & HQLA

Assets of the reporting institution

253,755

94,731

 

 

1,087,854

226,154

 

 

Equity instruments

76,424

58,720

76,424

58,720

48,946

16,193

48,946

16,193

Debt securities

39,838

36,010

39,838

36,010

61,276

41,592

61,276

41,592

of which covered bonds

135

101

135

101

274

224

274

224

of which asset-backed securities

130

74

130

74

3,262

60

3,262

60

of which issued by general governments

34,611

34,104

34,611

34,104

31,770

31,770

31,770

31,770

of which issued by financial corporations

3,052

1,345

3,052

1,345

18,816

3,685

18,816

3,685

of which issued by non-financial corporations

2,256

587

2,256

587

9,183

397

9,183

397

Other asset

138,329

-

 

 

973,492

169,936

 

 

of which Loans on demand

5,477

-

-

-

196,750

166,301

-

-

of which Loans and advances other than loans on demand

131,769

-

-

-

513,061

1,282

-

-

of which: other

1,719

-

-

-

257,793

2,373

-

-

(1)

Table's figures are calculated as medians of the four quarters across 2021.

(In EURm)

31.12.2022(1)

Fair value of encumbered collateral received or
own debt securities issued

Fair value of collateral received or own debt
securities issued available for encumbrance

 

of which
EHQLA
& HQLA(1)

 

of which
EHQLA
& HQLA(1)

Collateral received by the reporting institution

434,458

365,124

58,616

47,748

Loans on demand

-

-

-

-

Equity instruments

94,565

52,173

9,649

5,849

Debt securities

339,536

311,931

48,890

41,462

of which covered bonds

3,833

2,057

2,724

2,415

of which asset-backed securities

4,338

840

6,382

2,142

of which issued by general governments

308,331

303,518

37,511

36,407

of which issued by financial corporations

20,528

4,179

8,146

2,567

of which issued by non-financial corporations

10,136

4,442

3,535

2,349

Loans and advances other than loans on demand

-

-

-

-

Other collateral received

-

-

-

-

Own debt securities issued other than own covered bonds or asset-backed securities

1,857

-

39

-

Own covered bonds and asset-backed securities issued and not yet pledged

 

 

8,585

-

TOTAL ASSETS, COLLATERAL RECEIVED AND OWN DEBT SECURITIES ISSUED

676,627

432,077

 

 

(1)

Table's figures are calculated as medians of the four quarters across 2022.

(In EURm)

31.12.2021(1)

Fair value of encumbered collateral received or
own debt securities issued

Fair value of collateral received or own debt
securities issued available for encumbrance

 

of which
EHQLA
& HQLA(1)

 

of which
EHQLA
& HQLA(1)

Collateral received by the reporting institution

371,005

318,340

63,028

46,853

Loans on demand

-

-

-

-

Equity instruments

77,453

45,080

12,019

5,765

Debt securities

294,793

271,918

51,145

41,326

of which covered bonds

2,490

990

4,237

3,948

of which asset-backed securities

4,292

2,357

3,835

707

of which issued by general governments

270,974

265,510

39,288

35,895

of which issued by financial corporations

15,449

2,975

9,284

4,155

of which issued by non-financial corporations

8,642

3,484

2,096

716

Loans and advances other than loans on demand

-

-

-

-

Other collateral received

-

-

-

-

Own debt securities issued other than own covered bonds or asset-backed securities

1,602

-

29

-

Own covered bonds and asset-backed securities issued and not yet pledged

 

 

8,253

-

TOTAL ASSETS, COLLATERAL RECEIVED AND OWN DEBT SECURITIES ISSUED

625,152

413,070

-

-

(1)

Table's figures are calculated as medians of the four quarters across 2021.

(In EURm)

31.12.2022(1)

Matching liabilities, contingent
liabilities or securities lent

Assets, collateral received
and own debt securities issued other
than covered bonds
and ABSs encumbered

Carrying amount of selected financial liabilities

407,205

447,332

(1)

Table's figures are calculated as medians of the four quarters across 2022.

(In EURm)

31.12.2021(1)

Matching liabilities, contingent
liabilities or securities lent

Assets, collateral received
and own debt securities issued other
than covered bonds
and ABSs encumbered

Carrying amount of selected financial liabilities

402,302

424,769

(1)

Table's figures are calculated as medians of the four quarters across 2021.

12.5 LIQUIDITY RESERVE

The Group’s liquidity reserve encompasses cash at central banks and assets that can be used to cover liquidity outflows under a stress scenario. The reserve assets are available, i.e. not used in guarantee or as collateral on any transaction. They are included in the reserve after applying a haircut to reflect their expected valuation under stress. The Group’s liquidity reserve contains assets that can be freely transferred within the Group or used to cover subsidiaries’ liquidity outflows in the event of a crisis: non-transferable excess cash (according to the regulatory ratio definition) in subsidiaries is therefore not included in the Group’s liquidity reserve.

The liquidity reserve includes:

central bank deposits, excluding mandatory reserves;

High-Quality Liquid Assets (HQLAs), which are securities that can be quickly monetised on the market via sale or repurchase transactions; these include government bonds, corporate bonds and equities listed on major indices (after haircuts). These HQLAs meet the eligibility criteria for the LCR, according to the most recent standards known and published by regulators. The haircuts applied to HQLA securities are in line with those indicated in the most recent known texts on determining the numerator of the LCR;

non-HQLA Group assets that are central bank-eligible, including receivables as well as covered bonds and securitisations of Group receivables held by the Group.

(In EURbn)

31.12.2022

31.12.2021

Central bank deposits (excluding mandatory reserves)

195

168

HQLA securities available and transferable on the market (after haircut)

59

58

Other available central bank-eligible assets (after haircut)

24

3

TOTAL

279

229

12.6 REGULATORY RATIOS

Regulatory requirements for liquidity risk are managed through two ratios:

the Liquidity Coverage Ratio (LCR), which aims to ensure that banks hold sufficient liquid assets or cash to survive to a significant stress scenario combining a market crisis and a specific crisis and lasting for one month The minimum regulatory requirement is 100% at all times;

the Net Stable Funding Ratio (NSFR), a long-term ratio of the balance sheet transformation, which compares the financing needs generated by the activities of institutions with their stable resources; The minimum level required is 100%.

In order to meet these requirements, the Group ensures that its regulatory ratios are managed well beyond the minimum regulatory requirements set by Directive 2019/878 of the European Parliament and of the Council of 20 May 2019 (CRD5) and Regulation (EU) 2019 /876 of the European Parliament and of the Council of 20 May 2019 (CRR2)(1).

Societe Generale’s LCR ratio has always been above 100%: 141% at the end of 2022 compared to 129% at the end of 2021. Since it came into force, the NSFR ratio has always been above 100% and stands at 114% at the end of 2022 compared to 110% at the end of 2021.

In addition, in order to complete its system, the Group has adapted monitoring indicators, in particular the monitoring of liquidity gap under various stress scenarios and under normal conditions, by significant currency and all currencies combined, which may be subject to additional constraints in terms of objective and minimum level. USD liquidity indicators are also specifically monitored.

(1)

Several amendments to European regulatory standards were adopted in May 2019: The text on the CRL, published in October 2014, has since been supplemented by a Delegated Act corrigendum which entered into force on 30 April 2020. The minimum level of the required ratio is 100% since January 1, 2018. The NSFR requirement included in CRR2 (EU) 2019/876 of 20 May 2019 has applied since June 2021. The required ratio is 100%.

The liquidity coverage ratio is calculated as the simple average of month-end observations over the twelve months preceding the end of each quarter.

Prudential Group

(In EURm)

Total unweighted value

(in average)

Total weighted value

(in average)

Quarter ending on

31.12.2022

30.09.2022

30.06.2022

31.03.2022

31.12.2022

30.09.2022

30.06.2022

31.03.2022

High-quality liquid assets

 

Total high-quality liquid assets (HQLA)

 

246,749

242,177

238,136

235,333

Cash Outflows

 

Retail deposits and deposits from small business customers, of which:

232,177

231,136

228,527

225,948

18,687

18,693

18,415

18,105

Stable deposits

126,164

122,569

121,113

120,126

6,308

6,128

6,056

6,006

Less stable deposits

101,370

103,742

102,398

100,552

12,357

12,544

12,341

12,083

Unsecured wholesale funding

309,913

307,312

301,779

292,765

166,535

165,700

162,798

158,345

Operational deposits (all counterparties) and deposits in networks of cooperative banks

71,734

72,616

72,562

70,349

17,451

17,659

17,653

17,111

Non-operational deposits
(all counterparties)

224,717

220,519

214,152

206,058

135,622

133,863

130,080

124,876

Unsecured debt

13,462

14,178

15,065

16,358

13,462

14,178

15,065

16,358

Secured wholesale funding

 

103,466

105,934

106,023

104,645

Additional requirements

215,310

209,420

200,219

191,339

77,934

74,769

68,608

64,006

Outflows related to derivative exposures
and other collateral requirements

44,389

41,600

36,427

32,887

42,350

39,552

34,448

31,052

Outflows related to loss of funding on debt products

10,677

10,853

10,457

10,000

10,677

10,853

10,457

10,000

Credit and liquidity facilities

160,243

156,967

153,334

148,452

24,907

24,365

23,703

22,954

Other contractual funding obligations

68,539

67,450

63,817

63,496

68,539

67,450

63,817

63,496

Other contingent funding obligations

69,000

64,106

60,740

56,879

1,890

1,531

1,155

992

TOTAL CASH OUTFLOWS

 

437,050

434,078

420,815

409,590

CASH – INFLOWS

 

Secured lending (eg reverse repos)

312,015

309,590

304,082

295,777

100,769

99,420

96,209

92,410

Inflows from fully performing exposures

54,460

52,794

50,404

48,046

46,646

45,204

42,819

40,651

Other cash inflows

119,855

118,402

110,543

105,281

114,965

114,081

106,784

102,097

(Difference between total weighted inflows and total weighted outflows arising from transactions in third countries where there are transfer restrictions or which are denominated in non-convertible currencies)

 

-

-

-

-

(Excess inflows from a related specialised credit institution)

 

-

-

-

-

TOTAL CASH INFLOWS

486,330

480,786

465,030

449,105

262,381

258,705

245,812

235,158

Fully exempt Inflows

-

-

-

-

-

-

-

-

Inflows subject to 90% cap

-

-

-

-

-

-

-

-

Inflows subject to 75% cap

384,265

376,735

360,313

346,275

262,381

258,705

245,812

235,158

TOTAL ADJUSTED VALUE

 

LIQUIDITY BUFFER

 

246,749

241,995

237,934

234,974

TOTAL NET CASH OUTFLOWS

 

174,670

175,373

175,003

174,432

LIQUIDITY COVERAGE RATIO (%)

 

141.41%

138.06%

136.00%

134.72%

As at 31 December 2022, the average of Societe Generale’s LCR stood at 141% (arithmetic average of the 12 LCR monthly values from January 2022 to December 2022, in accordance with the prudential disclosure requirement emanating from Regulation (EU) No 2019/876).

Reported LCR was 141% as of 1 December 2022, or EUR 74 billion of liquidity surplus over the regulatory requirement of 100%. This compares to 143%, or EUR 75 billion of liquidity surplus, as of 30 September 2022.

As of 31 December 2022, the numerator of the LCR included EUR 195 billion of central bank reserves (EUR 64 billion in the form of withdrawable central bank reserves and EUR 131 billion in the form of O/N deposit classified as level 1 assets). Level 1 assets are complemented with EUR 50 billion of Level 1 high-quality securities. Level 2 high-quality securities stand at EUR 9 billion.

The euro accounted for 60% of Societe Generale’s total high-quality liquid assets as of 31 December 2022. The US dollar also accounted for more than 5% of liquid assets, with a weight of 19.7%, as well as the Swiss franc, with a weight of 5.7% and the Japanese yen, with a weight of 5.2%. The liquidity profile of the Group in US dollars is framed by a set of thresholds and metrics, including indicators of liquidity excess under stress, in US dollars.

Societe Generale ensures it does not overly rely on any given individual counterparty or segment by setting and monitoring concentration risk metrics on secured and unsecured markets. For instance, unsecured short-term funding is subject to thresholds by counterparty type (Corporates, Central banks, Public sector, Asset managers, etc). Secured funding is framed to ensure that the drying up of liquidity in any segment of the repo market (counterparty segments, underlying collateral segments, currencies) would not materially impair the refinancing of inventories in capital markets. In addition to this, the Group’s long-term funding is structurally diversified. The plain vanilla funding programme is split into various currencies, instruments and geographies and seeks to continuously expand the investor base. Structured issuances are highly granular (multiple distributing networks) and provide a diversification in terms of nature of investors.

Societe Generale impacts its LCR computation to factor in collateral needs for covered bonds issuance vehicles and other vehicles used in capital markets activities, in case of a 3-notch downgrade of Societe Generale’s credit rating. Societe Generale also impacts its LCR computation to factor in a potential adverse market shock based on a 24-month historical look-back approach.

Intraday funding requirements give rise to dedicated reserves which are taken into account when computing liquidity stress tests based on internal models, which ground the control of the Societe Generale Group survival horizon under stress.

