549300JB1P61FUTPEZ75 2025-12-31 549300JB1P61FUTPEZ75 2024-12-31 549300JB1P61FUTPEZ75 2025-01-01 2025-12-31 549300JB1P61FUTPEZ75 2024-01-01 2024-12-31 549300JB1P61FUTPEZ75 2023-12-31 549300JB1P61FUTPEZ75 2024-01-01 2024-12-31 ifrs-full:ReserveOfExchangeDifferencesOnTranslationMember 549300JB1P61FUTPEZ75 2024-01-01 2024-12-31 ifrs-full:RevaluationSurplusMember 549300JB1P61FUTPEZ75 2024-01-01 2024-12-31 ifrs-full:ReserveOfCashFlowHedgesMember 549300JB1P61FUTPEZ75 2024-01-01 2024-12-31 ifrs-full:RetainedEarningsMember 549300JB1P61FUTPEZ75 2024-01-01 2024-12-31 ifrs-full:StatutoryReserveMember 549300JB1P61FUTPEZ75 2024-01-01 2024-12-31 ifrs-full:IssuedCapitalMember 549300JB1P61FUTPEZ75 2024-01-01 2024-12-31 vub:OtherCapitalFundsMember 549300JB1P61FUTPEZ75 2024-01-01 2024-12-31 ifrs-full:ReserveOfGainsAndLossesOnFinancialAssetsMeasuredAtFairValueThroughOtherComprehensiveIncomeMember 549300JB1P61FUTPEZ75 2024-01-01 2024-12-31 ifrs-full:SharePremiumMember 549300JB1P61FUTPEZ75 2025-01-01 2025-12-31 ifrs-full:ReserveOfGainsAndLossesOnFinancialAssetsMeasuredAtFairValueThroughOtherComprehensiveIncomeMember 549300JB1P61FUTPEZ75 2025-01-01 2025-12-31 ifrs-full:StatutoryReserveMember 549300JB1P61FUTPEZ75 2025-01-01 2025-12-31 ifrs-full:ReserveOfExchangeDifferencesOnTranslationMember 549300JB1P61FUTPEZ75 2025-01-01 2025-12-31 ifrs-full:IssuedCapitalMember 549300JB1P61FUTPEZ75 2025-01-01 2025-12-31 ifrs-full:ReserveOfCashFlowHedgesMember 549300JB1P61FUTPEZ75 2025-01-01 2025-12-31 ifrs-full:SharePremiumMember 549300JB1P61FUTPEZ75 2025-01-01 2025-12-31 ifrs-full:RetainedEarningsMember 549300JB1P61FUTPEZ75 2025-01-01 2025-12-31 vub:OtherCapitalFundsMember 549300JB1P61FUTPEZ75 2025-01-01 2025-12-31 ifrs-full:RevaluationSurplusMember 549300JB1P61FUTPEZ75 2023-12-31 ifrs-full:IssuedCapitalMember 549300JB1P61FUTPEZ75 2023-12-31 ifrs-full:RevaluationSurplusMember 549300JB1P61FUTPEZ75 2023-12-31 ifrs-full:RetainedEarningsMember 549300JB1P61FUTPEZ75 2023-12-31 ifrs-full:ReserveOfExchangeDifferencesOnTranslationMember 549300JB1P61FUTPEZ75 2023-12-31 ifrs-full:SharePremiumMember 549300JB1P61FUTPEZ75 2023-12-31 vub:OtherCapitalFundsMember 549300JB1P61FUTPEZ75 2023-12-31 ifrs-full:StatutoryReserveMember 549300JB1P61FUTPEZ75 2023-12-31 ifrs-full:ReserveOfGainsAndLossesOnFinancialAssetsMeasuredAtFairValueThroughOtherComprehensiveIncomeMember 549300JB1P61FUTPEZ75 2023-12-31 ifrs-full:ReserveOfCashFlowHedgesMember 549300JB1P61FUTPEZ75 2024-12-31 ifrs-full:RevaluationSurplusMember 549300JB1P61FUTPEZ75 2024-12-31 ifrs-full:RetainedEarningsMember 549300JB1P61FUTPEZ75 2024-12-31 ifrs-full:StatutoryReserveMember 549300JB1P61FUTPEZ75 2024-12-31 ifrs-full:ReserveOfGainsAndLossesOnFinancialAssetsMeasuredAtFairValueThroughOtherComprehensiveIncomeMember 549300JB1P61FUTPEZ75 2024-12-31 ifrs-full:ReserveOfCashFlowHedgesMember 549300JB1P61FUTPEZ75 2024-12-31 ifrs-full:IssuedCapitalMember 549300JB1P61FUTPEZ75 2024-12-31 ifrs-full:SharePremiumMember 549300JB1P61FUTPEZ75 2024-12-31 ifrs-full:ReserveOfExchangeDifferencesOnTranslationMember 549300JB1P61FUTPEZ75 2024-12-31 vub:OtherCapitalFundsMember 549300JB1P61FUTPEZ75 2025-12-31 ifrs-full:ReserveOfGainsAndLossesOnFinancialAssetsMeasuredAtFairValueThroughOtherComprehensiveIncomeMember 549300JB1P61FUTPEZ75 2025-12-31 ifrs-full:StatutoryReserveMember 549300JB1P61FUTPEZ75 2025-12-31 vub:OtherCapitalFundsMember 549300JB1P61FUTPEZ75 2025-12-31 ifrs-full:ReserveOfCashFlowHedgesMember 549300JB1P61FUTPEZ75 2025-12-31 ifrs-full:IssuedCapitalMember 549300JB1P61FUTPEZ75 2025-12-31 ifrs-full:ReserveOfExchangeDifferencesOnTranslationMember 549300JB1P61FUTPEZ75 2025-12-31 ifrs-full:SharePremiumMember 549300JB1P61FUTPEZ75 2025-12-31 ifrs-full:RetainedEarningsMember 549300JB1P61FUTPEZ75 2025-12-31 ifrs-full:RevaluationSurplusMember iso4217:EUR
2
Table of Contents
ANNUAL FINANCIAL REPORT 2025
...............................................................................................................
3
ANNUAL REPORT 2025
................................................................................................................................
4
General information about the Bank
.............................................................................................................
4
Address by the Chairman of the VUB Supervisory Board
..................................................................................
8
Address by the Chairman of the VUB Management Board
..................................................................................
9
VUB Management Board Report on the Business Activities of the Company
.....................................................
12
Corporate Governance Statement
...............................................................................................................
19
Consolidated Financial Statements
..............................................................................................................
33
Separate financial statements
...................................................................................................................
134
Profit distribution
....................................................................................................................................
235
Consolidated Sustainability Report
............................................................................................................
236
Annexes
.................................................................................................................................................
390
3
ANNUAL FINANCIAL REPORT 2025
VUB, a.s., as an issuer of debt securities that have been admitted to trading on a regulated market and in accordance
with Article 34 of Act No. 429/2002 Coll. on the Stock Exchange, as amended, and Article 77 of Act No. 566/2001
Coll. on Securities and Investment Services and on changes and amendments to some acts, as amended, prepared
the following annual ﬁnancial report, which includes the annual report.
The annual report is an integral part of the annual ﬁnancial report and is prepared in accordance with Act no.
431/2002 Coll. on Accounting, as amended, Act no. 423/2015 Coll. on Statutory Audit as amended by Act No.
566/2001 Coll. on Securities and Investment Services and on changes and amendments to some acts, as amended
and Article 34(5) of the Act on the Stock Exchange and Article 77(2) of Act No. 566/2001 Coll. on Securities and
Investment Services, as amended, including individual and consolidated ﬁnancial statements certiﬁed by the auditor
Ernst & Young Slovakia, spol. s
r.o., Žižkova 9, 811 02 Bratislava, licence SKAU No. 2
57.
The annual ﬁnancial statements of the parent company Intesa Sanpaolo S.p.A., Torino, Italy, are fully available on
the website of the parent company: www.intesasanpaolo.com.
Method of publication of the annual report
The annual report are published in the following ways:
–
Register of Financial Statements, https://www.registeruz.sk/;
–
the Bank’s website www.vub.sk.
Statement of Responsible Persons
I hereby declare that, to the best of my knowledge, the ﬁnancial statements prepared in accordance with speciﬁc
regulations provide a true and fair view of the assets, liabilities, ﬁnancial position, and ﬁnancial performance of the
Bank and the companies included in the overall consolidation. Furthermore, the annual report provides a true and
fair overview of the development and results of the business activities and position of the Bank and the companies
included in the overall consolidation, along with a description of the main risks and uncertainties they face, and it is
prepared in accordance with the standards for sustainability reporting.
