+d. Implementation strategy

d. Implementation strategy

i. Overview of short-, me-dium-, and long-term actions taken or planned in core banking activities and processes to achieve the plan’s targets, in-cluding how the institution em-information its fectiveness beds framework, its decision-making regular the plan’s or on risk complemented estimated the objectives management observed process contri- into and by ef-Actions taken or planned in core banking activities: Changes the risk ment work: regular manage- frame- toThis pertains to how the insti-tution will implement its ob-jectives and targets through its core activity. This pertains to how the insti-tution into management ICAAP, capital/portfolio budgeting the will ILAAP, mix embed process, of tools RAS, existing allocation, its risk strategic (e.g. targets limits, risk# Implementation of new tools for assessing ESG risks in current portfolios # Integration of ESG risk-related objectives into the medium strategic cision-making # into Incorporating the risk planning and management long-term processes ESG and risks de-Key ERSR-E1-1_16b # Percentage of activi-ties affected by imple-ESRS-E1 mentation actions Qualitative: ESRS Table 1 # Percentage of busi- (n) ESRS-E1-2 ness at plan's # risk Adoption implementing management decisions targets rate that of tools ESG aim the Table (a) Table (c) 2 3 ESRS-E1-3 ------------------- ESRS-E2-E5 ESRS-S1-S4 ESRS-G1 ESRS-E3actions: MDR-A 2 MDR-A MDR-A MDR-A
bution of each action to the rele-vant target(s).Policies and conditions on activities, sec-tors, loca-tions:plan, funding plan, etc), in line w ith section 5. Policies and the conditions that govern them, including updates to existing policies and newly created policies, in line with paragraph 46(b-c).framework # A list of current policies and original ESG risk sta-tus # A roadmap detailing which policies & condi-tions, and their scope, will be updated or created, how, when and by whom # For each policy, the fol-lowing aspects may be in-ESRS-E4 ESRS-E5 # Policy adoption rate, e.g. percentage of branches or depart-ments that have adopted new ESG risks ESRS-E1-1_16b policies ESRS-E1-2 ESRS-E1-3 # Number of times ESG Qualitative:MDR-A MDR-A 52
ii. Adaptations to policies and procedures on financial risk cate-gories and to lending and invest-ment policies and conditions on key economic activities, sectors and locations.Policies and procedures on financial risk categories:This pertains to the adapta-tions made to policies and pro-cedures in accordance with section 5.6. This pertains to how the insti-tution will adapt its mix of ser-cluded: . Goal: how it reflects the strategic objective, risk strategy and supports the implementation of the plan . Scope: precise iteration of business, location, sec-tor etc that are governed and impacted . Conditions: clear criteria ensuring ease of applica-bility and tracking . Exclusions: any exclu-sions in line with risk ap-petite # Risk-based pricing: ad-justing pricing based on the ESG risk profile of therisk policies are re- Table 1 viewed and updated (d) (o) Activities within a given period Table 2 lated (c) (e) in/near # Percentage of opera- Table 3 versity-sensitive tions in compliance ( c) (d) areas: with updated ESG risk ESRS policies 1_19a # Outcomes of internal and external audits fo-cused on ESG risk man-agement framework # Frequency and extent Qualitative: Activities of pricing adjustments Table 1re-to sites biodi-E4.IRO-53 in-
iii. Changes introduced to the mix and pricing of services and products to support the imple-mentation of the plan.Mix and pric-ing of services and products: Sustainability-related and transition-re-lated products and services:vices and products and their pricing based on ESG risk-rele-vant criteria and the institu-tion’s risk strategy and inter-nal capital policy, in line with paragraph 46b. The types of financial instru-ments (green and sustainabil-ity-linked loans, bonds, mort-gages, funds…) and advisory services offered or managedborrower or project # Incentives for risk miti-gation: offering incentives for clients who implement effective ESG risk mitiga-tion strategies # Strategy, policies and criteria on green or transi-tion or ESG-linked mort-gages, loans and bondscompatible based on ESG risk pro- (r) transition: files Table 2 ESRS-E1.IRO-1 # Number of clients (j) taking advantage of in- Table 3 AR12 centive pricing (d) # Growth in sustaina-ble financing: year-to-year growth in the vol-ume and proportion of sustainable financing # Default rate on green or transition or ESG-with
iv. Investments and strategic portfolio allocation supporting the institution’s business strat-egy and risk appetite in relation to ESG risks, including infor-mation on sustainability-related and transition-related products commensurate changes choices and services, are in strategic accompanied risk and management how financing any byConsistency strategic nancing choices with fi- ofby the institution. This tution cides and strategy, pertains to will adapt ensure, to that its how business when those the it insti- de- mix# Diversification of lend-ing and investments port-folios based on ESG risk-relevant criteria e.g. in terms or # green Credit geographical of loans economic risk policies and areas sectors mort- onlinked mortgages or loans Qualitative: ESRS-E1-3 Table 1 (m) (r) ESRS-E4-1 # Proportion of new fi- Table 2 e nanced projects that (e) undergo a comprehen- Outcomes sive ment # decisions Percentage ESG that risk of explicitly assess- credit Quantita- tive: Templates 0 6>10 affected munities: ESRS-S3-4 bAR 1 for com- AR 34
procedures.risk manage-ment proce-dures:changes fit the risk manage-ment arrangements to have in place in accordance with sec-tion 5.gages # How an institution that finances renewable en-ergy projects ensures that the projects comply with environmental regula-tions to avoid legal and reputational risksconsider ESG risks # Profit margins on ESG-related products: comparison of profit margins between ESG-related products and traditional products54

1. Overview

,
Summary Regulation

1.1 References

1.2 Identified Requirements

1.3 Related Standards

2. Identified Requirements

Requirements
Source Requirement

3. Related Standards

Standards
Source Requirement
  • EBA -

    EN: Guidelines and other publications of the European Banking Authority (EBA), https://www.eba.europa.eu/. © European Banking Authority. Reproduction is authorised provided the source is acknowledged (EBA legal notice). Divided into sections and converted into the GRCA format, the wording unchanged. Only the versions published by the EBA are authoritative.

    DE: Leitlinien und weitere Veröffentlichungen der Europäischen Bankenaufsichtsbehörde (EBA), https://www.eba.europa.eu/. © European Banking Authority. Wiedergabe mit Quellenangabe gestattet (Rechtlicher Hinweis der EBA). In Abschnitte aufgeteilt und in das GRCA-Format umgewandelt, der Wortlaut unverändert. Maßgeblich sind allein die von der EBA veröffentlichten Fassungen.