(In EURm)

31.12.2022

Unweighted value by residual maturity

Weighted

value

No maturity

< 6 months

6 months

to < 1yr

≥ 1yr

Available stable funding (ASF) Items

 

 

 

 

 

Capital items and instruments

66,261

3,374

-

9,641

75,902

Own funds

66,261

3,374

-

9,641

75,902

Other capital instruments

 

-

-

-

-

Retail deposits

 

230,165

1,934

8,138

224,352

Stable deposits

 

144,568

1,934

8,138

147,315

Less stable deposits

 

85,597

-

-

77,038

Wholesale funding:

 

496,446

53,458

166,794

312,751

Operational deposits

 

77,890

5

2

38,950

Other wholesale funding

 

418,556

53,452

166,792

273,801

Interdependent liabilities

 

59,775

0

3,727

-

Other liabilities: 

3,051

88,683

360

4,306

4,486

NSFR derivative liabilities 

3,051

 

 

 

 

All other liabilities and capital instruments
not included in the above categories

 

88,683

360

4,306

4,486

TOTAL AVAILABLE STABLE FUNDING (ASF)

 

 

 

 

617,491

Required stable funding (RSF) Items

 

 

 

 

 

Total high-quality liquid assets (HQLA)

 

 

 

 

27,605

Assets encumbered for more than 12m in cover pool

 

2

5

25,593

21,760

Deposits held at other financial institutions for operational purposes

 

-

-

-

-

Performing loans and securities:

 

248,013

52,987

384,295

394,099

Performing securities financing transactions with financial customerscollateralised by Level 1 HQLA subject to 0% haircut

 

95,197

9,559

2,482

10,865

Performing securities financing transactions with financial customer collateralised by other assets and loans and advances to financial institutions

 

59,807

7,627

28,970

38,326

Performing loans to non- financial corporate clients, loans to retail and small business customers, and loans to sovereigns, and PSEs, of which:

 

62,655

28,687

213,275

236,653

With a risk weight of less than or equal to 35% under the Basel II Standardised Approach for credit risk

 

13,054

5,250

28,364

38,102

Performing residential mortgages, of which: 

 

4,201

4,991

115,874

81,923

With a risk weight of less than or equal to 35% under the Basel II Standardised Approach for credit risk

 

3,777

4,502

105,826

72,926

Other loans and securities that are not in default and do not qualify as HQLA, including exchange-traded equities and trade finance on-balance sheet products

 

26,153

2,123

23,694

26,331

Interdependent assets

 

59,775

-

3,727

-

Other assets: 

 

133,260

4,065

72,440

90,160

Physical traded commodities

 

 

 

-

-

Assets posted as initial margin for derivative contracts and contributions to default funds of CCPs

 

10,820

2,923

8,641

19,027

NSFR derivative assets

 

-

 

 

-

NSFR derivative liabilities before deduction of variation margin posted 

 

94,602

 

 

4,730

All other assets not included in the above categories

 

27,839

1,142

63,799

66,404

Off-balance sheet items

 

202,469

1,307

29

9,924

TOTAL RSF

 

543,549

NET STABLE FUNDING RATIO (%)

 

113.60%

(In EURm)

30.06.2022

Unweighted value by residual maturity

Weighted

value

No maturity

< 6 months

6 months

to < 1 year

≥ 1 year

Available stable funding (ASF) Items

 

 

 

 

 

Capital items and instruments

65,777

44

1,672

12,124

77,901

Own funds

65,777

44

1,672

12,124

77,901

Other capital instruments

 

-

-

-

-

Retail deposits

 

230,691

836

4,996

219,709

Stable deposits

 

125,938

834

4,996

125,430

Less stable deposits

 

104,753

1

-

94,279

Wholesale funding

 

526,085

56,487

178,260

317,900

Operational deposits

 

70,733

4

5

35,373

Other wholesale funding

 

455,352

56,483

178,255

282,527

Interdependent liabilities

 

60,957

1

2,834

-

Other liabilities

3,798

98,691

224

257

369

NSFR derivative liabilities 

3,798

 

 

 

 

All other liabilities and capital instruments
not included in the above categories

 

98,691

224

257

369

TOTAL AVAILABLE STABLE FUNDING (ASF)

 

 

 

 

615,879

Required stable funding (RSF) Items

 

 

 

 

 

Total high-quality liquid assets (HQLA)

 

 

 

 

23,492

Assets encumbered for more than 12m in cover pool

 

99

99

23,274

19,952

Deposits held at other financial institutions for operational purposes

 

-

-

-

-

Performing loans and securities

 

290,210

50,326

391,395

407,774

Performing securities financing transactions with financial customerscollateralised by Level 1 HQLA subject to 0% haircut

 

112,185

5,935

3,004

8,991

Performing securities financing transactions with financial customer collateralised by other assets and loans and advances to financial institutions

 

80,125

8,880

27,874

40,426

Performing loans to non- financial corporate clients, loans to retail and small business customers, and loans to sovereigns, and PSEs, of which:

 

63,902

29,129

233,595

255,241

With a risk weight of less than or equal to 35% under the Basel II Standardised Approach for credit risk

 

11,590

3,516

45,402

49,347

Performing residential mortgages, of which: 

 

3,518

4,841

100,102

72,060

With a risk weight of less than or equal to 35% under the Basel II Standardised Approach for credit risk

 

3,127

4,364

86,031

59,665

Other loans and securities that are not in default and do not qualify as HQLA, including exchange-traded equities and trade finance on-balance sheet products

 

30,480

1,541

26,819

31,056

Interdependent assets

 

60,957

1

2,834

-

Other assets

-

104,023

1,299

81,238

88,672

Physical traded commodities

 

 

 

-

-

Assets posted as initial margin for derivative contracts and contributions to default funds of CCPs

 

4,410

-

21,282

21,839

NSFR derivative assets

 

-

 

 

-

NSFR derivative liabilities before deduction of variation margin posted 

 

63,390

 

 

3,170

All other assets not included in the above categories

 

36,222

1,299

59,955

63,664

Off-balance sheet items

 

192,058

-

-

9,603

TOTAL RSF

 

549,492

NET STABLE FUNDING RATIO (%)

 

112.08%

12.7 BALANCE SHEET SCHEDULE

The main lines of the Group’s financial liabilities and assets are presented in Note 3.13 to the consolidated financial statements.

(In EURm)

31.12.2022

Note to the consolidated financial statements

0-3 m

3 m-1 yr

1-5 yrs

>5 yrs

Total

Due to central banks

 

8,361

-

-

-

8,361

Financial liabilities at fair value through profit or loss, excluding derivatives

Notes 3.1 et 3.4

150,413

22,543

29,654

25,940

228,550

Due to banks

Note 3.6

49,803

39,639

42,213

1,333

132,988

Customer deposits

Note 3.6

475,608

27,233

23,101

4,822

530,764

Securitised debt payables

Note 3.6

34,158

24,030

46,583

28,405

133,176

Subordinated debt

Note 3.9

3

-

6,062

9,881

15,946

NB: The scheduling assumptions for these liabilities are presented in Note 3.13 to the consolidated financial statements. In particular, the data are shown without provisional interest and excluding derivatives.

(In EURm)

31.12.2021

Note to the consolidated financial statements

0-3 m

3 m-1 yr

1-5 yrs

>5 yrs

Total

Due to central banks

 

5,152

-

-

-

5,152

Financial liabilities at fair value through profit or loss, excluding derivatives

 

136,581

17,693

23,438

23,244

200,956

Due to banks

Note 3.6

57,174

4,185

76,106

1,712

139,177

Customer deposits

Note 3.6

470,890

15,244

16,568

6,431

509,133

Securitised debt payables

Note 3.6

89,671

12,164

19,040

14,449

135,324

Subordinated debt

Note 3.9

7,735

61

3,649

4,514

15,959

NB: The scheduling assumptions for these liabilities are presented in Note 3.13 to the consolidated financial statements. In particular, the data are shown without provisional interest and excluding derivatives.

(In EURm)

31.12.2022

Note to the consolidated financial statements

0-3 m

3 m-1 yr

1-5 yrs

>5 yrs

Total

Cash, due from central banks

 

203,389

734

1,808

1,082

207,013

Financial assets at fair value through profit or loss, excluding derivatives

Note 3.4

242,458

11,045

-

-

253,503

Financial assets at fair value through other comprehensive income

Note 3.4

37,066

132

-

265

37,463

Securities at amortised cost

Note 3.5

6,939

4,718

6,547

3,226

21,430

Due from banks at amortised cost

Note 3.5

57,524

1,569

7,348

462

66,903

Customer loans at amortised cost

Note 3.5

111,407

62,807

183,235

120,477

477,927

Lease financing agreements(1)

Note 3.5

2,760

6,014

15,663

4,165

28,602

(1)

Amounts are featured net of impairments.

(In EURm)

31.12.2021

Note to the consolidated financial statements

0-3 m

3 m-1 yr

1-5 yrs

>5 yrs

Total

Cash, due from central banks

 

176,064

822

1,988

1,095

179,969

Financial assets at fair value through profit or loss, excluding derivatives

Note 3.4

233,186

9,173

-

-

242,359

Financial assets at fair value through other comprehensive income

Note 3.4

42,798

380

-

272

43,450

Securities at amortised cost

Note 3.5

16,686

289

1,480

916

19,371

Due from banks at amortised cost

Note 3.5

47,182

3,619

4,715

456

55,972

Customer loans at amortised cost

Note 3.5

94,978

65,686

189,325

117,555

467,544

Lease financing agreements(1)

Note 3.5

2,778

6,378

16,024

4,440

29,620

(1)

Amounts are featured net of impairments.

Due to the nature of its activities, Société Générale holds derivative products and securities whose residual contractual maturities are not representative of its activities or risks.

By convention, the following residual maturities were used for the classification of financial assets:

1.

assets measured at fair value through profit or loss, excluding derivatives (customer-related trading assets):

-

positions measured using prices quoted on active markets (L1 accounting classification): maturity of less than 3 months,

-

positions measured using observable data other than quoted prices (L2 accountBing classification): maturity of less than 3 months,

-

positions measured mainly using unobservable market data (L3): maturity of 3 months to 1 year;

2.

financial assets at fair value through other comprehensive income:

-

available-for-sale assets measured using prices quoted on active markets: maturity of less than 3 months,

-

bonds measured using observable data other than quoted prices (L2): maturity of 3 months to 1 year,

-

finally, other securities (shares held long-term in particular): maturity of more than 5 years.

As regards the other lines of the balance sheet, other assets and liabilities and their associated conventions can be broken down as follows:

(In EURm)

31.12.2022

Note to the consolidated financial statements

Not scheduled

0-3 m

3 m-1 yr

1-5 yrs

> 5 yrs

Total

Tax liabilities

Note 6.3

-

-

807

831

-

1,638

Revaluation difference on portfolios hedged against interest rate risk 

 

(9,659)

-

-

-

-

(9,659)

Other liabilities

Note 4.4

-

100,859

1,969

2,864

1,861

107,553

Non-current liabilities held for sale

Note 2.5

-

-

220

-

-

220

Insurance contracts related liabilities

Note 4.3

-

5,345

10,055

39,677

86,611

141,688

Provisions

Note 8.3

4,579

-

-

-

-

4,579

Shareholders’ equity

 

72,782

-

-

-

-

72,782

(In EURm)

31.12.2021

Note to the consolidated financial statements

Not scheduled

0-3 m

3 m-1 yr

1-5 yrs

> 5 yrs

Total

Tax liabilities

Note 6.3

-

-

836

741

-

1,577

Revaluation difference on portfolios hedged against interest rate risk 

 

2,832

-

-

-

-

2,832

Other liabilities

Note 4.4

-

98,035

2,241

3,023

3,006

106,305

Non-current liabilities held for sale

 

1

-

-

-

-

1

Insurance contracts related liabilities

Note 4.3

-

15,566

10,232

40,848

88,642

155,288

Provisions

Note 8.3

4,850

-

-

-

-

4,850

Shareholders’ equity(1)

 

70,863

-

-

-

-

70,863

(In EURm)

31.12.2022

Note to the consolidated financial statements

Not scheduled

0-3 m

3 m-1 yr

1-5 yrs

> 5 yrs

Total

Revaluation differences on portfolios hedged against interest rate risk

 

(2,262)

-

-

-

-

(2,262)

Other assets

Note 4.4

-

85,072

-

-

-

85,072

Tax assets

Note 6

4,696

-

-

-

-

4,696

Deferred profit-sharing

 

 

1,170

0

1

4

1,175

Investments accounted for using the equity method

 

-

-

-

-

146

146

Tangible and intangible fixed assets

Note 8.4

-

-

-

-

33,089

33,089

Goodwill

Note 2.2

-

-

-

-

3,781

3,781

Non-current assets held for sale

Note 2.5

-

1

1,049

15

17

1,081

Investments of insurance companies

Note 4.3

-

34,774

7,907

35,418

80,316

158,415

(In EURm)

31.12.2021

Note to the consolidated financial statements

Not scheduled

0-3 m

3 m-1 yr

1-5 yrs

> 5 yrs

Total

Revaluation differences on portfolios hedged against interest rate risk

 

131

-

-

-

-

131

Other assets

Note 4.4

-

92,898

-

-

-

92,898

Tax assets

Note 6

4,812

-

-

-

-

4,812

Investments accounted for using the equity method

 

-

-

-

-

95

95

Tangible and intangible fixed assets

Note 8.4

-

-

-

-

31,968

31,968

Goodwill

Note 2.2

-

-

-

-

3,741

3,741

Non-current assets held for sale

 

-

1

2

12

12

27

Investments of insurance companies

 

-

49,908

5,632

36,781

86,577

178,898

1.