Jozef Kausich
Chief Executive Ofﬁcer
and
Chairman of the Management Board
Darina Kmeťová
Chief Financial Ofﬁcer
and Member of the Management Board
4
ANNUAL REPORT 2025
General information about the Bank
Business name:
Registered office:
Company ID:
Date of establishment:
Founder:
Capital in EUR:
Contact person:
Phone no.:
E-mail:
Website:
Scope of business:
Všeobecná úverová banka, a.s.
Mlynské nivy 1, 829 90 Bratislava
31 320 155
April 1,1992
National Property Fund of the Slovak Republic, Bratislava
EUR 510 819 063.81
Ing. Milan Danči
+421 904 755 502
mdanci@vub.sk
www.vub.sk
bank services, see Annex Scope of business
The branch of the parent company included in the separate ﬁnancial statements:
Business name
Company
reg. no.
Address
Country
Legal form
of entity
Main activity
Všeobecná úverová banka
, a.s.,
Prague Branch
48550019
Purkyňova 2121/3,
110 00 Praha 1
CZ
Branch of the
parent company
abroad
Commercial and investment
banking services in the Czech
Republic
The entities included in the consolidated ﬁnancial statements:
Business name
Companyreg.
number
Address
Share
Consolidation
method
Main activity
Subsidiaries
VUB Operating Leasing, a.s.
54108128
Mlynské nivy 1
820 05 Bratislava
100.00%
Full method
Operating leasing
VUB
Generali dôchodková správcovská spoločnosť, a.s.
35903058
Mlynské nivy 1
820 04 Bratislava
55.26%
Full method
Pension fund administration
Joint ventures
Monilogi s.r.o.
54508673
Mlynské Nivy 1
821 09
Bratislava
33.00%
Net equity method
Cash processing
Associates
Slovak Banking Credit Bureau, s.r.o.
35869810
Mlynské nivy 14
821 09 Bratislava
33.33%
Net equity method
Credit database administration
General information about the Bank
5
General information about the Bank
6
Separate financial statements
prepared in accordance with IFRS
as adopted by the EU
Consolidated financial statements
prepared in accordance with IFRS
as adopted by the EU
€ ’000
2025
2024
2023
2025
2024
2023
Loans and advances to customers
21 828 029
20 458 105
18 471 650
21 827 322
20 455 952
18 464 494
Mortgage loans (gross amount)
10 405 109
9 906 364
9 311 918
10 405 109
9 906 364
9 311 918
Consumer loans (gross amount)
1 552 489
1 507 892
1 605 652
1 552 489
1 507 892
1 605 652
Due to customers (including lease liabilities)
18 089 599
17 168 518
16 039 273
18 089 503
17 167 594
16 038 978
Equity
2 402 157
2 239 271
2 118 416
2 428 880
2 264 507
2 144 524
Balance sheet total
26 253 295
25 196 730
24 326 231
26 320 181
25 254 317
24 386 101
Profit before provisions, impairment and tax
504 904
462 359
404 295
505 332
462 931
411 934
Profit before tax
429 175
422 802
341 620
436 392
426 498
342 480
Income tax expense
(160 599)
(170 871)
(77 426)
(166 271)
(172 941)
(78 735)
Net profit for the year
268 576
251 931
264 194
270 121
253 557
263 745
Commercial indicators
2025
2024
2023
ATMs
556
550
554
EFT POS Terminals
14 875
14 944
14 524
Payment cards
1 072 087
1 041 820
1 015 464
of which credit cards
102 203
99 330
97 770
Number of employees
3 187
3 331
3 312
Number of branches in Slovakia
163
165
167
Key ratios of VUB Group
2025
2024
2023
Return on assets
1.03 %
1.00 %
1.08 %
Cost-Income Ratio
(without bank levy)
37.2 %
39.4 %
39.5 %
Tier 1 capital ratio
20.14 %
17.66 %
17.25 %
Total capital ratio
21.92 %
19.65 %
19.79 %
Rating (status as at 31 December 2025)
Moody’s
Long-term deposits
A2
Short-term deposits
P-1
Baseline credit assessment
baa2
Positive outlook
General information about the Bank
7
The shares issued by VUB
Security name
Shares of VUB, a. s., 1
Total issue amount
EUR 135 393 185.60
Type, form of security
Ordinary registered shares in book-entry form
Number and nominal value per share
4 078 108 shares at EUR 33.20 each
ISIN
SK1110001437
series 01, 02, 03, 04, 05, 06
Share in capital%
26.51%
Admitted/not admitted for trading
Not admitted for trading
Security name
Shares of VUB, a. s., 2
Total issue amount
EUR 295 425 878.21
Type, form of security
Ordinary registered shares in book-entry form
Number and nominal value per share
89 shares at EUR 3 319 391.89 each
ISIN
SK1110003573 series 01
Share in capital%
57.83%
Admitted / not admitted for trading
Not admitted for trading
Security name
Shares of VUB, a.s., 3
Total issue amount
EUR 80 000 000.00
Type, form of security
Ordinary registered shares in book-entry form
Number and nominal value per share
80 shares per EUR 1000 000.00
ISIN
SK1000026403
Share in capital%
15.66%
Admitted / not admitted for trading
Not admitted for trading
Other information
During the accounting year 2025, VUB Group held in its assets the shares of the parent company (Art. 22, Sec. 3 of
the Act no. 431/2002 Coll. on Accounting, as amended) Intesa Sanpaolo S.p.A. (ISP), with its registered ofﬁce at
Piazza San Carlo 156, Turin, Italy, ISIN IT0000072618, in particular book-entered registered ordinary shares, with a
market value of EUR 5 4088 each, in a total number of 110 019 shares. These shares have been acquired by the
Bank in order to adopt and implement ISP Group Remuneration Policies in line with the Capital Directive 'CRD V'
(i.e. Directive 2019/878/EU, amending the Capital Requirements Directives). In 2025, the Bank transferred 59 285
shares in accordance with ISP Group Remuneration Policies.
There is no known information about agreements between the owners of securities that may lead to restrictions on
the transferability of securities and limitations on voting rights.
For the year 2025, the bank records operating costs related to research and development activities in the amount of
approximately EUR 2.0 mil (2024: EUR 2.0 mil).
There were no subsidies from public sources.
Events of special importance according to Article 20(1) letter b) of Act no. 431/2002 Coll. on accounting are
presented in the ﬁnancial statements.
The Bank is not subject to the special regulations in accordance with Article 20(1) letter g) of Act no. 431/2002 Coll.
on Accounting.
8
Address by the Chairman of the VUB Supervisory
Board
Dear Shareholder, Clients and Business Partners, Employees,
The year 2025 was a very successful one for VUB. In the commercial area, it achieved growth in deposit and loan
volumes despite the uncertain macroeconomic situation. Importantly, VUB's business growth was accompanied by
a continued prudent approach to risk and further improvements in operational efﬁciency. V
UB's cost-to-income ratio
is 37.2%, enabling the group to achieve satisfactory results in the ﬁnancial area, both in terms of operating proﬁt
and net proﬁt.
Beyond commercial and ﬁnancial performance, I would also like to highlight V
UB’s results in the area of ESG.
Sustainability has truly become an integral part of the Bank’s operations. VU
B not only signiﬁcantly increased its
sustainable ﬁnance targets year
-on-year, but also exceeded its
ambitions through the continued expansion of its sustainable and
social solutions offering. These efforts were further supported by the
ongoing issuance of social and sustainable bonds by the parent
company, Intesa Sanpaolo, enabling VUB to offer more favourable
conditions to its clients. In 2025, VUB also maintained its leading
position in the sale of ESG funds.
VUB’s outstanding performance was recognised through several
prestigious awards. Global Finance magazine once again named VUB
the Best Bank in Slovakia, marking the ﬁfth consecutive year of this
recognition. VUB also received the Global Finance Sustainable Finance
Award for the third time. The prestigious Euromoney magazine
awarded VUB its Award for Excellence as the Best Bank in Slovakia. At
the domestic level, VUB was named Bank of the Year 2025 by the
weekly Trend. These awards underline VUB’s leading position in the
Slovak market from both quantitative and qualitative perspectives, as
well as in terms of sustainability. On behalf of the Supervisory Board, I
would like to express our sincere appreciation to the Bank’s
management and employees for these exceptional achievements.
