+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 - Published by the European Banking Authority at https://www.eba.europa.eu/