Revaluation differences on portfolios hedged against interest rate risk are not scheduled, as they comprise transactions backed by the portfolios in question. Similarly, the schedule of tax assets whose schedule would result in the early disclosure of income flows is not made public.

2.

Other assets and other liabilities (guarantee deposits and settlement accounts, miscellaneous receivables) are considered as current assets and liabilities.

3.

The notional maturities of commitments in derivative instruments are presented in Note 3.2.2 to the consolidated financial statements.

4.

Investments in subsidiaries and affiliates accounted for by the equity method and Tangible and intangible fixed assets have a maturity of more than 5 years.

5.

Provisions and shareholders’ equity are not scheduled.

 

13 COMPLIANCE RISK, LITIGATION

IN BRIEF

Compliance means acting in accordance with the obligations applicable to the Group’s activities, ranging from laws and regulations to professional, ethical and internal standards and principles.

By ensuring that these provisions are observed, the Group works to protect its employees, customers and all stakeholders. Compliance with rules is the responsibility of all Group employees, who must demonstrate compliance and integrity in their daily tasks.

The Group relies on a recently restructured, clear organisation to ensure the compliance system is both respected and consistent.

Compliance risk is considered an extra-financial risk, in keeping with the Group’s risk taxonomy.

Acting in compliance means understanding and observing the external and internal rules that govern our banking and financial activities. These rules aim to ensure a transparent and balanced relationship between the Bank and all of its stakeholders. Compliance is the cornerstone of trust between the Bank, its customers, its supervisors and its staff.

Compliance with rules is the responsibility of all Group employees, who must demonstrate compliance and integrity on a daily basis. The rules must be clearly expressed, and staff have been informed and/or trained to understand them properly.

The compliance risk prevention system is based on shared responsibility between the operational entities and the Group Compliance Department:

the operational entities (BU/SUs) must incorporate into their daily activities’ compliance with laws and regulations, the rules of professional best practice and the Group’s internal rules;

the Compliance Department manages the Group’s compliance risk prevention system. It ensures the system’s consistency and efficiency, while also developing appropriate relationships – alongside the General Secretary – with bank supervisors and regulators. This independent department reports directly to General Management.

To support the businesses and supervise the system, the Compliance Department is organised into:

Standards and Consolidation teams responsible for defining the normative system and oversight guidelines, consolidating them at Group level, as well as defining the target operational model for each compliance risk;

Departmental/business compliance teams which are aligned across the Group’s major business lines (Corporate and Investment Bank, French Retail Banking, International Retail Banking, Private Banking and Corporate Divisions), responsible for the relationship with BU/SUs, including deal flow, advisory, and risk oversight of BU/SUs;

teams responsible for cross-business functions, including second-level controls.

The Compliance Department is organised into three main compliance risk categories:

financial security: know your client (KYC) processes; the observance of international sanctions and embargo rules, and anti-money laundering and counter-terrorism financing rules, including issuing declarations of suspicion to the relevant authorities where applicable;

regulatory risks, which cover in particular: customer protection, anti-bribery and corruption, ethics and conduct, compliance with tax transparency regulations (based on knowledge of the customers’ tax profile), compliance with corporate social responsibility regulations and Group commitments, market integrity, compliance with prudential regulations in collaboration with the Risk Division, joint coordination with HRCO of the Group’s Culture & Conduct issues (Conduct in particular);

data protection, including personal data, in particular those of customers.

Financial crime risks

Regulatory risks

Data

protection

& digital

know your clients

Anti-Money Laundering & Counter Terrorism Financing

Sanctions & Embargoes

Client Protection

Market Integrity

Tax Transparency

Anti-Corruption & Bribery, Ethics & Conduct

Corporate Social Responsibility

Prudential risks

RGPD, Storage

 

Compliance has set up an extensive compulsory training programme for each of these risk categories, designed to raise awareness of compliance risks among all or some employees. The training has been completed by high-level employees within the Group.

In addition to its LoD2 function with regard to the aforementioned risks, Compliance oversees the regulatory system for all regulations applicable to credit institutions, including those implemented by other departments, such as prudential regulations.

13.1 COMPLIANCE

At the end of 2022, the Group concluded an extensive programme launched in 2018 to rework its KYC functions in order to boost their operational efficiency (via the simplification of standards, greater pooling of resources, optimisation of tools and processes) and to improve the client experience. Placed under the responsibility of the Compliance Department, this programme has made it possible to redefine a standardised normative framework country by country in terms of KYC due diligence, to develop new client rating models, and to launch an industrialised system for the screening and processing of negative client news. This allowed the anti-corruption system to be upgraded in line with the requirements of the French anti-bribery agency.

The Group has transposed all the measures linked to Directive (EU) 2015/849 on anti-money laundering and counter-terrorism financing (referred to as “the 5th Anti-Money Laundering Directive”), as well as European Regulation 2015/847 on the quality of payment information and the Order of 6 January 2021 on the system and internal controls to fight money laundering and terrorism financing.

The system for the detection of suspicious or unusual transactions continued to be strengthened in 2022 with the roll-out of more sophisticated monitoring tools, the optimisation of scenarios used and the launch of initiatives to switch to new-generation monitoring tools, with priority given to International Retail Banking and Boursorama.

In 2022, the Embargoes/Sanctions teams were hit with the impact of the Russian crisis, in particular the increase in and complexity of the sanction regimes defined by the various jurisdictions (European Union, United States, United Kingdom, etc.) in the first months of the Ukraine war and the disposal of our subsidiary Rosbank.

Societe Generale was able to effectively react to this crisis thanks to the strengthening in recent years of its embargoes/sanctions risk management system, and the exceptional recruitment of additional employees to manage the sharp rise in alerts.

Despite the significant increase in workload for all teams, managing the Russian crisis did not affect the completion of upgrades to the system following agreements entered into with the US authorities in 2018. In accordance with the dismissal of the Deferred Prosecution Agreement, announced in December 2021, the La Fayette programme was officially closed on 1 August 2022. Nevertheless, Societe Generale is still regularly reviewed by an independent consultant appointed by the FED.

Customer protection is a major challenge for the Societe Generale Group, which is committed to respecting and protecting the interests of its customers.

The prevention of financial vulnerability (early detection), banking inclusion (the right to hold an account) and the removal of insurance taken out on a real estate loan are still priorities. These measures were supplemented by the application of the recent Lemoine law, which stipulates that any request to replace a contract must be processed within 10 days.

Information provided to customers was strengthened with new rules on ESG (Environmental and Social Governance) labelling and designations.

The Group continues to implement significant measures to improve its system in terms of:

strengthening internal rules regarding key aspects of customer protection (marketing rules – especially in terms of sustainable investment, cross-border sales, customer claims, conflicts of interest, product governance, protection of customers’ assets, along with compensation and qualification of employees);

specific training and increased staff awareness; the importance the Group places on this issue is largely addressed in the Group’s Code of Conduct;

adapting as a matter of necessity existing tools to new regulatory requirements, in particular the Shareholder Rights Directive II (SRD2), applicable as of 2021.

Processing a claim is a commercial act that impacts customer satisfaction. Accordingly, it has received much coverage in the Code of Conduct.

The “Customer claim processing” Group instruction incorporates the recommendations of the national supervisor (French Prudential Supervisory and Resolution Authority – ACPR) and the regulatory requirements (MIF2, DDA and DSP – the Payment Services Directive) relative to the strengthening of customer protection measures at European level. The Bank’s businesses have an ad hoc governance, an organisation, human resources and applications, formalised procedures, and quantitative and qualitative monitoring indicators.

Independent mediation supplements this internal system. Mediation, a measure aimed at amicable settlement, is brought to customers’ awareness on multiple information media, in particular through a permanent notice on the back of bank account statements. Every entity involved is obliged to comply with the independent mediator’s decision.

The Group has a clear normative framework in place to prevent and manage conflicts of interest. This framework specifies the principles and mechanisms that have been implemented. This robust system covers three categories of potential conflicts of interest: those that may arise between the Group and its customers or between the Group’s customers; those occurring between the Group and its employees (particularly in relation to activities involving an employee’s personal interest and/or their professional obligations); and, lastly, those arising between the Group and its suppliers. The system has been supplemented by the annual reporting of conflicts of interest (Déclaration des Conflits d’intérêts – DACI) regarding people most exposed to the risks of corruption.

Systematic reviews ahead of and during the marketing process ensure compliance with product governance obligations. As product originator, Societe Generale sets up Product Review Committees to ensure the target market has been defined correctly and, if not, to adjust it accordingly. As distributor, Societe Generale checks that the criteria match the customers’ situation and communicates with product originators to track products during their life cycle. Societe Generale’s investment services policy includes new offers in terms of sustainable finance, the supervision of crypto-assets, and detailed notes on the target markets of the main instruments produced or distributed by each business.

Societe Generale has established practices and usages to comply with legislation vis-à-vis vulnerable customers, in particular customers benefiting from the offer tailored to financially vulnerable customers. To contribute to the national effort to boost the purchasing power of French citizens in challenging financial circumstances, the Group has added to its practices by introducing additional measures in 2019, notably: i) freezing bank fees; ii) capping bank intervention fees for vulnerable clients; and iii) organising follow-up and support suited to the situation of customers experiencing difficulties in the wake of recent events. These measures are closely monitored and covered in action plans aimed at identifying financially vulnerable customers.

The market integrity laws and regulations adopted in recent years have been included in a robust risk hedging system implemented in the Societe Generale Group.

The rules of conduct, the organisational principles and the oversight and control measures are in place and regularly assessed. Moreover, extensive training and awareness-raising programmes are provided to all Group employees.

This system was strengthened in 2022 to keep pace with regulatory developments, in particular:

to address the escalation in regulatory requirements regarding transaction reporting;

regarding derivatives, which is an area subject to regulatory changes; combined with business and technological developments, they require constant updates and adjustments to the compliance management system;

by continuing the IBOR transition to adopt Risk-Free Rates after an important milestone was achieved at the end of 2021 with the discontinuation of LIBOR in EUR, GBP, JPY and CHF.

Societe Generale Group’s principles on combating tax evasion are governed by the Tax Code of Conduct. The Code is updated periodically and approved by the Board of Directors after review by the Executive Committee. It is publicly available via the Bank’s institutional investor portal (https://www.societegenerale.com/sites/default/files/documents/Code%20de%20conduite/tax_code_of_conduct_of_societe_generale_group_uk.pdf).

The five main principles of the Code of Conduct are as follows:

Societe Generale ensures compliance with the tax rules applicable to its business in all countries where the Group operates, in accordance with international conventions and national laws;

in its customer relationships, Societe Generale ensures that customers are informed of their tax obligations relating to transactions carried out with the Group, and the Group complies with the reporting obligations that apply to it as bookkeeper or in any other way;

in its relations with the tax authorities, Societe Generale is committed to strictly respecting tax procedures and ensures that it maintains open and transparent relations to uphold its reputation;

Societe Generale does not encourage or promote tax evasion for itself, its subsidiaries or its customers;

Societe Generale has a tax policy in line with its strategy of sustainable profitability and refrains from any operation, whether for its own account or for its customers, whose main purpose or effect is tax motivated, unless this is consistent with the intention of the legislation.

The Tax Department annually presents to the Risk Committee or the Board of Directors the Group’s tax policy, including the procedures and systems in place within the Group to ensure that new products and new establishments comply with the Group’s tax principles.

The Group is committed to a strict policy with regard to tax havens. No Group entity is authorised in a state or territory on the official French list of ETNCs (États et territoires non coopératifs in French)(1) and internal rules have been in place since 2013 to monitor an expanded list of countries or territories.

The Group adheres to the Organisation for Economic Co-operation and Development’s (OECD) Transfer Pricing Guidelines and applies the principle of competitive neutrality in order to ensure that its intra-group transactions are made at arm’s length conditions and do not lead to the transfer of any indirect benefits. However, local constraints may require deviations from OECD methodologies, in which case the local constraints must be documented.

The Group publishes information on its entities and activities annually on a country-by-country basis (see section 2.12 page 67 of the Universal Registration Document) and confirms that its presence in a number of countries is for commercial purposes only, and not to benefit from special tax provisions. The Group also complies with the tax transparency rules for its own account (CbCR – country-by-Country Reporting).