Looking ahead to 2026, it is clear that the environment in which the
Bank operates remains highly challenging and will require an even
greater degree of prudence than in previous years. Continued slow
economic growth in the euro area, persistent geopolitical uncertainty,
and the ongoing tightening of ﬁscal policy in Slovakia will continue to weigh on the conﬁdence of households and
businesses alike. At the same time, I believe that this combination of external pressures will further highlight the
importance of a strong capital position, sound risk management, and the Bank’s ability to provide long-term, stable
ﬁnancing to its clients. The year 2026 will therefore not only be about managing challenges, but also about the
ability to seize new opportunities and strengthen the Bank’s role as a trusted partner during a period of heightened
economic volatility.
In conclusion, I would like to reafﬁrm the continued support of our parent company, Intesa Sanpaolo, for V
UB in all
respects. I remain conﬁdent that,
with the ongoing trust of our clients and business partners, VUB will continue to
deliver stable results and remain a key pillar of stability and support for the Slovak economy and society as a whole.
Massimo Enrico Proverbio
Chairman of the VUB Supervisory Board
9
Address by the Chairman
of the VUB Management Board
Dear shareholder, clients and business partners,
In a complex macroeconomic environment marked by a high degree of uncertainty and ongoing changes in the
domestic business environment, stability was our primary goal. I am pleased to say that we achieved this while also
recording
signiﬁcant
growth
in terms of volume, revenue and proﬁtability. I therefore consider 2025 to be a
successful year. At the same time, it was a year that brought one signiﬁcant change to our brand: a new visual
identity.
I will begin my assessment with a brief analysis of the macroeconomic environment. Slovakia's economic
development was uneven during 2025. The beginning of the year was marked by a high degree of external
uncertainty driven by
the threat of a tariff war by the new U.S. administration, as well as uncertainty arising, for
example, from the introduction of a new ﬁnancial transaction tax. Although sentiment improved slightly in the
second half of the year, overall economic growth remained relatively weak. GDP growth for the year as a whole is
unlikely to have exceeded 1%, which is signiﬁcantly l
ower than in 2024 and also represents a noticeably weaker
performance compared with neighbouring countries.
A key domestic problem was the increase in the tax burden on households and rising prices, mainly as a result of
higher VAT. Inﬂation rose again to 4%, leading to a weakening of real
incomes and households' ability to save. In addition, the labour market
cooled noticeably during the year, with employment falling and
unemployment rising across several sectors of the economy. This
further undermined consumer conﬁdence and
spending.
Despite these unfavourable macroeconomic fundamentals, the
banking sector demonstrated a high degree of resilience. The
mortgage market recovered fully thanks to falling interest rates, and
corporate lending also resumed growth in the second half of the year.
However, deposits in the banking sector grew more slowly than loans,
further exacerbating the already tense liquidity situation in the market.
In addition, part of households' free resources was absorbed by a
completely new government issue of so-called bonds for the people.
The sector's proﬁtability remained positive, although the pace of net
proﬁt growth gradually slowed compared to the previous year.
The challenging business and competitive environment was reﬂected
in VUB's commercial results. In the important mortgage market, we
managed to increase volumes by 5.3% year-on-year, only slightly
belowthe previous year´s growth of 6.4%. As a result, our market
share reached 21.6%.
We also grew year-on-year in consumer loans, albeit more slowly than in the previous year, by 3.7% compared to
5.5% in December 2024. VUB's market share here reached 21.2%.
In the segment of sole traders and small businesses, I am pleased to report that, following stagnation in lending in
the previous year, we managed to boost volumes again in 2025 and strengthen our position by a strong 8.6%. Our
share of all loans provided to sole traders in Slovakia thus represented an impressive 36.2%.
Overall, we grew by 5.1% year-on-year in theretail loans segment, with our share reaching 20.8%.
As regards corporate loans, volume growth was signiﬁcantly affected by companies' reduced appetite for investment
amid growing uncertainty and the slowing economy. The total volume provided by our VUB Group to the corporate
sector decreased by 1% year-on-year. The decline was driven primarily by large multinational companies that were
reassessing their involvement in the Slovak economy, including the footwear, textile, and automotive industries. Our
overall position in the Slovak corporate loan market declined to 19.7% after last year's improvement, which
effectively returning to the 2023 level. However, it should be noted that the VUB Group is also active in the Czech
corporate market, where we recorded signiﬁcant loan growth of 6.5% year
-on-year. This presence allows us, to
some extent, to pursue sources of growth beyond Slovakia's borders.
It is important to note that despite the complex macroeconomic circumstances facing companies in Slovakia, we
managed to overcome stagnation in the small and medium-sized enterprise (SME) sector, increasing the volume of
lending to these companies by 1.4% in 2025. We also support our SME clients in ways other than bank loans, such
as,
using leasing and factoring services. In the area of ﬁnancial leasing, we maintained the volume of ﬁnancing
for
Address of the Chairman of VUB Management Board
10
vehicles up to 3.5 tonnes at the previous year's level in 2025, despite a weaker start due to legislative changes.
Overall, we achieved
total ﬁnancial leasing
volume of EUR 157.3 million
with growth in key segments including
machinery and industrial equipment and ofﬁce equipment. In operational leasing, we focused primarily on stabilising
and renewing our portfolio, directing new contracts to our partner company. VUB has long been one of the largest
companies in the factoring sector. It conﬁrmed its dom
inant position again in 2025, recording a 13% year-on-year
increase in assigned receivables. VUB holds a market share of approximately 30% among banks and factoring
companies within the Association of Factoring Companies.
Turning to the other side of the balance sheet, deposits, I am pleased to report that we have managed exceeded
our expectations. The year-on-year increase in primary deposits reached 5.3%, which was double the growth rate
of
gross loans. This development has signiﬁcantly simpliﬁed our liquidity management, which has been marked by a
structurally higher volume of loans than deposits – not only within our Group but in the entire banking sector over
the past decade. In this context, I would like to appreciate the efforts and continued success of our treasury team in
ﬁnancing the
Group beyond the domestic market, particularly through the issuance of covered bonds. Indeed, VUB
succesfully issued another covered bond worth EUR 500 million with a seven-year maturity.. This was the longest
covered bond issue in the Central and Eastern European region in 2025. VUB remains the largest issuer of covered
bonds among banks in Central and Eastern Europe, supported by
a strong and diversiﬁed investor base.
We managed to increase the volume of household deposits by 4.7% and maintain our share of this important market
at 17.2%. I would argue that this representsa solid result, given the declining household savings rate and intense
competition for these savings –
not only from other banks and management companies, but also, for the ﬁrst time,
from the state, which began competing for household funds in 2025 through so-called bonds for the people.
We also managed to increase the volume of corporate deposits by 7%. However, it must be acknowledged that this
strong growth was driven primarily by increases in deposits at our Czech subsidiary, VUB Praha. On the domestic
Slovak market, we only managed to increase corporate client deposits in the SME segment. Our share of total
corporate deposits in Slovakia reached 20.7%.
Before moving on to the ﬁnancial results, I would also like to
review the commercial performance of the VUB Group
in the mutual fund and pension markets in which we operate. Both markets had a very strong year, thanks to
constructive conditions in the ﬁnancial markets
and, importantly, to growth in the number of clients and their new
assets under management. In mutual fund asset management, we collaborate with Eurizon Capital (‘Eurizon‘), a
leading European management company within the Intesa Sanpaolo Group. During 2025, we continued to focus
on expanding our product portfolio of local and Luxembourg funds to cover the full range of investment strategies
suitable for our clients. Total net inﬂows of new investments exceeded EUR 300 million. Assets under management
reached EUR 3.5 billion and our client base grew to 207 000 clients up from 185 000 a year ago. In 2025, we
continued to focus on ESG issues and supported investment savings programmes as a key factor in building a long-
term capital base in ﬁnancial markets.
Our market shareincreased
year-on-year to 22.2%, once
again conﬁrming
Eurizon's leading position among management companies on the Slovak market.
VUB also operates in the pension market through VUB Generali, our joint venture with Generali Slovensko, in which
we hold a majority stake of 55.26%. In 2025, VUB Generali accumulated a total volume of assets under management
of EUR 3.94 billion, representing growth of almost 15%. The company's market share thus increased by 0.34
percentage points, reaching 20.49%. We also continued to grow our client base very successfully. The number of
clients in our pension savings systems increased by more than 28 000, reaching a total of almost 423 000 clients by
the end of 2025, securing third place in the market in terms of client numbers. VUB Generali was also the leader in
pension fund performance and managed the most proﬁtable index fund in the entire second pension pillar sector,
conﬁrming our commitment and ability to deliver the highest possible returns on our clients' savings.
In terms of ﬁnancial results, I am pleased to report year
-on-year improvements in all key indicators. The Group's
operating income increased by 5.4% to EUR 805.3 million. All three main income categories recorded positive
growth. Net interest income rose by 2.6%, mainly driven by growth in interest-bearing assets, while net fee and
commission income grew by a signiﬁcant 14.7% thanks to growth in assets under management, current accounts,
loans and payment card fees. Trading also made a positive contribution, with net income from these activities
increasing by 15.4% year-on-year. We managed to keep operating costs at EUR 300 million. As a result, our cost-
to-
income ratio on a consolidated basis thus improved further, to 37.2%. The net ﬁnancial result was helped by the
planned reduction in the special banking tax and, conversely, worsened by the increase in loan loss provisions – a
prudent decision in response to the economic slowdown. After adjustments for provisions, reserves and taxes, the
G
roup reported a net proﬁt of EUR 270.1 million compared to EUR 253.6 million in 2024, an increase of 6.5%.
When
reﬂecting
about the successes of 2025, I would also like to highlight the results of the work of our VUB
Foundation. Its DNA, based on supporting art and cultural heritage, has been deﬁned for the second
consecutive
year running by a strategic partnership with the Gothic Route civic association. As part of this partnership, we have
committed to donating a total of EUR 500
000 over ﬁve years to restore medieval monuments in the Gemer and
Address of the Chairman of VUB Management Board
11
Malohont regions. In 2025, we added another EUR 100 000 euros from our foundation and more than 30 000 euros
from our own art auction. As part of our partnership with the Gothic Route civic association, we celebratedthe
opening of another restored sacral building in 2025, this time in the village of Rákoš.
The 20th edition of the Maľba
– VUB Foundation Award competition for young artists was also a special chapter for
us in 2025. Over two decades, Maľba has become a respected event and an integral part of the development of the
artistic and cultural environment in Slovakia. Throughout its history, it has given emerging young painters a chance
to shine. The international jury has recognised a total of 51 talented artists to date and has supported them with a
total of EUR 430 000.
Thanks to the resources provided by our VUB Foundation, we were involved in 141 projects in 2025, which received
EUR 1.6 million in total support. We continued to strengthen and expand partnerships and grant assistance in our
long-term domains. A total of 22 projects were dedicated to nature and environmental protection. In the area of
arts and cultural heritage preservation, we devoted our resourc
es to 9 projects. We also made a signiﬁcant impact
in the charitable and social assistance, where our grants contributed to 50 projects. Last but not least, we also
supported 60 additional initiatives aimed at community development, education and leisure activities for children.
A special event for us was the presentation of an exceptional gift to the Clinic of Paediatric Neurology of the Faculty
of Medicine of Comenius University and the National Institute of Child Health. Thanks to our grant, children with
neuromotor disorders in Slovakia received, a unique device that improves treatment prospects. This, along with all
the other stories we have supported, shows us that our mission to improve people's lives and to promote and
preserve cultural and natural values is very meaningful. Encouraged by these results and feedback received, we are
committed to continue this work persistently.
Let me now turn to the outlook for 2026. I expect the banking environment to remain very challenging. Economic
growth is likely to remain fragile. The economy should stay out of recession, but below its potential. Domestic
demand will remain subdued due to ongoing ﬁscal consolidation and cautious behaviour
by households and
businesses, which will be reﬂected in moderate growth in credit demand. The external environment will remain
challenging, primarily due to ongoing tensions in global trade, which will continue to affect export-oriented sectors
that form the backbone of the Slovak economy.
We see potential for more favourable developments primarily through a faster drawdown of European Union funds
and a possible revival of demand from major trading partners in the euro area, which could support investment
activity and improve
the quality of the loan portfolio. On the other hand, the risks remain signiﬁcant, particularly the
possibility of a deeper slowdown in the external environment, a deterioration in public sector ﬁnancing conditions
in the event of non-
compliance with ﬁs
cal targets, and the continuing fragility of private investment.
In this context, it will be crucial for the bank to maintain a prudent approach to risk management, ensure an
adequate capital and liquidity position, and focus on sustainable growth that is consistent with the macroeconomic
environment and long-
term ﬁnancial stability.
Finally, I would like to thank all employees for their commitment over the past year. I would also like to thank our
clients and business partners for the trust they have placed in the bank, and our parent company Intesa Sanpaolo
for its continued support. I wish everyone a successful 2026.
Jozef Kausich
CEO and Chairman of the VUB Management Board
12
VUB Management Board Report on the Business
Activities of the Company
Changes in the External Environment
External Environment
In 2025, major central banks confirmed a turnaround in the monetary policy as inflation in both the U.S. and the
Eurozone continued to decline towards target. Inflation in the Eurozone was just above 2%, in the US at 2.7%,
which allowed for further rate cuts – in the Eurozone to 2%, in the US to 3.75% and in the Czech Republic to 3.5%.
Although rates in the U.S. remained above neutral, global financial conditions eased.
The world economy grew by around 3.3% in 2025, similar to the previous year, despite the negative impact of U.S.
trade policy. The U.S. maintained growth at around 2.1%, the Eurozone at around 1.4%. Financial markets reacted
positively to the policy easing – stock indices grew by double digits and bonds benefited from stabilising yields. The
strongest asset was gold, which rose sharply due to geopolitical uncertainty and fiscal risks in the U.S.
Despite tensions in international trade and ongoing conflicts, global recession scenarios did not materialize. At the
turn of 2025/2026, the IMF raised its global growth forecasts back to their original levels.
The Slovak economy grew only moderately in 2025, by approximately 0.8%. Development was dampened by the
consolidation of public ﬁnances, the U
.S. trade war, strong competition from China and weaker real household
incomes. Domestic consumption remain subdued, while investments was low due to increased uncertainty. The
labour market remained tight, but wage growth gradually slowed and unemployment began to increase from
historical lows. Inﬂation moved up towards 4%
driven by tax changes and increasing prices of services. Household
savings remained low and bank deposits were also affected by absorption of new retail government bonds in the
amount of EUR 500 million.
Budget consolidation and weaker growth did not bring a signiﬁcant reduction in the deﬁcit
– the shortfall probably
reached around 5% of GDP. Nevertheless, the risk premium of Slovak government bonds fell to 70 basis points and
rating agencies conﬁrmed the Slovak Republic's ratings.
Financial Sector
The decline in both short-term and long-term rates was reflected in credit conditions in 2025. New mortgage rates
fell closer to the euro area average, below 3.5%from the peak of 4.6% in 2024, which significantly revived
household demand. Housing loans grew by 7.4% year-on-year, consumer loans by 7.2%. Strong credit demand
was also reflected in a sharp increase in real estate prices – by approximately 12% according to the National bank
of Slovakia.
Corporate loans grew slower (5.5%), while investment loans virtually stagnated. Household deposit growth (6.2%)
slowed closer to the level of nominal economic growth, partly also due to the retail government bonds. For
companies, deposit growth was dampened by stagnant profitability.
The (gross) loan-to-deposit ratio (LTD) increased from 107.3% to 108.6%, forcing banks to rely more on market
ﬁnancing
, mainly through covered bonds. Banks' net interest income increased by 6.9% and total operating
revenues by 4.9%, but costs grew almost as fast. Provisioning nearly tripled, although the share of non-performing
loans remained low (2.0%). The bank levy became a slightly smaller burden after the rate was reduced to 25%, but
the sector as a whole saw a modest decrease
in net proﬁtability (
-1.9%).
Outlook for 2026
A more stable global environment is expected, and the world economy is expected to continue growing moderately
at around 3.1%. Inflation is expected to remain low – below 2% in the Eurozone, slightly higher at around 2.8% in
the US. The ECB is unlikely to cut rates any further, but the Fed could continue its gradual easing after the nomination
of a new chairman in May, with a possible drop in the key rate to a range of 3.0–3.25%.
Eurozone growth is expected to slow slightly (1.1%), while in the U.S. it will remain at around 2.1%. Financial
markets will operate in an environment of stabilizing inflation and lower rates, but with persistent geopolitical, fiscal
and political risks that may rather slightly widen risk premiums.
The Slovak economy is expected to accelerate to around 1.3% in 2026, with growth supported by the completion
of the Recovery Plan and the growth recovery in Germany. Real wages will increase only slightly, the household
VUB Management Board Report on the Business Activities of the Company
13
savings rate could remain low, and slightly higher unemployment rate, together with ongoing ﬁscal consolidation,
will reduce household disposable income compared to 2025.