Societe Generale complies with client tax transparency standards. The Common Reporting Standard (CRS) enables tax authorities to be systematically informed of income received abroad by their tax residents, including where the accounts are held in asset management structures. Societe Generale also complies with the requirements of the United States FATCA (Foreign Account Tax Compliance Act), which aims to combat tax evasion involving foreign accounts or entities held by US taxpayers. The Group has implemented the European Directive DAC6, which will require the reporting of cross-border tax arrangements. Lastly, the Group is studying the new tax transparency standards on digital assets ahead of their upcoming implementation, in particular the CARF (Crypto-Asset Reporting Framework), changes to the CRS standard, and the new European directive in this regard, known as DAC8 (Directive on Administrative Cooperation 8).

Importantly, the account-keeping entities of the Private Banking business line are established exclusively in countries with the strictest tax transparency rules imposed by G20 member countries and the OECD. Assets deposited in Private Banking books are subject to enhanced scrutiny using comprehensive due diligence procedures to ensure they are tax compliant.

In accordance with regulatory requirements, Societe Generale also includes tax fraud in its anti-money laundering procedures.

(1)

Including the European Union blacklist.

Societe Generale is fully committed to fighting corruption and has given clear undertakings in this respect by participating in the Wolfsberg Group and the Global Compact.

The Group applies the strict principles included in its Code of Conduct and its “Anti-Corruption and Influence Peddling Code”.

Societe Generale’s anti-corruption programme is built around the following themes:

code of conduct;

risk mapping;

appropriate training at all levels (senior management, exposed persons, all employees);

control systems;

accounting procedures;

evaluation of third parties;

disciplinary system;

right to whistleblow.

Within this context, processes and tools have been strengthened since 2018 with more staff dedicated to anti-corruption practices within the Group (in particular to carry out client due diligence), the creation of monitoring indicators, and new operational checks to reduce the risk of corruption.

The Group’s anti-corruption instructions are revised and expanded every year.

The Societe Generale Group also has several tools at its disposal, such as the tool for declaring gifts and invitations (GEMS), the tool for whistleblowing management (WhistleB), the annual conflict of interest declaration tool (DACI), and the tool for selecting risky manual accounting entries (OSERIS).

Several anti-corruption training measures are implemented on a regular basis, for the benefit not only of employees, but also of persons most exposed to the risk of corruption, accounting controllers, and members of General Management and the Board of Directors.

Third-party (customers, suppliers and associations benefiting from donations or sponsorship initiatives) knowledge procedures have been strengthened.

European financial regulations have seen significant changes from a social and environmental perspective, in particular with:

the entry into force in March 2021 of Regulation (EU) 2019/2088 – SFDR on sustainability-related disclosures in the financial services sector;

the Taxonomy Regulation (EU) 2020/852 on the establishment of a framework to facilitate sustainable investment; and

the entry into force in January 2022 of the Delegated Regulation of 4 June 2021 supplementing the Taxonomy Regulation.

The Compliance Department is developing the normative framework relative to the European Union regulations on sustainable investment. A dedicated programme is helping the business lines to comply with regulations and is producing deliverables pertaining to normative documentation, training, controls and supervision. An e-learning module on sustainable investment was made compulsory for more than 30,000 Group employees.

Over and above the regulations, the Group is making voluntary, public commitments in this area. To manage the implementation of the environmental and social risk management system and ensure the Group’s commitments are upheld, the Compliance Division has taken the following measures:

developing normative controls;

deploying e-learning on environmental and social risk management. The training was made compulsory for all employees having a direct or indirect relationship with corporate customers. Moreover, specific workshops were conducted with targeted employees in the Compliance Division to foster an understanding of and compliance with the criteria for applying voluntary commitments;

defining an environmental and social escalation procedure with respect to corporate customers to set out the criteria requiring business lines to reach out to the Compliance Division and, where applicable, the Responsible Commitments Committee, to connect with a company or during situations likely to present a reputational risk arising from environmental or social factors.

Societe Generale is especially sensitive to personal data protection.

In order to comply with the General Data Protection Regulation (GDPR), Societe Generale Group has significantly strengthened its personal data processing framework.

Across all Group entities, internal instructions and associated procedures in line with local and European regulations define the rules to apply and the measures to take to guarantee the protection and security of customer and staff data. In particular, measures to inform data subjects (customers, employees, shareholders, suppliers, etc.) and process their demands are in place so that such persons can exercise their rights, notably via dedicated digital platforms. A personal data security policy has been defined, which fits in with the Group’s overall security strategy, especially as regards cybersecurity. Moreover, there has been a specific effort to increase staff awareness via dedicated training. Accordingly, the e-learning module was revised in 2022 to be rolled out to all employees working in the relevant entities.

Societe Generale Group has appointed a Data Protection Officer (DPO) in accordance with the applicable regulations. Reporting to the Head of Group Compliance, the DPO is the main contact person for the Personal Data Protection Authority (Commission Nationale de l’Informatique et des Libertés – CNIL). The DPO is also responsible for ensuring sound Group compliance for personal data protection. Alongside the network of local DPOs and correspondents throughout the Group entities, the DPO assists them with security issues and personal data usage.

As part of his or her duties, the DPO regularly reviews a number of indicators, notably the number and nature of requests by persons seeking to exercise their rights under GDPR, the internal training completion rate, and the local DPO certification programme.

Societe Generale Group is required to archive information that could provide evidence of its activities, in accordance with the laws and regulations applicable in its countries of operation.

Data Records Management (DRM) is defined as all actions, tools and methods aimed at identifying, storing, retrieving and destroying or permanently preserving all information providing evidence of its activities. It ensures the traceability of the Group’s activities by preserving records held in compliance with the legal, regulatory, contractual and business rules applicable to the relevant activities, and by destroying them at the end of their retention period, except in specific cases (pre-litigation or litigation retention procedures, for example).

Three DRM principles must be observed and implemented in a proportionate manner for all archived records: integrity, traceability and access.

DRM governance is covered by a specific Group-wide policy.

It is being rolled out gradually as part of a dedicated programme, under the responsibility of the Human Resources, Compliance and Legal Departments, and relies on a network of DRM correspondents.

It is coordinated by the Compliance Department, which:

supports the Compliance Control Officers of the businesses in their strategy for preventing, identifying, assessing and controlling reputational risk;

develops a reputational risk dashboard that is communicated quarterly to the Risk Committee of the Board of Directors, based on information from the businesses/Business Units and support functions/Service Units (in particular the Human Resources, Communications, Legal, Corporate Social Responsibility and Data Protection Departments).

Moreover, Chief Compliance Officers dedicated to Business Units take part in the various bodies (New Product Committees, ad hoc Committees, etc.) organised to approve new types of transactions, products, projects or customers, and formulate a written opinion as to their assessment of the level of risk of the planned initiative, and notably the reputational risk.

In addition to its second-line-of-defence function with regard to the aforementioned risks, the Compliance Department has continued to strengthen the supervision of the Group’s regulatory system in coordination with the Risk, Finance and Legal Departments. This oversight relies on the corporate compliance framework, which aims to ensure the Group’s compliance with all banking and finance regulations, including those implemented by other departments (control functions or independent expert functions) in areas where Compliance has no dedicated expertise.

Furthermore, the process for reporting prudential non-compliance incidents was strengthened in 2022 with the creation of a new category in the Group’s taxonomy, dedicated to prudential regulations and incorporated into the scope of the Compliance Incident Committees.

In June 2018, Societe Generale entered into agreements with the US Department of Justice (DOJ) and the US Commodity Futures Trading Commission (CFTC) to resolve their investigations into IBOR submissions, and with the DOJ and the French Financial Prosecutions Department (Parquet National Financier PNF) to resolve their investigations into certain transactions involving Libyan counterparties.

In November 2018, Societe Generale entered into agreements with the US authorities to resolve their investigations into certain US dollar transactions involving countries, persons or entities subject to US economic sanctions.

As part of these agreements, the Bank committed to enhance its compliance system in order to prevent and detect any violation of anti-corruption and bribery, market manipulation and US economic sanction regulations, and any violation of New York state laws. The Bank also committed to enhance corporate oversight of its economic sanction’s compliance programme.

Moreover, the Bank agreed with the US Federal Reserve to hire an independent consultant to assess the Bank’s progress on the implementation of measures to strengthen its compliance programme with respect to sanctions and embargoes.

To meet the commitments made by Societe Generale as part of these agreements, the Bank developed a programme to implement these commitments and strengthen its compliance system in the relevant areas, which was officially concluded on 1 August 2022.

On 30 November and 2 December 2021, the US federal court confirmed the termination of legal proceedings by the DOJ, which confirmed that Societe Generale complied with obligations relating to the deferred prosecution agreements (DPA) of June and November 2018. In December 2020, the PNF resolved proceedings against Societe Generale and acknowledged that Societe Generale had fulfilled its obligations with respect to the public interest judicial convention.

On 19 November 2018, Societe Generale Group and its New York branch (SGNY) entered into an agreement (enforcement action) with the NY State Department of Financial Services regarding the SGNY anti-money laundering compliance programme. This agreement requires (i) submitting an enhanced anti-money laundering programme, (ii) an anti-money laundering governance plan, and (iii) the performance of an external audit in 2020.

As background information, on 14 December 2017, Societe Generale and SGNY on the one hand, and the Board of Governors of the Federal Reserve on the other hand, agreed to a Cease-and-Desist order (the “Order”) regarding the SGNY compliance programme to adhere to the Bank Secrecy Act (“BSA”) and its anti-money laundering (“AML”) obligations (the “Anti-Money Laundering Compliance Program”), and regarding some aspects of its know your client (KYC) programme.

This Cease-and-Desist Order signed on 14 December 2017 with the US Federal Reserve supersedes the Written Agreement entered into in 2009 between Societe Generale Group and SGNY on the one hand, and the US Federal Reserve and the New York State Financial Services Department on the other.

On 17 December 2019, Societe Generale SA and SGNY signed an agreement with the Federal Reserve Bank of New York (FRB) regarding compliance risk management. This agreement included the submission and approval by the FRB, followed by the implementation, of (i) an action plan to strengthen supervision by the US Risk Committee of the compliance risk management programme, (ii) an action plan to improve the compliance risk management programme in the US, and (iii) revisions of the internal audit programme concerning compliance risk management audits in the US.

At the end of 2022, Societe Generale had made considerable progress in the delivery of remedial actions.

13.2 LITIGATION

The information pertaining to risks and litigation is included in Note 9 to the consolidated financial statements, page 552 of the Universal Registration Document .

 

14 ENVIRONMENTAL, SOCIAL AND GOVERNANCE (ESG) RISKS

 

IN BRIEF

Environmental, social and governance (ESG) risks correspond to the risk of negative impacts stemming from current or prospective ESG factors relating to the Group’s financing, investment or service activities.

14.1 INTRODUCTION

Article 449 bis of CRR2, requires the publication of information on environmental, social, and governmental risks (ESG risks). This requirement has been implemented by implementing regulation 2022/2453 of November 30th 2022.

14.2 QUALITATIVE INFORMATION ON ESG RISKS

The below table shows where to find in the Group 2023 Universal Registration Document(1), the qualitive information required in tables 1, 2, 3. When necessary, precisions have been made.

14.2.1 PILLAR 3 CROSS-REFERENCE TABLE

Topic

Sub-topic

Pilar 3

reference

Pillar 3 requirement

2023 Universal Registrement

Document page

Environmental risk

Business strategy and processes

Table 1 (a)

Institution’s business strategy to integrate environmental factors and risks, taking into account the impact of environmental factors and risks on institution’s business environment, business model, strategy and financial planning

1.3 A strategy of profitable and sustainable development, based on a diversified and integrated banking model (page 11)

2.4 Extra-financial report (page 46)

5.2.1.2 Aligning our activities with pathways consistent with a maximum temperature rise of 1.5°C (page 319)

5.2.1.3 Supporting positive change
(page 325)

5.2.2.1 Dialogue with stakeholders
(page 335)

Table 1 (b)

Objectives, targets and limits to assess and address environmental risk in short-, medium-, and long-term, and performance assessment against these objectives, targets and limits, including forward-looking information in the design of business strategy and processes

4.2.1 Risk Appetite (page 175), including section Measures to manage ESG risk factors (page 176)

4.13.4.3 Incorporating climate risks in the risk management framework (page 281), including Scenarios (page 283)

5.2.1.1 Taking action and building a sustainable future together (page 314)

5.2.1.2 Aligning our activities with patways consistent with a maximum temperature rise of 1.5 °C (page 319)(1)

(See also the section Risk Appetite in section 14.2.2.1 of the present Pillar 3 document (page 261))

Table 1 (c)

Current investment activities and (future) investment targets towards environmental objectives and EU Taxonomy-aligned activities

4.13.3.4 Operational implementation in the Group's Business Units (page 277)

4.13.3.5 Additional E&S risk management processes related to the specific characteristics of certain Group activities (page 278)

5.2.1 A committed bank (page 314)

(1)

https://www.societegenerale.com/sites/default/files/documents/2023-03/2023-Universal-Registration-Document_EN.pdf.