Real GDP growth in y/y and q/q terms
Source: Eurostat, VUB
3M Euribor and ECB's Reﬁ Rate
Source: Bloomberg, VUB
VUB Management Board Report on the Business Activities of the Company
14
Employment: number of workers in thousands
Source: SO SR, Macrobond, VUB
Development of bank volumes (EUR bn)
Source: NBS, VUB
VUB Management Board Report on the Business Activities of the Company
15
Slovak government's 10Y bond yield, generic index
Source: Bloomberg, VUB
VUB’s 2025 commercial performance
The beginning of 2025 was marked by heightened uncertainty stemming from potential U.S. trade tariffs and newly
introduced domestic taxes. Although conditions improved slightly later in the year, overall economic activity
remained subdued, with GDP growth projected to stay below 1%.
Higher taxation and sustained price pressures lifted inﬂation to around 4%, eroding households’ real incomes.
Labour
-
market conditions softened as employment declined and unemployment rose, weighing on consumer
sentiment and moderating spending.
Despite challenging macroeconomic environment VUB has not only achieved a very satisfactory performance in the
commercial area, but also has laid a great emphasis on sustainability, environmental and social responsibility.
Throughout the year, the interest rates have been relatively stable. In retail lending, we managed to keep our market
share on very satisfactory level (20.84%). Also, in corporate lending, our market position remained high at 19.72%
in December 2025. As far as deposits are concerned, our initiatives to strengthen the deposit base for further growth
were successful in retail segment (including Eurizon funds), where we managed to keep stable market position over
the year.
Deposits
The volume of bank deposits in VUB amounted to almost EUR 18.1 billion at the end of 2025, 5.4% up against the
previous year due to both retail and corporate deposits. In the retail market, we managed to increase the amount
of deposits this year, both current accounts and term deposits. Customers’ assets under management beneﬁted
from both net sales and market value development and posted substantial year-over-year increase of 16.4%,
signiﬁcantly
above the market increase (7.7%). Market share in mutual funds thus increased by 47 bps in 2025. The
market share of total deposits received from clients incl. mutual funds amounted to 19.2%. In the corporate
segment, VUB recorded signiﬁcant year
-over-year growth, although still below the whole market, which resulted
into decrease in the market share by 146 bps.
Electronic Banking
Throughout 2025, VUB Bank focused on the implementation of a new solution for internet and mobile banking. By
the end of the year, more than 600 000 clients had been successfully migrated to the new platforms. At the same
time, we introduced a range of improvements and innovations driven by client satisfaction, user feedback, and
emerging market trends, including biometric online onboarding.
VUB Management Board Report on the Business Activities of the Company
16
Bank Cards
In 2025, card payments accounted for 58.5% of the total card transaction volume. Compared to 2024, card
payments increased year over year by 6% in number of transactions and by 7.5% in volume. Cash withdrawal
transactions continued to decline, with the number of withdrawals decreasing by 9% and the volume by 3%
compared to 2024.
VUB clients continued using electronic wallets (such as Apple Pay and Google Pay) for card payments in 2025. During
the year, we introduced new payment methods using wearables, including rings and bracelets. In 2025, 33.7% of
all card payments were made through electronic wallets, representing a 28.3% share of transaction volume. Two
out of three mobile payments were executed using Apple Pay.
In 2025, we also continued our support for the Dobrý Anjel (Good Angel) charity through our co-branded Mastercard
Good Angel card. By the end of the year, almost 75 000 of these cards had been issued. The total amount of support
provided in 2025 via POS transactions made with Good Angel cards amounted to EUR 350 000.
ATMs and EFT POS
With 556 ATMs, VUB held 2
nd
place on the market in terms of ATM presence in 2025 as well. The cash volume
withdrawn from ATMs decreased year over year by 8% (while the number of transactions decreased by 7%). This is
a consequence of clients’ long-term preference for making purchases by card rather than using physical cash.
In 2025, we focused on expanding the network of ATMs with cash deposit functionality. By the end of the year, we
had 148 such ATMs in operation, representing a year-over-year increase of 4 units. The number of ATM cash deposit
transactions increased by more than 4%. Throughout the year, almost 77% of all clients’ cash deposit transactions
were carried out via ATMs.
Before the end of the year, we began replacing of 60 obsolete ATMs. These new ATMs support visually impaired
clients through a special software application that provides audio guidance throughout the transaction process.
In 2025, we installed nearly 1 800 new POS terminals, including self-service terminals for parking and gas stations,
as well as payment gateways for e shops. In September 2025, we launched a new product – a POS terminal in a
mobile phone or tablet (softpos). This product is suitable for small business clients, such as those with seasonal
payments, food trucks, or newly established companies. We have installed approximately 400 new POS terminals on
mobile phones.
Digital Branch 2024
Throughout 2025, our focus was the migration of clients to the new VUB Online Banking application, which
signiﬁcantly inﬂuenced our operational results.
During the year, we handled 656 000 incoming calls, representing a 22% increase compared to 2024. The volume
of emails also rose by 7%, reaching 145 000. On the other hand, we recorded a slight decline in chat interactions
and outbound calls, primarily because our resources were redirected toward managing the growing number of
incoming requests. To ensure we could assist as many clients as possible, we also utilized the services of an external
call center.
2025 was a demanding year, as change naturally brings challenges, which was also reﬂected in client reactions.
Nevertheless, our aim throughout the entire period was to remain fully available for our clients and support them to
the best of our abilities.
Despite these challenges, we succeeded in improving our sales performance and exceeded the results achieved in
2024. As in previous years, our campaign and outbound activities continued to focus mainly on Digital Lovers client
segments. Outcoming calls we also directed maily toward Digital lovers clients, as in previous year.
Loans
Individuals – Mortgage and Consumer Loans
In 2025, VUB recorded substantial demand for mortgage loans, which resulted into growth of mortgages by over
5.3% year-over-year. Thanks to these efforts, VUB maintaned strong market position at 21.6%. In terms of
Consumer Loans, VUB recorded signiﬁcant increase over the year, yet below the market growth. Thus, our market
position has decreased slightly to still sound at 21.5%.
VUB Management Board Report on the Business Activities of the Company
17
Corporate Financing
VUB bank was outperformed by the rest of the market in the corporate loans segment. While the volume of
corporate loans in the market increased by 6.4%, in the case of VUB it increased by 3.1% at the bank level (without
the Prague Branch). Thus, VUB’s market share in these loans went down to 19.7%.
Real estate ﬁnancing deteriorated, while the volume of project and trade ﬁnancing loans increased substantially.
Leasing, previously a subsidiary of VUB Leasing, recorded slight decrease of 3%.
Review of VUB’s Economic and Financial Position
The year 2025 began with high uncertainty due to potential U.S. trade tariffs and new domestic taxes. Despite a
slight improvement later, growth remained weak, with GDP likely below 1%.
Higher taxes and rising prices pushed inﬂation to about 4%, reducing real incomes and savings. The labour market
cooled as employment fell and unemployment rose, weakening consumer conﬁdence and spending.
However, even in this challenging environment, VUB generated operating revenues of EUR 805.3 million on
consolidated basis. Compared to the previous year, the results improved by over 5% mainly due to great
performance in terms of fee-based business, mainly our customer proposition in terms of wealth management, but
also due to year-over-year increase of interest income. Operating costs have decreased marginally reaching the
amount of EUR 299.9 million at the end of 2025.
VUB Group recorded operating proﬁt of
EUR
505.3 million and kept its proﬁt before tax on the more than satisfactory
level of EUR
436.4 million, which represent an increase by 2.3%. Net proﬁt of the Group, also, has increased by
6.5% and reached EUR 270.1 million. Cost-income ratio of VUB Group amounted to 37.25%, representing an
improvement compared to last year.
Regarding business development, VUB delivered a very good strong performance in its net loan portfolio, which
grew by 6.7%, resulting in a strong market share exceeding 20%. Total assets of the whole VUB Group increased
by 4.2% and reached the level of EUR 26.32 billion.
Our portfolio quality remained strong and NPL ratio remained at very prudent levels. In addition, VUB also
outperformed the market in terms of loan quality, when non-performing loans from banking operations at the
Group level reached only 1.84% of the total gross volume of loans in VUB at the end of 2025, compared to the
market level of 2.0% (market data is based on individual statements from NBS).
At the same time, the bank was able to increase its primary deposits by 5.4%, while keeping a sound liquidity
position which is represented by the rather prudent loan-to-deposit ratio (including debt securities in issue) of 98.9%.
Information on the Expected Economic and Financial Situation for 2026
Looking ahead to 2026, the operating environment for the banking sector is expected to remain demanding.
Economic growth will likely stay fragile—avoiding recession, while continuing below its potential. Domestic demand
is set to remain subdued, reﬂecting ongoing ﬁscal consolidation and cautious behaviour of households and
businesses, which will translate into moderate loan demand. External conditions will also remain challenging, as
persistent global trade tensions continue to weigh on export
-
oriented industries that are central to the Slovak
economy.
Our long
-
term strategic vision at VUB Bank remains unchanged: to be a modern, agile leader in the banking sector
and a pioneer of sustainability within the industry. We aim to deliver efﬁcient, customer
-
centric ﬁnancial advisory
and services across diversiﬁed channels, while strengthening our leading position in the advisory domain.
VUB Management Board Report on the Business Activities of the Company
18
To unlock a step
-
change in performance, we will further promote an innovation
-
driven mindset across the
organisation, embed structured change
-
management practices into our culture, and ensure dual
-
track IT delivery.
This includes both the development of local IT capabilities through convergence initiatives and the successful
implementation of Group
-
driven projects. In the area of customer experience, we will continue to focus on service
improvements and the rollout of an omnichannel approach, supported by network optimisation and channel
expansion.
We will continue enhancing value creation in corporate banking through product and process innovation and
through a disciplined repricing strategy, with the ambition to outperform the market, particularly in segments with
strong growth potential.
Continuously optimize the bank's liquidity structure and funding sources into a sustainable proﬁle, prioritizing cost
-
efﬁcient funding
—especially for any asset growth—and effective risk/return through strategic asset allocation.
Finally, as a responsible corporate citizen, VUB Bank will continue to generate value beyond its core business. We
remain committed to supporting our employees in their community engagement and environmental initiatives, while
advancing meaningful projects through the VUB Foundation and our ‘Green Bank‘ activities, including the ATLAS
environmental award and programmes promoting ﬁnancial and environmental education among young people.
19
Corporate Governance Statement
The Bank manages the company in compliance with all the principles of the Corporate Governance Code in Slovakia
(hereinafter referred to as the ‘Code’).
The Management Board and the Supervisory Board undertook to enhance corporate governance and adopted the
Corporate Governance Code in Slovakia within the following speciﬁc scope:
–
Company organisation – Rules of Functioning of VUB, a.s., Rules of Competence of VUB, a.s., Rules of Signing
in VUB, a.s.
–
Relationship between the company and its
shareholder – Statutes of VUB, a.s.
–
Company’s approach to shareholders – Statues of VUB, a.s.
–
Disclosure of information and transparency
–
Audit Committee, Remuneration Committee, Nomination Committee and Risk and Sustainability Committee
The aim of the Bank’s managing bodies is to take measures in order to ensure full implementation of the Code
principles.
The Corporate Governance Code in Slovakia is available on the website of the Slovak Association of Corporate
Governance – SACG) (Central European Corporate Governance Association – CECGA), https://sacg.sk/
Methods of Management
The Bank’s management system and methods are governed by the Rules of the Intesa Sanpaolo Group, unless they
are contrary to the legal regulations and provisions of the Articles of Association of the Bank. These rules deﬁne the
procedures and methods of application of the instructions issued by the Intesa Sanpaolo Group in connection with
the performance, management and coordination of Intesa Sanpaolo Group’s activities.
The structure of the Bank’s executive management is managed by the Management Board as the statutory body of
the Bank, through the Chief Executive Ofﬁcer, Deputy Chief Executive Ofﬁcer, and Heads of Divisions who are
directly accountable to the Management Board.
To maintain a clear separation of risk management from other banking functions, the Bank has created independent
units dedicated mainly to market and credit risk management.
Activities related to the execution of investment transactions are separate from activities related to the execution of
credit transactions. The organisational structure identiﬁes the units that carry out investment transactions as well as
those that carry out credit transactions. The organisational units that carry out investment transactions are not
allowed to carry out credit transactions and vice versa. The scope of activities of these units is
deﬁned in detail in the
Company's internal regulations.
The monitoring of risks during the performance of banking activities for persons with a special relationship to the
Bank is ensured by an autonomous unit which is separate from the banking activities unit.
Protection against money laundering falls within the competence of the Management Board, which performs this
task through an autonomous Bank unit.
To ensure a functional information system, the Bank uses the support of the autonomous Information Technology
and Operations Division, thus creating the conditions for a fast and secure information system of the Bank.
Corporate Governance Statement
20
The Internal Control System
The Bank’s internal control system consists of three integral levels:
The statutory level is ensured by means of:
The Supervisory Board
–
As the main control body of the Bank. The advisory body of the Supervisory Board is the Audit Committee whose
competences are deﬁned in the Audit Committee Charter and, in the ﬁnancial reporting area, are as follows:
–
To review the most important accounting issues, also in relation to complex and/or extraordinary operations;
–
T
o analyse the annual ﬁnancial statements and quarterly ﬁnancial reports;
–
To oversee that the establishment of accounting policies by the Bank is in line with the ISP Group standards;
–
T
o monitor the ﬁnancial reporting process and submit recommendations or proposal to ensure its reliability and
integrity;
–
To monitor the adequacy and functionality of the administrative-accounting system (including the related IT
systems) as well as its reliability in correctly representing the management facts;
–
To monitor the effectiveness of the internal quality control, risk management system and internal audit regarding
the ﬁnancial reporting;
–
To examine the periodic reports on the administrative-
ﬁnancial governance activities carried out by the
Financial
Statements & Regulatory Reporting Ofﬁce, the ﬂaws of the accounting processes and the status of the related
corrective actions;
–
To examine the periodic reporting on the results achieved in the application of the criteria and procedures aimed
at the classiﬁcation, assessment and management of impaired loans and to assess the need to deﬁne measures
to improve such criteria and procedures.
The Management Board
–
The main executive body of the Bank, responsible for the set-up, monitoring and implementation of an
appropriate and effective system of internal controls and internal regulations, principles and procedures, as well
as for compliance with external requirements.
The executive level is ensured by the managing staff in line with the Rules of Functioning of VUB, a.s. This level
consists of two levels:
–
Chief Executive Ofﬁcer, Deputy Chief Executive Ofﬁcer, Heads of Divisions
– within the business, support and
control units in line with the Bank’s Rules of Functioning;
–
Managing Directors – each manager is responsible for adherence to the internal and generally binding legal
regulations, guidelines, principles and procedures applied in the Bank.
The control level is ensured by the appointed independent Internal Audit Department of the Bank.
Corporate Governance Statement
21
Risk Management
The objective of the company is to bring its risks in compliance with the limits set by the regulatory authority, the
parent company and as determined internally. The credit risk is measured by means of interest gaps and interest
sensitivity for each currency. The purpose of the hedging derivatives is to reduce interest rate exposure to a level that
adheres to the set limits. The company carries out both micro- and macro-hedging transactions.
The purpose of the Bank’s risk management principles is to identify and analyse existing risks, set the respective risk
limits, and monitor risks and compliance with the limits. Along with the risk management systems, these principles
are described in the following documents: Risk Management Strategy, in particular risk management charters, and
Guideline for the Internal Capital Adequacy Assessment System and individual policies and relevant risk management
charters describing risk management and measurement in VUB Bank (Credit Risk, Market Risk, Operational Risk
Charter, Liquidity Policy, etc.).
The use of ﬁnancial instruments suggests the Bank’s exposure to the following risks:
Credit risk
The credit risk represents the risk that the client or the counterparty of a ﬁnancial instrument fails to comply with its
contractual obligations, resulting in the risk of ﬁnancial losses for the Bank. The credit risk arises mainly from loans
provided to
clients, receivables from banks and ﬁnancial investments. The Bank considers the current credit risk
related to ﬁnancial derivatives considerably lower than the exposure calculated according to loan equivalents. The
credit risk arising from trading in securities is managed separately but is reported as part of exposure to the market
risk. (
See more in
’
Consolidate ﬁnancial statements
’
Chapter ’
4.1. Credit risk
’
.)
Market risk
Market risk is the risk of change in market prices arising, for example, from interest rates, stock prices, exchange
rates and the impacts of such change on the Bank’s revenues and/or on the value of the ﬁnancial instruments held
by the Bank. Value-at-Risk (’VaR’) is the main instrument used for the measurement and control of exposure to
market risk under the Bank’s business portfolio. (
See more in
’
Consolidate ﬁnancial statements
’
Chapter ’
4.2. Market
risk
’
.)
Operational risk
The deﬁnition of operational risk according to Basel II excludes strategic and reputational risk, however, it includes
legal risk. Legal risk means the risk of losses resulting from the breach of laws and legal regulations, contractual
obligations or obligations outside contractual terms and conditions, or from other disputes. The internal model of
Intesa Sanpaolo Bank combines all principal quantitative (data on losses from previous periods) and qualitative
information sources (scenario analysis). The Bank uses the traditional model for the transfer of operational risks
(insurance) with the aim to mitigate the impacts of any unexpected losses. (
See more in
’
Consolidate ﬁnancial
statements
’
Chapter
’
4.4. Operational risk
’
.)