Topic

Sub-topic

Pilar 3

reference

Pillar 3 requirement

2023 Universal Registrement

Document page

Environmental risk

Business strategy and processes

Table 1 (d)

Policies and procedures relating to direct and indirect engagement with new or existing counterparties on their strategies to mitigate and reduce environmental risks

4.13.3 Managing ESG-related risks in the group's activities (page 275)

4.13.4.4 Processes and tools for identifying and managing climate risk (page 284)

5.5 Duty of care plan (page 361)

Governance

Table 1 (e)

Responsibilities of the management body for setting the risk framework, supervising and managing the implementation of the objectives, strategy and policies in the context of environmental risk management covering relevant transmission channels

3.1.2 Board of Directors (page 72), including sections Board of Directors and CSR (page 93), Risk committee (page 98), Appraisal of the Board of Directors and its members (page 104) et Training (page 104)

3.1.3 General Management (page 105)

5.2.3.1 Incorporating CSR at the highest level of governance (including diagram) (page 343)

Table 1 (f)

Management body’s integration of short-, medium- and long-term effects of environmental factors and risks, organisational structure both within business lines and internal control functions

4.1.1.5 Risks stemming - environmental, social and governance risks (page 166)

4.13.1 Introduction (page 273)

4.13.3.4 Operational implementation in the Group's Business Units (page 277)

4.14.3.5 Additional E&S risk management processes related to the specific characteristics of certain Group activities (page 278)

Table 1 (g)

Integration of measures to manage environmental factors and risks in internal governance arrangements, including the role of committees, the allocation of tasks and responsibilities, and the feedback loop from risk management to the management body covering relevant transmission channels

3.1.2 Board of Directors (page 72), including section Risk Committee (page 98)

4.2.3 Risk management organisation
(page 181)

4.13.2 Analytical approach to extra-financial risks factors (page 273)

5.2.3.1 Incorporating CSR at the highest level of governance (page 343)

Table 1 (h)

Lines of reporting and frequency of reporting relating to environmental risk

4.2.3 Risk management organisation
(page 181), including Risk reporting and assessment systems (page 184)

4.13.2 Analytical approach to extra-financial risks factors
(page 273), 5.2.3.1 Incorporating CSR at the highest level of governance (page 343)

Table 1 (i)

Alignment of the remuneration policy with institution’s environmental risk-related objectives

3.1.6 Remuneration of Group senior Management (page 112) including elements on non-financial remuneration

Risk management

Table 1 (j)

Integration of short-, medium- and long-term effects of environmental factors and risks in the risk framework

4.2.1 Risk Appetite (page 175), including section Measures to manage ESG risk factors (page 176)

4.13.4.2 Terminology for environmental risks (page 279)

4.13.4.3 Incorporating climate risks in the risk management framework (page 281)

Table 1 (k)

Definitions, methodologies and international standards on which the environmental risk management framework is based

4.13.1 Introduction (page 273)

4.13.4.2 Terminology for environmental risks (page 279)

5.2.1.1 Taking action and building a sustainable future together (page 314)

Environmental risk

Risk management

Table 1 (l)

Processes to identify, measure and monitor activities and exposures (and collateral where applicable) sensitive to environmental risks, covering relevant transmission channels

4.13.3 Managing ESG-related risks in the group's activities (page 275), including 4.13.3.2 Environmental and Social (E&S) General Principles and sector policies (page 275) and 4.13.3.3 Operational implementation procedures (page 276)

4.13.4.3 Incorporating climate risks in the risk management framework (page 281), including section Identifying climate-induced risks (page 281)

Table 1 (m)

Activities, commitments and exposures contributing to mitigate environmental risks

4.13.4.3 Incorporating climate risks in the risk management framework (page 281), including section Governance of climate risk management and mitigation
(page 283)

5.2.1 A committed bank (page 314)

Table 1 (n)

Implementation of tools for identification, measurement and management of environmental risks

4.13.4.4 Processes and tools for identifying and managing climate risk (page 284)

4.13.4.5 Biodiversity and nature risks
(page 286)

Table 1 (o)

Results and outcome of the risk tools implemented and the estimated impact of environmental risk on capital and liquidity risk profile

4.13.4.3 Incorporating the environment in the risk management framework (page 281), including sections Identifying climate-induced risks (page 281) and Quantifying climate risks and climate stress tests (page 282)

(See also the section Quantifying climate risks and climate stress tests in section 14.2.2.1 of the present Pillar 3 document (page 261))

Table 1 (p)

Data availability, quality and accuracy, and efforts to improve these aspects

4.13.4.4 Processes and tools for identifying and managing climate risk (page 284), including Data Issues (page 286)

(See also chapter 14.3 Quantitative information on ESG risks of the present Pillar 3 document (page 262))

Table 1 (q)

Description of limits to environmental risks (as drivers of prudential risks) that are set, and triggering escalation and exclusion in the case of breaching these limits

4.2.1 Risk Appetite (page 175), including section Measures to manage ESG risk factors (page 176)

4.2.2 Risk appetite - General framework (page 179)

5.2.1.2 Aligning our activities with patways consistent with a maximum temperature rise of 1.5 °C (page 319)

(Also see the section Risk Appetite in section 14.2.2 of the present Pillar 3 document (page 261))

Table 1 (r)

Description of the link (transmission channels) between environmental risks with credit risk, liquidity and funding risk, market risk, operational risk and reputational risk in the risk management framework

4.13.4.3 Incorporating climate risks in the risk management framework (page 281), including section Identifying climate-induced risks (page 281)

Social risk

Business strategy and processes

Table 2 (a)

Adjustment of the institution’s business strategy to integrate social factors and risks taking into account the impact of social risk on the institution’s business environment, business model, strategy and financial planning

1.3 A strategy of profitable and sustainable development, based on a diversified and integrated banking model (page 11)

2.4 Extra-financial report (page 46)

5.1.1 Being a responsible employer
(page 293)

5.2.1.3 Supporting positive change
(page 325)

5.2.2.1 Dialogue with stakeholders
(page 335)

Table 2 (b)

Objectives, targets and limits to assess and address social risk in short-term, medium-term and long-term, and performance assessment against these objectives, targets and limits, including forward-looking information in the design of business strategy and processes

4.2.1 Risk Appetite (page 175), including section Measures to manage ESG risk factors (page 176)

4.13.3 Managing ESG-related risks in the group's activities (page 275)

5.1.1 Being a responsible employer
(page 293)

5.2.1.1 Taking action and building a sustainable future together (page 314)

Table 2 (c)

Policies and procedures relating to direct and indirect engagement with new or existing counterparties on their strategies to mitigate and reduce socially harmful activities

4.13.3 Managing ESG-related risks in the group's activities (page 275)

5.5 Duty of care plan (page 361)

Governance

Table 2 (d)

Responsibilities of the management body for setting the risk framework, supervising and managing the implementation of the objectives, strategy and policies in the context of social risk management covering counterparties’ approaches to:

(i)

activities towards the community and society;

(ii)

employee relationships and labour standards;

(iii)

customer protection and product responsibility;

(iv)

Human rights.

3.1.2 Board of Directors (page 72), including sections Board of Directors and CSR (page 93), Risk committee (page 98), Appraisal of the Board of Directors and its members (page 104) et Training (page 104)

3.1.3 General Management (page 105)

5.2.3.1 Incorporating CSR at the highest level of governance (page 343)

Table 2 (e)

Integration of measures to manage social factors and risks in internal governance arrangements, including the role of committees, the allocation of tasks and responsibilities, and the feedback loop from risk management to the management body

3.1.2 Board of Directors (page 72), including section Risk Committee (page 98)

4.13.2 Analytical approach to extra-financial risks factors (page 273)

5.2.3.1 Incorporating CSR at the highest level of governance (including diagram) (page 343)

Table 2 (f)

Lines of reporting and frequency of reporting relating to social risk

5.2.3.1 Incorporating CSR at the highest level of governance (page 343)

5.5 Duty of care plan (page 361)

Table 2 (g)

Alignment of the remuneration policy in line with institution’s social risk-related objectives

3.1.6 Remuneration of Group senior Management (page 112) including elements on non-financial remuneration

Risk management

Table 2 (h)

Definitions, methodologies and international standards on which the social risk management framework is based

4.13.1 Introduction (page 273)

5.1.1 Being a responsible employer
(page 293)

Table 2 (i)

Processes to identify, measure and monitor activities and exposures (and collateral wher applicable) sensitive to social risk, covering relevant transmission channels

4.13.3 Managing ESG-related risks in the group's activities (page 275)

5.1.1 Being a responsible employer
(page 293)

5.5 Duty of care plan (page 361)

Social risk

Risk management

Table 2 (j)

Activities, commitments and assets contributing to mitigate social risk

4.13.3 Managing ESG-related risks in the group's activities (page 275)

5.1.1 Being a responsible employer (page 293)

5.5 Duty of care plan (page 361)

Table 2 (k)

Implementation of tools for identification and management of social risk

4.13.3 Managing ESG-related risks in the group's activities (page 275)

5.1.1 Being a responsible employer (page 293)

5.5 Duty of care plan (page 361)

Table 2 (l)

Description of setting limits to social risk and cases to trigger escalation and exclusion in the case of breaching these limits

4.13.3 Managing ESG-related risks in the group's activities (page 275)

5.1.1 Being a responsible employer (page 293)

5.5 Duty of care plan (page 361)

Table 2 (m)

Description of the link (transmission channels) between social risks with credit risk, liquidity and funding risk, market risk, operational risk and reputational risk in the risk management framework

4.13.3 Managing ESG-related risks in the group's activities (page 275)

Governance risk

Governance

Table 3 (a)

Institution’s integration in their governance arrangements governance performance of the counterparty, including committees of the highest governance body, committees responsible for decision-making on economic, environmental, and social topics

4.13.3.1 ESG risk management framework (page 275)

Table 3 (b)

Institution’s accounting of the counterparty’s highest governance body’s role in non-financial reporting

4.13.3.1 ESG risk management framework (page 275)

Table 3 (c)

Institution’s integration in governance arrangements of the governance performance of their counterparties including:

(i)

ethical considerations;

(ii)

strategy and risk management;

(iii)

inclusiveness;

(iv)

transparency;

(v)

management of conflict of interest;

(vi)

internal communication on critical concerns.

4.13.3.1 ESG risk framework (page 275)

Risks related to governance issues are covered by several internal processes (including the customer evaluation process - see Chapter 4.13.3, page 278, based on the principles of ethical business conduct and compliance with regulatory requirements. They include, in particular, the processes concerning financial embargoes and sanctions (see chapter 4.11 Compliance, page 266), anti-money laundering and counter-terrorism financing (see chapter 4.11 Compliance, page 266), Anti-corruption measures (see chapter 4.11 Compliance, page 267), resources appropriation, tax transparency and evasion (see chapter 4.11 Compliance, page 267) and Data protection (see chapter 4.11 Compliance, page 268)

Risk management

Table 3 (d)

Institution’s integration in risk management arrangements the governance performance of their counterparties considering:

(i)

ethical considerations;

(ii)

strategy and risk management;

(iii)

Inclusiveness;

(iv)

transparency;

(v)

management of conflict of interest;

(vi)

internal communication on critical concerns.

4.13.1 Introduction (page 273)

4.13.2 Analytical approach to extra-financial risks factors (page 273)

4.13.3.1 ESG risk framework (page 275)

14.3 QUANTITATIVE INFORMATION ON ESG RISKS

Quantitative information on environmental, social and governance risks in application of the implementing regulation 2022/2453, use the same data as the ones used to produce other regulatory reports. In particular, elements used to produce the reporting of financial information (FINREP) have been used to ensure native consistency with existing productions. Specific enhancements have then been performed from this base to comply with each template requirements. These enhancements mainly consist in using external data providers.

14.3.1 TEMPLATE 1: BANKING BOOK – CLIMATE CHANGE TRANSITION RISK

Sector breakdown of exposures to non-financial counterparts have been made by leveraging on the internal procedure used for regulatory reportings in order to determine the activity sector of a specific counterparty.

Regarding exposures towards companies excluded from EU Paris-aligned Benchmarks, their identification is based on data purchased from data provider Moody’s and internal monitoring. These data have allowed us to apply the exclusion criteria as defined under regulation 2020/1818 regarding to revenues or emissions intensity thresholds as well as the evaluation of significant harm to at least one of the six environmental objectives. Based on these results, internal reviews have performed to qualify the consistency with existing internal procedures.

The first Pillar 3 publication of greenhouse gas (GHG) emissions will be reported as of 30 June 2024. Indeed, although the Group already have these elements, more work is necessary to ensure of their quality before meeting this deadline.