Liquidity risk
Liquidity risk indicates the amount of funds that will have to be obtained to meet the obligations related to ﬁnancial
instruments. The Bank complies with the set amount in accordance with the measures of the National Bank of
Slovakia. All principles and procedures related to liquidity are subject to assessment and approval by ALCO and the
parent company. The key indicators the Bank uses in the management of medium-term and long-term liquidity are
based on the rules deﬁned in the laws and the applicable E
uropean and local regulations that the Bank is required
to adhere to (Single Rule Book). (
See more in
’
Consolidate ﬁnancial statements
’
chapter
’
4.3. Liquidity risk
’
.)
The risk management system consists of the following parts:
–
Supervisory Board
as the shareholders’ representative. The Supervisory Board is the principal control body that
supervises the Management Board and the performance of the Group’s business activities.
–
Management Board
which, as a statutory body, sets the executive management of the VUB Group. It is also
responsible for the creation of sound business practices and strategic plans, which implies collective
understanding of the nature of the business environment and related risks.
The members of the Management Board have sufﬁcient knowledge of the areas in which the Bank carries out its
activities and for which they are not necessarily responsible. All members of the Bank’s Management Board are
expected to have practical experience
in the ﬁeld of ﬁnancial markets or sufﬁcient professional experience in the
banking sector, acquired from their previous business/working activities.
The Management Board deﬁnes the structure of the VUB Group
’s executive management.
Corporate Governance Statement
22
The executive function consists of all managerial staff within the Group, whereas each manager is responsible for
compliance with the internal and external guidelines, policies, procedures and laws governing the operations of
banks and/or the Group.
The most important managing committees of the Bank that supervise risks are:
–
Credit Risk Governance Committee
–
Assets and Liabilities Management Committee
–
Operational Risk Committee
–
Internal Control Coordination Committee
–
Credit Committee
–
Problem Assets Committee
–
ESG Committee
–
Change Management Committee.
The Bank established a hierarchy of documents that deﬁne risk management. The Bank's Management Board
approves the Risk Management Strategy. In line with this basic document, the Management Board prepared
statutory documents, which describe the principles and procedures applied to individual risks, including the
managing bodies to which the implementation and enforcement of these principles and procedures are delegated.
Each division, when created, deﬁnes a series of procedures that describe in detail the
process of implementation of
functional tasks.
The Management Board has deﬁned a management strategy covering all basic types of risks that the Bank faces in
its operations.
Risk management, which is separate from banking activities, is ensured within the Bank’s organisational structure
through the creation of independent units focused mainly on the area of credit, market and operational risk
management, with the following responsibilities:
–
I
ndependent deﬁnition and implementation of standards and criteria concerning credit transactions, investment
transactions and trading of the Bank on its own account;
–
Independent monitoring and recording of risks to which the Bank is exposed during the execution of credit
transactions, investment transactions and trading on own account;
–
Independent representation of the execution of the risk management function in the committees dealing with
credit transactions, investment transactions and trading on own account.
Corporate Governance Statement
23
Structure of the Company
The structure of VUB, a.s. bodies:
–
The General Meeting;
–
The Supervisory Board;
–
The Management Board.
General Meeting
The General Meeting is the main decision-making body of VUB, a.s. The General Meeting has the power to decide
on issues that are in line with the mandatory provisions of legal regulations and VUB Articles of Association.
The decision of the sole shareholder of the company exercising the powers of the General Meeting in 2025 was
made on April 15 2025, when the sole shareholder approved the Regular Individual Financial Statements of VUB,
a.s., for the year 2024 and the Consolidated Financial Statements of VUB, a.s., for the year 2024,
both ﬁnancial
statements were compiled according to International Financial Reporting Standards as adopted by the EU and were
presented by the bank's Board of Directors. The sole shareholder approved the Annual Report of VUB, a.s., for the
year 2024.
The sole shareholder of the company approved Erns & Young Slovakia, spol. s r.o., as the external auditor of VUB,
a.s. for the year 2026, as well as the external auditor of VUB, a.s. for the purposes of the sustainability reporting for
the years 2024, 2025 and 2026.
On 29 January 2025, the sole shareholder adopted a resolution on the allocation of proﬁt for the year 2024, and on
18 February 2025, adopted a resolution on the amendment of the Articles of Association of VUB, a.s.
On 17 November 2025, the sole shareholder of the company adopted a resolution approving the collective suitability
of the supervisory board of the company for the year 2024, the individual suitability of candidates for and members
of the supervisory board, the collective suitability of the supervisory b
oard for the term of ofﬁce 2025
–2028, the
training plan for the members of the supervisory b
oard for the term of ofﬁce 2025
–2028, personnel changes in the
supervisory board, and the remuneration of the members of the supervisory b
oard for the term of ofﬁce 2025
–2028.
On 19 December 2025, the Sole Shareholder adopted a resolution on personnel changes in the Supervisory Board.
The activities of the General Meeting of the Company are governed by the Articles of Association, approved by the
General Meeting, and by the applicable provisions of the Commercial Code. Its competencies include:
–
Decisions on amendments to the Articles of Association of VUB, a.s.,
–
Decision on the increase and decrease of the subscribed capital and decision on authorising the Management
Board to increase the subscribed capital pursuant to Article 210 of the Commercial Code;
–
Decision on the issuance of preference bonds or convertible bonds;
–
Decision on liquidation of the Bank;
–
Decision on the change of rights associated with any type of the Bank's shares and on restriction of the
transferability of the Bank's shares;
–
Election and removal of members of the Supervisory Board, except for the members of the Supervisory Board
elected and removed by the Bank's employees;
–
A
pproval of regular and/or extraordinary individual and/or consolidated ﬁnancial statements, decision on proﬁt
distribution or settlement of losses and determination of the amount of royalties;
–
Decision on the distribution of retained earnings from previous years and/or reimbursement of unpaid losses
from previous years;
–
Decision to use the reserve fund,
–
Decision on the amount, method and place of payment and the setting of the reference date for determining
the persons entitled to exercise the right to dividends,
–
Appointment and removal of members of the Audit Committee, except for the members of the Audit Committee
who are appointed by the Supervisory Board;
–
Decision on other issues that fall within the competencies of the General Meeting under the mandatory
provisions of legal regulations and the Articles of Association of VUB, a.s.;
–
Adjustments to the powers of the Management Board and the Supervisory Board in relation to remuneration
at VUB, a.s.;
–
Approval of remuneration for members of the Supervisory Board.
Decisions on the matters referred to in
ﬁrst four
points above must be adopted by a two-thirds majority of the votes
of the shareholders present at the General Meeting and a notarial record must be drawn up. Decisions of the General
Meeting changing the rights attached to certain types of shares and/or limiting the transferability of registered shares
also the consent of a two-thirds majority of the votes of the shareholders holding such shares.
Corporate Governance Statement
24
Decisions of the General Meeting on other matters falling within the decision-making power of the General Meeting
require a majority of votes of the shareholders present, unless the Commercial Code or the Articles of Association
of VUB, a.s. provide otherwise.
The shareholders’ rights and related procedures are set out in the legal regulations and the Articles of Association
of the Bank:
–
Each shareholder is entitled to attend the General Meeting, vote, request information and seek explanations
concerning the matters of the Company or matters of persons or entities controlled by the Company which
relate to the agenda of the General Meeting, and to submit proposals.
–
The exercise of a shareholder's voting rights may only be restricted or suspended exclusively by Act No. 513/1991
Coll. Commercial Code, as amended, or under a special legal regulation.
–
A shareholder may exercise the shareholder rights attached to book-entered shares at the General Meeting if
the shareholder is entitled to exercise these rights as of the reference date speciﬁed in the invitation to the
General Meeting. The reference date shall be the day set in accordance with the legal regulations.
–
A shareholder has the right to attend the General Meetings in person or through a proxy, by the authority of a
written power of attorney. As long as VUB, a.s. is a public joint stock company, the power of attorney may be
issued to a member of the Supervisory Board in accordance with the provisions speciﬁed in the Commercial
Code. If the shareholder issues a power of attorney for the exercise of voting rights related to the same shares
to more than one proxy at one General Meeting, the Company shall permit that the proxy who has signed the
list of attending shareholders votes ﬁrst. Shareholders shall comply with the reasonable formal requirements
imposed by the Management Board in respect of powers of attorney and electronic means via which the
Company rece
ives notiﬁcations on appointment of a proxy, amendment to the power of attorney and dismissal
of a proxy, as notiﬁed to the shareholders together with the invitation to the General Meeting and on the website
of the Company.