Sector/subsector

 

Gross carrying amount (in EURm)









of which exposures towards

companies excluded from EU

Paris-aligned Benchmarks in

accordance with Article 12(1)

points (d) to (g) and

Article 12(2) of Regulation

(EU) 2020/1818

of which

stage 2

exposures

of which

non-

performing

exposures

1

Exposures towards sectors that highly contribute
to climate change*

176,775

16,616

17,062

7,498

 

2

A – Agriculture, forestry and fishing

2,138

-

226

127

 

3

B – Mining and quarrying

7,875

3,915

356

128

 

4

B.05 – Mining of coal and lignite

8

6

-

1

 

5

B.06 – Extraction of crude petroleum and natural gas

4,394

3,159

118

1

 

6

B.07 – Mining of metal ores

1,669

265

141

54

 

7

B.08 – Other mining and quarrying

800

5

27

12

 

8

B.09 – Mining support service activities

1,005

480

70

60

 

9

C – Manufacturing

36,139

3,818

3,650

1,856

 

10

C.10 – Manufacture of food products

5,500

1

411

264

 

11

C.11 – Manufacture of beverages

1,414

-

130

24

 

12

C.12 – Manufacture of tobacco products

99

-

3

0

 

13

C.13 – Manufacture of textiles

353

-

28

55

 

14

C.14 – Manufacture of wearing apparel

206

-

46

30

 

15

C.15 – Manufacture of leather and related products

128

-

17

15

 

16

C.16 – Manufacture of wood and of products of wood and cork, except furniture; manufacture of articles of straw and plaiting materials

621

-

31

33

 

17

C.17 – Manufacture of paper and paper products

606

-

70

15

 










 

Accumulated impairment, accumulated

negative changes in fair value due to credit risk

and provisions (in EURm)

<= 5 years

> 5 year

<= 10 years

> 10 year

<= 20 years

> 20 years

Average

weighted

maturity

 

 

of which

Stage 2

exposures

of which

non-

performing

exposures


1

(4,753)

(855)

(3,485)

124,371

29,230

19,976

3,198

5

 

2

(114)

(20)

(82)

1,446

443

170

79

6

 

3

(72)

(10)

(52)

5,554

2,128

189

3

3

 

4

-

-

-

8

-

-

-

1

 

5

(11)

(5)

(1)

3,184

1,210

-

-

3

 

6

(26)

(1)

(23)

1,123

435

110

-

4

 

7

(13)

(1)

(10)

540

247

10

3

4

 

8

(21)

(3)

(18)

698

236

70

1

4

 

9

(1,176)

(214)

(844)

30,830

3,838

1,320

151

3

 

10

(204)

(57)

(126)

4,800

537

126

37

2

 

11

(31)

(10)

(13)

1,164

157

56

37

4

 

12

-

-

-

99

0

-

-

2

 

13

(46)

(1)

(43)

290

54

6

3

3

 

14

(19)

(1)

(18)

191

15

0

0

2

 

15

(13)

-

(13)

106

8

14

1

3



16

(24)

(3)

(18)

497

91

20

13

4

 

17

(20)

(6)

(10)

565

38

2

1

2

Sector/subsector

 

Gross carrying amount (in EURm)









of which exposures towards

companies excluded from EU

Paris-aligned Benchmarks in

accordance with Article 12(1)

points (d) to (g) and

Article 12(2) of Regulation

(EU) 2020/1818

of which

stage 2

exposures

of which

non-

performing

exposures

18

C.18 – Printing and reproduction of recorded media

431

-

45

45

 

19

C.19 – Manufacture of coke and refined petroleum products

2,736

1,499

38

127

 

20

C.20 – Manufacture of chemicals and chemical products

2,404

205

142

40

 

21

C.21 – Manufacture of basic pharmaceutical products and pharmaceutical preparations

1,746

8

539

75

 

22

C.22 – Manufacture of rubber products

1,355

5

174

73

 

23

C.23 – Manufacture of other non-metallic mineral products

1,493

23

227

73

 

24

C.24 – Manufacture of basic metals

1,411

194

144

141

 

25

C.25 – Manufacture of fabricated metal products, except machinery and equipment

2,599

33

458

247

 

26

C.26 – Manufacture of computer, electronic and optical products

1,234

1

84

13

 

27

C.27 – Manufacture of electrical equipment

1,429

12

233

143

 

28

C.28 – Manufacture of machinery and equipment n.e.c.

1,898

6

198

88

 

29

C.29 – Manufacture of motor vehicles, trailers and semi-trailers

5,092

1,810

227

178

 

30

C.30 – Manufacture of other transport equipment

1,923

19

232

113

 

31

C.31 – Manufacture of furniture

292

-

19

19

 

32

C.32 – Other manufacturing

423

0

65

14

 

33

C.33 – Repair and installation of machinery and equipment

747

1

88

32

 

34

D – Electricity, gas, steam and air conditioning supply

18,076

5,785

817

266

 

35

D35.1 – Electric power generation, transmission and distribution

15,110

4,952

324

233

 

36

D35.11 – Production of electricity

13,162

4,515

244

230

 

37

D35.2 – Manufacture of gas; distribution of gaseous fuels through mains

2,810

832

492

31

 

38

D35.3 – Steam and air conditioning supply

157

2

0

1

 

39

E – Water supply; sewerage, waste management and remediation activities

2,035

250

89

29

 

40

F – Construction

8,561

177

817

846

 

41

F.41 – Construction of buildings

3,516

52

175

314

 

42

F.42 – Civil engineering

1,761

75

105

187

 

43

F.43 – Specialised construction activities

3,284

51

537

345

 

44

G – Wholesale and retail trade; repair of motor vehicles
and motorcycles

34,425

1,842

2,692

1,802

 

45

H – Transportation and storage

21,422

799

4,016

702

 

46

H.49 – Land transport and transport via pipelines

7,237

96

631

170

 

47

H.50 – Water transport

6,428

671

1,837

187

 

48

H.51 – Air transport

3,117

-

1,246

127

 

49

H.52 – Warehousing and support activities for transportation

4,592

33

296

215

 

50

H.53 – Postal and courier activities

47

-

7

3

 

51

I – Accommodation and food service activities

5,703

-

2,010

854

 

52

L – Real estate activities

40,402

30

2,389

888

 

53

Exposures towards sectors other than those that highly contribute to climate change*

96,526

760

5,657

2,833

 

54

K – Financial and insurance activities

28,409

564

917

300

 

55

Exposures to other sectors (NACE codes J, M – U)

68,117

196

4,740

2,533

 

56

TOTAL

273,301

17,376

22,719

10,331

 

*

In accordance with the Commission Delegated Regulation EU) 2020/1818 supplementing Regulation (EU) 2016/1011 as regards minimum standards for EU Climate Transition Benchmarks and EU Paris-aligned Benchmarks – Climate Benchmark Standards Regulation – Recital 6: Sectors listed in Sections A to H and Section L of Annex I to Regulation (EC) No 1893/2006

 









 

Accumulated impairment, accumulated

negative changes in fair value due to credit risk

and provisions (in EURm)

<= 5 years

> 5 year

<= 10 years

> 10 year

<= 20 years

> 20 years

Average

weighted

maturity

 

of which

Stage 2

exposures

of which

non-

performing

exposures

 

18

(24)

(3)

(18)

378

48

5

0

2

 

19

(23)

(6)

(15)

1,590

476

670

0

5

 

20

(41)

(7)

(27)

1,933

451

13

7

3


21

(28)

(10)

(14)

1,511

127

93

14

2

 

22

(48)

(9)

(31)

1,152

179

19

5

2

 

23

(50)

(6)

(36)

1,122

357

9

5

3

 

24

(101)

(12)

(86)

1,164

244

2

0

2


25

(138)

(27)

(102)

2,226

336

29

7

3

 

26

(12)

(3)

(7)

1,080

84

69

1

3

 

27

(106)

(7)

(94)

1,198

220

6

3

2

 

28

(74)

(21)

(42)

1,690

152

45

10

2

 

29

(87)

(10)

(72)

4,970

110

8

2

2

 

30

(36)

(4)

(29)

1,843

26

53

1

3

 

31

(14)

-

(12)

260

30

2

0

2

 

32

(15)

(6)

(8)

367

43

11

2

3

 

33

(20)

(4)

(13)

638

52

57

1

3

 

34

(179)

(71)

(79)

10,246

3,507

3,828

496

6

 

35

(91)

(14)

(52)

8,584

3,111

2,920

495

6

 

36

(83)

(11)

(50)

7,395

2,646

2,631

490

6


37

(86)

(57)

(26)

1,628

299

883

0

5

 

38

(2)

-

(1)

34

98

24

0

7


39

(30)

(10)

(16)

1,230

338

376

90

6

 

40

(574)

(64)

(480)

7,131

805

585

42

3

 

41

(178)

(13)

(154)

2,960

278

247

32

3

 

42

(173)

(12)

(156)

1,272

263

225

1

4

 

43

(224)

(39)

(170)

2,918

258

101

8

3


44

(1,313)

(124)

(1,105)

30,771

2,400

423

830

3

 

45

(381)

(91)

(259)

12,458

5,563

2,941

460

5

 

46

(129)

(26)

(85)

4,839

1,630

478

290

5

 

47

(78)

(42)

(31)

2,884

2,490

1,055

0

6

 

48

(59)

(16)

(42)

1,351

860

907

0

7

 

49

(113)

(7)

(101)

3,347

583

490

172

5

 

50

(1)

-

-

44

1

3

0

2

 

51

(462)

(96)

(353)

4,072

1,044

522

64

4

 

52

(452)

(155)

(215)

20,633

9,164

9,622

983

7


53

(2,102)

(583)

(1,286)

74,341

13,156

7,134

1,895

4

 

54

(177)

(30)

(110)

23,996

3,284

901

228

2

 

55

(1,925)

(553)

(1,176)

50,345

9,872

6,233

1,667

5

 

56

(6,855)

(1,438)

(4,771)

198,713

42,385

27,109

5,093

4

15 MODEL RISK

 

IN BRIEF

Model risk is defined as the potential for adverse consequences from decisions based on incorrect or misused model outputs and reports.

Many choices made within the Group are based on quantitative decision support tools (models). Model risk is defined as the risk of adverse consequences (including financial consequences) due to decisions reached based on results of internal models. The source of model risk may be linked to errors in development, implementation or use of these models and can take the form of model uncertainty or errors in the implementation of model management processes.

15.1 MODEL RISK MONITORING

The Group is fully committed to maintaining a solid governance system in terms of model risk management in order to ensure the efficiency and reliability of the identification, design, implementation, modification monitoring processes, independent review and approval of the models used. An MRM (“Model Risk Management”) Department in charge of controlling model risk was created within the Risk Department in 2017. Since then, the model risk management framework has been consolidated and structured and is based today on the following device.

The model risk management system is implemented by the three independent lines of defence, which correspond to the responsibility of the business lines in risk management, to the review and independent supervision and evaluation of the system and which are segregated and independent to avoid any conflict of interest.

The device is as follows:

the first line of defence (LoD1), which brings together several teams with diverse skills within the Group, is responsible for the development, implementation, use and monitoring of the relevance over time of the models, in accordance with model risk management system; these teams are housed in the Business Departments or their Support Departments;

the second line of defence (LoD2) is made up of governance teams and independent model review teams, and supervised by the “Model Risk” Department within the Risk Department;

the third line of defence (LoD3) is responsible for assessing the overall effectiveness of the model risk management system (the relevance of governance for model risk and the efficiency of the activities of the second line of defence) and independent audit of models: it is housed within the Internal Audit Department.

A MRM Committee chaired by the Risk Director meets at least every three months to ensure the implementation of the management system and monitor the risk of models at Group level. Within the second line of defence and the “Model risk” Department, a governance team is in charge of the design and management of the model risk management system at Group level.

As such:

the normative framework applicable to all of the Group’s models is defined, applied when necessary to the main families of models to provide details on the specifics, and maintained while ensuring the consistency and homogeneity of the system, its integrity and its compliance with regulatory provisions; this framework specifies in particular the definition of expectations with regard to LoD1, the principles for the model risk assessment methodology and the definition of guiding principles for the independent review and approval of the model;

the identification, recording and updating of information of all models within the Group (including models under development or recently withdrawn) are carried out in the model inventory according to a defined process and piloted by LoD2;

the monitoring and reporting system relating to model risk incurred by the Group in Senior Management has been put in place. The appetite for model risk, corresponding to the level of model risk that the Group is ready to assume in the context of achieving its strategic objectives, is also formalised through statements relating to risk tolerance, translated under form of specific indicators associated with warning limits and thresholds.

For each model, risk management is based on compliance with the rules and standards defined for the entire Group by each LoD1 player, it is guaranteed by an effective challenge from LoD2 and a uniform approval process.

The need to examine a model is assessed according to the level of model risk, its model family and applicable regulatory requirements. The independent review by the second line of defence is triggered in particular for new models, periodic model reviews, proposals to change models and transversal reviews in response to a recommendation:

it corresponds to all the processes and activities which aim to verify the conformity of the functioning and use of the models with respect to the objectives for which they were designed and to the applicable regulations, on the basis of the activities and controls implemented by LoD1;

it is based on certain principles aimed at verifying the theoretical robustness (evaluation of the quality of the design and development of the model), the conformity of the implementation and use, and the relevance of the monitoring of the model;

it gives rise to an Independent Review Report, which describes the scope of the review, the tests carried out, the results of the review, the conclusions or the recommendations.

The approval process follows the same approval scheme for all models, the composition of governance bodies being able to vary according to the level of model risk, the family of models, the applicable regulatory requirements and the Business Units/Service Units in which model is applicable. Responsible for LoD2, the approval process consists of two consecutive instances:

the Review Authority which aims to present the conclusions identified by the review team in the Independent Review Report and to discuss, allowing for a contradictory debate between LoD1 and LoD2. Based on the discussions, LoD2 confirms or modifies the conclusions of the Review Report, including the findings and recommendations, without being limited thereto;

the Approval Authority, a body which has the power to approve (with or without reservation) or reject the use of a model, changes made to the existing model or continuous monitoring of the relevance of the model along the time proposed by the LoD1, from the Independent Review Report and the minutes of the Review Authority.

 

16 RISK RELATED TO INSURANCE ACTIVITIES

 

IN BRIEF

Through its insurance subsidiaries, the Group is also exposed to a variety of risks linked to this business. In addition to balance sheet management risks (interest rate, valuation, counterparty and exchange rate risks), these risks include premium pricing risk, mortality risk and the risk of an increase in claims.

Risk related to insurance activities: through its insurance subsidiaries, the Group is also exposed to a variety of risks linked to this business. In addition to balance sheet management risks (interest rate, valuation, counterparty and exchange rate risk), these risks include premium pricing risk, mortality risk and the risk of an increase in claims.

16.1 MANAGEMENT OF INSURANCE RISKS

There are two main types of insurance risks:

underwriting risks, particularly risk through life insurance, individual personal protection and non-life insurance. This risk can be biometrical: disability, longevity, mortality, or related to policyholders’ behavior (risk of lapses). To a lesser extent, the Insurance business line is also exposed to non-life and health risks. Such risks can come from pricing, selection, claims management or catastrophic risk;

risks related to financial markets and ALM: the Insurance business line, mainly through life insurance on the French market, is exposed to instabilities on the financial markets (changes in interest rates and stock market fluctuations) which can be made worse by policyholder behavior.

Managing these risks is key to the Insurance business line’s activity. It is carried out by qualified and experienced teams, with major bespoke IT resources. Risks are monitored and regularly reported, they are framed by risk policies validated by the Board of Directors of each entity.

Risk management techniques are based on the following:

heightened security for the risk acceptance process, with the aim of guaranteeing that the price schedule matches the policyholder’s risk profile and the guarantees provided;

regular monitoring of indicators on product claims rates in order to adjust certain product parameters, such as pricing or the level of guarantee, if necessary;

implementation of a reinsurance plan to protect the business line from major/serial claims;

application of policies on risk, provisioning and reinsurance.

Management of risks linked to the financial markets and to ALM is an integral part of the investment strategy as long-term performance objectives. The optimization of these two factors is highly influenced by the asset/liability balance. Liability commitments (guarantees offered to customers, maturity of policies), as well as the amounts booked under the major items on the balance sheet (shareholders’ equity, income, provisions, reserves, etc.) are analyzed by the Finance and Risk Departments of the Insurance business line.

Risk management related to financial markets (interest rates, credit and shares) and to ALM is based on the following:

monitoring short- and long-term cash flows (match between the term of a liability and the term of an asset, liquidity risk management);

particular monitoring of policyholder behavior (redemption);

close monitoring of financial markets;

hedging against exchange rate risks (both rising and falling);

hedging downside equity risk;

defining thresholds and limits per counterparty, per issuer rating and assets class;

stress tests, the results of which are presented annually at entities’ Board of Directors’ meetings, as part of the ORSA Report (Own Risk and Solvency Assessment), transferred to the ACPR after approval by the Board;

application of policies related to ALM and investment risks.

16.2 INSURANCE RISK MODELING

The models are reviewed by the Insurance Risks Department, which is the second line of defense in the context of model risk management. The review works relate to the theoretical robustness (evaluation of the quality of design and development) of the models, the use of the model, the conformity of the implementation and the continuous monitoring of the relevance of the model over time. The independent review process ends with (i) a report describing the scope of the review, the tests performed, the results of the review, conclusions or recommendations and by (ii) validation Committees. The model control system gives rise to recurring reporting to the appropriate bodies.

 

17 OTHER RISKS

 

IN BRIEF

This section describes equity risks and other risks not described in previous chapters.

17.1 INVESTMENT RISK

The Group has limited appetite for financial shareholdings in proprietary private equity operations. The types of acceptable private equity operations chiefly involve:

commercial support for the network through the private equity business of the Group’s retail banking networks in France and certain foreign subsidiaries;

shareholdings in innovative companies, either directly or through private equity funds;

shareholdings in financial services companies such as Euroclear and Crédit Logement.

Private equity investments are managed directly by the networks concerned (the Group’s retail bank in France and foreign subsidiaries) and are capped at EUR 25 million. Any investments above this threshold must be approved by the Group Strategy Department based on a file submitted by the Business Unit in conjunction with its Finance Department. The file must set out arguments justifying an investment of the allotted size, with details of:

the projected outcome;

the expected profitability based on the consumption of the associated capital;

the investment criteria (typology, duration, etc.);

the risk analysis;

the proposed governance.

The Group’s General Management must approve the investment amount if it exceeds EUR 50 million and must base its decision on the opinion delivered by the Strategy Department, the Finance Department, the General Secretary and the Compliance Department. At least once a year, the relevant Business Unit must submit a status report to the Strategy Department tracking the operations and the use of the allocated investment amount.

Other private equity minority investments undergo a dedicated validation process for both the investment and divestment phases. They are approved by the Heads of the Business Units and the entities concerned, by their Finance Department and the Strategy Department. Approval must also be sought from the Group’s General Management for amounts over EUR 50 million, and from the Board of Directors for amounts exceeding EUR 250 million. These files are assessed by the Strategy Department with the assistance of experts from the Services Units and Business Units involved in the operation, comprising at least the Finance Department, the General Secretary’s Legal and Tax Departments and the Compliance Department. The assessment is based on:

a review of the proposed shareholding;

the context of the investment and the reasons for going ahead with it;

the structuring of the operation;

its financial and prudential impacts;

an evaluation of the identified risks and the resources employed to track and manage them.

17.2 RISK RELATED TO OPERATING LEASING ACTIVITIES

Risk related to operating leasing activities is the risk of management of the goods leased (including the risk on residual value mainly, and risk on the value of the repair, maintenance and tires to a lesser extent), excluding the operational risk.

Through its Specialized Financial Services Division, mainly in its long-term vehicle leasing subsidiary, the Group is exposed to residual value risk (where the net resale value of an asset at the end of the leasing contract is less than expected).

Societe Generale Group holds, inside its ALDA Business Units (automobile leasing activity) cars on its balance sheet with a risk related to the residual value of these vehicles at the moment of their disposals. This residual value risk is managed by ALD Automotive (ALDA).

The Group is exposed to potential losses in a given reporting period caused by (i) the resale of vehicles associated with leases terminated in the reporting period where the used car resale price is lower than its net book value and (ii) additional depreciation booked during the lease term if the expected residual values of its vehicles decline below the contractual residual value. The future sales results and estimated losses are affected by external factors like macroeconomic, government policies, environmental and tax regulations, consumer preferences, new vehicles pricing, etc.

ALDA gross operating income derived from car sales totaled EUR 747.6 million at 31 December 2022 versus EUR 437.7 million at 31 December 2021.

The residual value setting procedure defines the processes, roles and responsibilities involved in the determination of residual values that will be used by ALDA as a basis for producing vehicle lease quotations.

A Residual Value Review Committee is held at least twice a year within each operating entity of ALDA. This Committee debates and decides residual values, taking into account local market specificities, documenting its approach, ensuring that there is a clear audit trail.

A central ALDA team dedicated to control validates the proposed residual values prior to their being notified to the operating entities and updated in the local quotation system. This team informs ALD’s Group Finance Director and Risk Manager in case of disagreements.

Additionally, the fleet revaluation process determines an additional depreciation in countries where an overall loss on the portfolio is identified. This process is performed locally twice a year for operating entities owning more than 5,000 cars (once a year for smaller entities) under the supervision of the central team and using common tools and methodologies. This depreciation is booked in accordance with accounting standards.

17.3 STRATEGIC RISKS

Strategic risks are defined as the risks inherent in the choice of a given business strategy or resulting from the Group’s inability to execute its strategy. They are monitored by the Board of Directors, which approves the Group’s strategic trajectory and reviews them at least once a year. Moreover, the Board of Directors approves strategic investments and any transaction (particularly disposals and acquisitions) that could significantly affect the Group’s results, the structure of its balance sheet or its risk profile.

Strategic steering is carried out under the authority of General Management, by the General Management Committee (which meets weekly without exception), by the Group Strategy Committee and by the Strategic Oversight Committees of the Business Units and Service Units. The composition of these various bodies is set out in the Corporate Governance chapter of the Universal Registration Document, Chapter 3 (see pages 69 and following). The Internal Rules of the Board of Directors (provided in Chapter 7 of the Universal Registration Document, at page 652) lay down the procedures for convening meetings.

17.4 CONDUCT RISK

The Group is also exposed to conduct risk through all of its core businesses. The Group defines conduct risk as resulting from actions (or inactions) or behaviours of the Bank or its employees, inconsistent with the Group’s Code of Conduct, which may lead to adverse consequences for its stakeholders, or place the Bank’s sustainability or reputation at risk.

Stakeholders include in particular the clients, employees, investors, shareholders, suppliers, the environment, markets and countries in which the Group operates.

See also “Culture & Conduct programme” (see page 184 of the Universal Registration Document).

 

18 PERSON RESPONSIBLE FOR THE PILLAR 3 REPORT

 

18.1 PERSON RESPONSIBLE FOR THE PILLAR 3 REPORT

Mrs. Claire DUMAS

Group Chief Financial Officer of Societe Generale

18.2 STATEMENT OF THE PERSON RESPONSIBLE FOR THE PILLAR 3 REPORT

I certify, after having taken all reasonable measures to this effect, that the information disclosed in this Pillar 3 Risk Report complies, to the best of my knowledge, with Part 8 of EU Regulation No. 2019/876 (and its subsequent amendments) and has been established in accordance with the internal control procedures agreed upon at the management body level.

Paris, 17 March 2022

Group Chief Financial Officer

Mrs. Claire DUMAS

 

19 APPENDICES

 

19.1 PILLAR 3 CROSS-REFERENCE TABLE

CRD4/CRR

article

Theme

Pillar 3 report reference

(except reference to the Universal Registration Document)


Page in

Pillar 3 report

90 (CRD)

Return on assets

5 Capital management and adequacy

55

435 (CRR)

Risk management objectives and policies

1 Group concise risk statement

3 Risk management and organisation

12 Liquidity risk

5-13

32-44

232-234

436 (CRR)

Scope of application

5 Capital management and adequacy

56-59;83-89

SG website - Capital instruments and TLAC eligible SNP/SP

 

SG website - Information about the consolidation scope

 

SG website - Differences in the scopes of consolidation (LI3)

 

437 (CRR)

Own funds

5 Capital management and adequacy

60-63;70-73

437a (CRR)

TLAC and related eligible instruments

5 Capital management and adequacy

SG website - Capital instruments and TLAC eligible SNP/SP

66;74-76

438 (CRR)

Capital requirements

5 Capital management and adequacy

54;64;

439 (CRR)

Exposure to counterparty credit risk

7 Counterparty credit risk

166-178

 

440 (CRR)

Capital buffers

5 Capital management and adequacy

80-82

441 (CRR)

Indicators of global systemic importance

SG website - Information and publication section

 

442 (CRR)

Credit risk adjustments

6 Credit risk

94;120-124

443 (CRR)

Encumbered and unencumbered assets

12 Liquidity risk

234-237

444 (CRR)

Information on the use of the standardised approach/use of ECAIs

6 Credit risk

8 Securitisation

94-97;139-142;

191

445 (CRR)

Exposure to market risk

9 Market risk

200-213

446 (CRR)

Operational risk

10 Operational risk

216-224

447 (CRR)

Information on key metrics

1 Group concise risk statement

13-15

 

448 (CRR)

Exposure to interest rate risk on positions not included in the trading book

11 Structural interest rate and exchange rate risks

222-229

449 (CRR)

Exposure to securitisation positions

8 Securitisation

180-198

449 bis (CRR)

Environnemental Social Governance

14 ESG

256-274

450 (CRR)

Remuneration policy

First update of the Pillar 3 report (planned)

 

451 (CRR)

Leverage

5 Capital management and adequacy

67;77-80

451a (CRR)

Liquidity

12 Liquidity risk

232-234;238-246

452 (CRR)

Use of the IRB Approach to credit risk

6 Credit risk

96;142-154

453 (CRR)

Use of credit risk
mitigation techniques

6 Credit risk

 

91-93;134;155-159

 

454 (CRR)

Use of the advanced measurement approaches to operational risk

10 Operational risk

216-224

455 (CRR)

Use of internal market risk models

9 Market risk

200-213

19.2 INDEX OF THE TABLES IN THE RISK REPORT

Chapter

Table

number

Pillar 3

report

Table

number

URD(1)

Title

Page in Pillar 3

report

Page in

URD(1)

EBA regulatory

references

1

1

10

Distribution of RWA by core business
and by risk type

7

204

 

1

2

 

Provisioning of doubtful loans

9

 

 

1

3

 

Cost of risk

9

 

 

1

4

 

Market risk – VaR and SVaR

10

 

 

1

5

35

Interest rate risk of non-trading book activities

12

249

IRRBB1

1

6

 

Key metrics

13

 

KM1

1

7

 

TLAC – Key metrics

15

 

KM2

3

8

1

Financial assets and liabilities and derivatives impacted by the interest rate benchmarks reform

44

187

 

5

9

2

Difference between accounting scope
and prudential reporting scope

56

196

 

5

10

3

Reconciliation of regulatory own funds
to balance sheet in the audited financial statements

56

197

CC2 

5

11

4

Entities outside the prudential scope

58

199

 

5

12

 

Total amount of debt instruments eligible
for Tier 1 equity

61

 

 

5

13

5

Changes in debt instruments eligible for solvency capital requirements

61

201

 

5

14

6

Breakdown of prudential capital requirement
for Societe Generale

62

201

 

5

15

7

Regulatory capital and solvency ratios

62

202

 

5

16

8

CET1 regulatory deductions and adjustments

63

202

 

5

17

9

Overview of risk-weighted assets

64

203

OV1

5

18

10

Risk-weighted assets (RWA) by core business and risk type

65

204

 

5

19

 

Main subsidiaries’ contributions to the Group’s RWA

65

 

 

5

20

11

Leverage ratio summary and transition from prudential balance sheet to leverage exposure

67

205

 

5

21

 

Financial conglomerates information on own funds and capital adequacy ratio

68

 

 INS2

5

22

 

Comparison of own funds and capital and leverage ratios with and without the application of transitional arrangements for IFRS 9

69

 

IFRS9-FL

5

23

 

Non-deducted equities in insurance undertakings

69

 

INS1

5

24

 

Composition of regulatory own funds

70

 

CC1

5

25

 

TLAC – Composition

74

 

TLAC1

5

26

 

TLAC – Creditor ranking of the resolution entity

75

 

TLAC3

5

27

 

Summary reconciliation of accounting assets and leverage ratio exposures

77

 

LR1-LRSUM

5

28

 

Leverage ratio – Common disclosure

78

 

LR2-LRCOM

5

29

 

Leverage ratio – Split-up of on-balance sheet exposures (excluding derivatives, SFTs and exempted exposures)

80

 

LR3-LRSPL

5

30

 

Geographical distribution of credit exposures relevant for the calculation of the countercyclical buffer

81

 

CCyB1

5

31

 

Amount of institution-specific countercyclical capital buffer

82

 

CCyB2

5

32

 

Differences between statutory and prudential consolidated balance sheets and allocation to regulatory risk categories

83

 

LI1

5

33

 

Main sources of differences between regulatory exposure amounts and carrying amounts
in financial statements

87

 

LI2

5

34

 

Prudent valuation adjustments (PVA)

89

 

PV1

6

35

 

Credit rating agencies used in standardised approach

98

 

 

6

36

13

Scope of the IRB and SA approaches

98

212

CR6-A

6

37

14

Scopes of application of the IRB and standardised approaches for the Group

99

212

 

6

38

15

Societe Generale’s internal rating scale and indicative corresponding scales of rating agencies

100

214

 

6

39

16

Main characteristics of models and methods – Wholesale clients

101

215

 

6

40

19

Comparison of risk parameters : estimated and actual LGD wholesale clients

102

218

 

6

41

20

Main characteristics of models and methods used – Retail clients

103

219

 

6

42

 

Internal approach - backtesting of PD per exposure class (fixed PD scale) – AIRB

104

 

CR9

6

43

 

Internal approach - backtesting of PD per exposure class (fixed PD scale) – FIRB

108

 

CR9

6

44

 

Internal approach - backtesting of PD per exposure class (only for PD estimates according to point (F) of article 180(1) CRR) – AIRB

110

 

CR9.1

6

45

 

Internal approach - backtesting of PD per exposure class (only for PD estimates according to point (F) of article 180(1) CRR) – FIRB

113

 

CR9.1

6

46

21

Comparison of risk parameters: estimated
and actual PD values – Retail clients

114

220

 

6

47

 

Exposure classes

116

 

 

6

48

23

Change in risk-weighted assets (RWA) by approach (credit and counterparty credit risks)

118

224

 

6

49

 

Performing and non-performing exposures
and related provisions

121

 

CR1

6

50

 

Changes in the stock of non-performing loans
and advances

123

 

CR2

6

51

 

Credit quality of forborne exposures

123

 

CQ1

6

52

 

Credit quality of performing and non-performing exposures by past due days

125

 

CQ3

6

53

 

Credit quality of non-performing exposures
by geography

127

 

CQ4

6

54

 

Credit quality of loans and advances to non-financial corporations by industry

131

 

CQ5

6

55

 

Collateral obtained by taking possession
and execution processes

133

 

CQ7

6

56

 

Maturity of exposures

134

 

CR1-A

6

57

12

Credit risk mitigation techniques – Overview

134

210

CR3

6

58

 

Information on loans and advances subject
to legislative and non-legislative moratoria

135

 

 

6

59

 

Breakdown of loans and advances subject
to legislative and non-legislative moratoria
by residual maturity of the moratoria

136

 

 

6

60

 

Information on newly originated loans and advances provided under newly applicable public guarantee schemes introduced in response to Covid-19 crisis

137

 

 

6

61

 

Credit risk exposure, EAD and RWA by exposure class and approach

138

 

 

6

62

 

Standardised approach – Credit risk exposure
and credit risk mitigation (CRM) effects

139

 

CR4

6

63

 

Standardised approach – Credit risk exposures
by regulatory exposure class and risk weights

142

 

CR5

6

64

 

Internal approach – Credit risk exposures
by exposure class and PD range – AIRB

143

 

CR6

6

65

 

Internal approach – Credit risk exposures
by exposure class and PD range – FIRB

151

 

CR6

6

66

 

IRB approach – Effect on RWA of credit derivatives used as CRM techniques

155

 

CR7

6

67

 

Internal approach – Disclosure of the extent
of the use of CRM techniques – AIRB

156

 

CR7-A

6

68

 

Internal approach – Disclosure of the extent
of the use of CRM techniques – FIRB

158

 

CR7-A

6

69

 

RWA flow statement of credit risk exposures
under the IRB approach

159

 

CR8

6

70

 

Specialised lending exposures – internal approach

160

 

CR10.1-10.4

6

71

 

Equity exposures under the simple risk-weighted approach

161

 

CR10.5

7

72

26

Counterparty credit risk exposure, EAD and RWA by exposure class and approach

170

232

 

7

73

27

Analysis of counterparty credit risk exposure
by approach

171

233

CCR1

7

74

28

Exposures to central counterparties

172

234

CCR8

7

75

 

Composition of collateral for counterparty credit risk exposures

173

 

CCR5

7

76

29

Transactions subject to own funds requirements for CVA risk

173

234

CCR2

7

77

 

Internal approach – Counterparty credit risk exposures by exposure class and PD scale

174

 

CCR4

7

78

 

Standardised approach – Counterparty credit risk exposures by regulatory exposure class
and risk weights

176

 

CCR3

7

79

 

Credit derivatives exposures

177

 

CCR6

7

80

 

RWA flow statement of counterparty credit risk exposures under the IMM

178

 

CCR7

8

81

 

Quality of securitisation positions retained or acquired

185

 

 

8

82

 

Securitisation exposures in the non-trading book

187

 

SEC1

8

83

 

Securitisation exposures in the trading book

188

 

SEC2

8

84

 

Exposures securitised by the institution – Exposures in default and specific credit risk adjustments

189

 

SEC5

8

85

 

Credit rating agencies used in securitisations
by type of underlying assets

191

 

 

8

86

 

Securitisation exposures in the non-trading book and associated regulatory capital requirements – institution acting as originator
or as sponsor

192

 

SEC3

8

87

 

Securitisation exposures in the non-trading book and associated regulatory capital requirements – institution acting as investor

194

 

SEC4

9

88

30

Regulatory ten-day 99% VaR and one-day
99% VaR

206

240

 

9

89

31

Regulatory ten-day 99% SVaR and one-day
99% SVaR

207

242

 

9

90

32

IRC (99.9%) and CRM (99.9%)

208

243

 

9

91

33

Market risk RWA and capital requirements
by risk factor

210

245

 

9

92

34

Market risk capital requirements and RWA
by type of risk

210

245

 

9

93

 

Market risk under the standardised approach

212

 

MR1

9

94

 

Market risk under the internal model approach

212

 

MR2-A

9

95

 

Internal model approach values for trading portfolios

213

 

MR3

9

96

 

RWA flow statement of market risk exposures under the internal model approach

213

 

MR2-B

10

97

39

Operational risk own fund requirements and risk-weighted assets

223

263

OR1

11

98

35

Interest rate risk of non-trading book activities

228

249

IRRBB1

11

99

36

Sensitivity of the Group’s Common Equity
Tier 1 ratio to a 10% change in the currency
(in basis points)

229

250

 

12

100

 

Encumbered and unencumbered assets

235

 

AE1

12

101

 

Collateral received

236

 

AE2

12

102

 

Sources of encumbrance

237

 

AE2

12

103

37

Liquidity reserve

238

253

 

12

104

 

Liquidity Coverage Ratio

239

 

LIQ1

12

105

 

Net Stable Funding Ratio

241

 

LIQ2

14

107

 

Banking book – Indicators of potential climate Change transition risk: Credit quality of exposures by sector, emissions and residual maturity

262

 

 

14

108

 

Banking book – Indicators of potential climate change transition risk: Loans collateralised by immovable property – Energy efficiency of the collateral

266

 

 

14

109

 

Banking book – Indicators of potential climate change transition risk: Exposures to top 20 carbon-intensive firms

267

 

 

14

110

 

Banking book – Indicators of potential climate change physical risk: Exposures subject to physical risk

268

 

 

14

111

 

Other climate change mitigating actions that are not covered in Regulation (EU) 2020/852

274

 

 

(1)

Universal Registration Document.

19.3 MAPPING TABLE OF EXPOSURE CLASSES

As part of the presentation of credit risk data, the table below shows the link between the synthetic presentations of certain tables and the exposure classes detailed in the tables requested by the EBA in the context of the revision of Pillar 3.

Approach

COREP exposure class

Pillar 3 exposure class

AIRB

Central governments and central banks

Sovereigns

AIRB

Institutions

Institutions

AIRB

Corporate - SME

Corporates

AIRB

Corporate - Specialised lending

Corporates

AIRB

Corporate - Other

Corporates

AIRB

Retail - Secured by real estate SME

Retail

AIRB

Retail - Secured by real estate non-SME

Retail

AIRB

Retail - Qualifying revolving

Retail

AIRB

Retail - Other SME

Retail

AIRB

Retail - Other non-SME

Retail

AIRB

Other non credit-obligation assets

Others

AIRB

Default funds contributions

Others

FIRB

Central governments and central banks

Sovereigns

FIRB

Institutions

Institutions

FIRB

Corporate - SME

Corporates

FIRB

Corporate - Specialised lending

Corporates

FIRB

Corporate - Other

Corporates

IRB

Equity Exposures

Others

IRB

Securitisation

Others

Standardised

Central governments or central banks

Sovereigns

Standardised

Regional governments or local authorities

Institutions

Standardised

Public sector entities

Institutions

Standardised

Multilateral development banks

Sovereigns

Standardised

International organisations

Sovereigns

Standardised

Institutions

Institutions

Standardised

Corporates

Corporates

Standardised

Retail

Retail

Standardised

Secured by mortgages on immovable property

Others

Standardised

Exposures in default

Others

Standardised

Items associated with particularly high risk

Others

Standardised

Covered bonds

Others

Standardised

Claims on institutions and corporate with a short-term credit assessment

Others

Standardised

Claims in the form of CIU

Others

Standardised

Equity Exposures

Others

Standardised

Other items

Others

Standardised

Default funds contributions

Others

Standardised

Securitisation

Others

19.4 ABBREVIATIONS TABLE

Abbreviation

Meaning

ABS

Asset-Backed Securities

ACPR

Autorité de contrôle prudentiel et de résolution (French supervisory authority)

ALM

Asset and Liability Management

CCF

Credit Conversion Factor

CDS

Credit Default Swap

CDO

Collaterallised Debt Obligation

CLO

Collateralised Loan Obligation

CMBS

Commercial Mortgage-Backed Securities

CRD

Capital Requirement Directive

CRM (credit risk)

Credit Risk Mitigation

CRM (market risk)

Comprehensive Risk Measure

CRR

Capital Requirement Regulation

CVaR

Credit Value at Risk

EAD

Exposure At Default

ECB

European Central Bank

EL

Expected Loss

IMM

Internal Model Method

IRBA

Internal Ratings-Based approach – Advanced

IRBF

Internal Ratings-Based approach – Foundation

IRC

Incremental Risk Charge

G-SIB

Global Systemically Important Bank

LCR

Liquidity Coverage Ratio

LGD

Loss Given Default

MREL

Minimum Requirement for own funds and Eligible Liabilities

NSFR

Net Stable Funding Ratio

PD

Probability of Default

RMBS

Residential Mortgage-Backed Securities

RW

Risk Weight

RWA

Risk-Weighted Assets

SREP

Supervisory Review and Evaluation Process

SVaR

Stressed Value at Risk

TLAC

Total Loss Absorbing Capacity

VaR

Value at Risk