–
The Management Board shall provide each shareholder, upon request, with complete and true information and
explanations regarding the items on the agenda of the General Meeting. If the Management Board is not able
to provide a shareholder with complete information at the General Meeting, or if a shareholder requests so at
the General Meeting, the Management Board shall provide such information to the shareholder in writing within
15 (ﬁfteen)
days from the date when the General Meeting was held. The Management Board is obliged, upon
the request made by the shareholder, to send forthwith the written information to the address given by that
shareholder; otherwise, it shall make such information available at the registered ofﬁce of the Company. The
Management Board may refer the shareholder to the website of the Company in its written information or
directly during its reply at the General Meeting. If the website does not include the requested information or
includes incomplete information, the court, upon the shareholder’s proposal, shall decide on the Company’s
obligation to provide the requested information. This right of the shareholder shall cease to exist in case the said
right has not been exercised within one month from the date in which the General Meeting was held, during
which the shareholder requested the Management Board or the Supervisory Board to provide this information.
The shareholder’s request of information may only be refused in case the disclosure of the requested information
would: constitute a breach of the law; or, following a diligent consideration of the content of such information,
adversely affect the Company or an entity controlled by the Company; or if the information is considered to be
a part of the Company's business secrets. Requests for information regarding the Company's economic
management and the status of its assets cannot be refused. The Management Board shall decide on the
acceptance or refusal of a request for information during the General Meeting. If the Management Board decides
to refuse the request for information, then the Supervisory Board, following a request by the shareholder, shall
decide on the duty of the Management Board to disclose the requested information. Upon his own initiative or
following a request by the Supervisory Board, the chairman of the General Meeting may adjourn the General
Meeting for the time necessary for the Supervisory Board to make a decision. If the Supervisory Board refuses to
provide the requested information, the shareholder may ﬁle a
proposal to the competent court entitled to decide
whether the Company is obliged to provide the requested information. This right of the shareholder shall cease
to exist in case said right has not been exercised within 1 (one) month from the date on which the General
Meeting was held, during which the shareholder requested the Management Board or the Supervisory Board to
provide information.
–
The shareholder is entitled to a share in the Bank's proﬁts (dividend). The General Meeting shall decide on the
reference date in order to determine which persons are entitled to exercise the right to dividend(s), which shall
be no earlier than 5 (ﬁve) a
nd no later than 30 (thirty) days following the General Meeting, whereas the dividend
is payable within 60 (sixty) days of the reference date.
–
The Bank shall bear the expenses and risks of payment of the dividend to the shareholders. A shareholder is not
obliged to return to the Bank a dividend which has been accepted in good faith.
–
A shareholder is not entitled to demand the return of its contribution during the term of the Bank's existence,
nor upon its winding-up. The shareholder has, however, the right to a share in the liquidation balance in the
event of the Bank's liquidation.
Corporate Governance Statement
25
Information about the Bank's shareholders is published quarterly, within 30 (thirty) days of the end of the given
quarter. The given data are as of December 31 2025. The structure of shareholders is as follows:
€ ’000
2025
2024
Intesa Sanpaolo Holding International S. A.
100.00%
100.00%
The qualifying holdings is at least 5% of the share capital of the Company. The shareholders disposing of qualifying
holdings have the right to request the Management Board to include the matter they wish to raise in the agenda of
the General Meeting. Furthermore, the shareholders with qualifying holdings have the right to request the
convocation of the Extraordinary General Meeting in accordance with the Articles of Association of the Bank. Except
for the sole shareholder – Intesa Sanpaolo Holding Internat
ional S.A. Luxemburg, with its Registered Ofﬁce at
Luxembourg L-
1821, 28 Boulevard de Kockelscheuer that holds a 100.00% stake in the registered capital, no other
shareholder has qualifying holdings of the Company’s share capital.
The VUB Group did not enter into any signiﬁcant agreements as a contractual party that would come into effect, be
modiﬁed, or become invalid due to changes in control circumstances resulting from a takeover offer, as no such
circumstances arose.
VUB Supervisory Board and Management Board in general
–
Supervisory Board members are elected by the General Meeting. Management Board are elected by the
Supervisory Board.
–
All members of the Management Board and Supervisory Board have timely access to all relevant information.
During the 2025
ﬁnancial year
, the Management Board held 25 meetings, 15 of which were via per rollam,
while the Supervisory Board held 11 meetings. Documents with detailed information are distributed well in
advance – in the case of the Management Board no less than 3 working days, in the case of the Supervisory
Board no less than 10 days prior to the meeting, thus ensuring all the members are able to
make qualiﬁed
decisions on individual matters.
–
None of the Supervisory Board members is a member of the VUB, a.s. Management Board nor holds any other
top managerial position in the Bank. With the exception the Supervisory Board members elected by VUB
employees, a Supervisory Board member may not be an employee of VUB.
The rules governing appointment and removal of members of the Bank’s Management Board and amendments to
the Articles of Association of the Bank are laid down in the Articles of Association of the Bank in compliance with
the Commercial Code, as amended, Act No. 483/2001 Coll. on Banks, as amended, and Rules of the Intesa Sanpaolo
Group. The members of the Management Board are elected and dismissed by the Supervisory Board. The Supervisory
Board also appoints the Chairman from among the members of the Management Board as well as the Vice-Chair(s)
in case a Vice-Chair position is set up.
Under Article 10.8 of the Articles of Association, the number of members of the Management Board of VUB, a.s.
determined and approved by the Supervisory Board is 7 (seven), with effect from 1 January 2025 (till 30 November
2025). As of 1 December 2025, the Management Board of VUB, a.s. has 6 (six) members.
Any decisions on amendments to the Articles of Association pursuant to paragraph 6.1(a) of the Articles of
Association of VUB, a.s. fall within the competence of the General Meeting. Decisions on amendments to the Articles
of Association pursuant to paragraph 6.1(a) of the Articles of Association of the Bank shall be made by a two-third
majority of the rights of the shareholders present at the General Meeting, and notarial record of the meeting must
be drawn up.
The powers of the statutory body comply with the Articles of Association of the Bank and with the Commercial
Code. The Management Board is the statutory body managing the activities of VUB, a.s. It is competent to act on
behalf of VUB, a.s. in all matters and represent VUB, a.s. with respect to third parties, before court and other
authorities. The Management Board manages the activities of VUB, a.s. and decides on all matters concerning VUB,
a.s., unless the legal regulations and/or the Articles of Association confer these powers to other bodies of VUB, a.s.
The statutory body of the Bank has no powers to decide on the issue or repurchase of shares. Decisions on the issue
or repurchase of shares are made by the General Meeting upon the proposal of the statutory body.
No agreements are concluded with the members of the Company’s bodies or employees based on which
compensation is to be provided to them, if their ofﬁce or employment terminates as a result of an offer for take
-
over. The conditions for exercising the duties of the members of the Management Board are laid down in the
Agreement on Exercising the Duties of the Member of the Management Board in compliance with the relevant
provisions of the Commercial Code, Act No. 483/2001 Coll. on Banks, the Principles of Remuneration and other
applicable legal regulations. The conditions of cooperation between the Bank’s employees and the Company are
deﬁned in the employment contracts concluded in accordance with the labour Code and the Collective Agreement
of the Company.
Corporate Governance Statement
26
Supervisory Board
Members of the Supervisory Board in 2025
Ignacio Jaquotot
Chairman of the Supervisory Board – till 19 November 2025
Massimo Enrico Proverbio
Chairman of the Supervisory Board – from 20 November 2025
Elena Kohútiková
Vice Chairwoman of the Supervisory Board
Marco Fabris
Member of the Supervisory Board
Luca Leoncini Bartoli
Member of the Supervisory Board – till 19 December 2025
Laura Asperti
Member of the Supervisory Board – from 20 December 2025
Christian Schaack
Member of the Supervisory Board – till 19 November 2025
Raymond Edmond Schadeck
Member of the Supervisory Board – from 20 November 2025
Draginja Djurić
Member of the Supervisory Board
Peter Gutten
Member of the Supervisory Board, employee representative
Dana Kondrótová
Member of the Supervisory Board, employee representative
Andrea Fumačová
Member of the Supervisory Board, employee representative
Upon the Management Board’s proposal, the Supervisory Board:
–
Reviews the annual report, the ordinary, extraordinary, individual and consolidated accounts and recommends
the annual report, the ordinary, extraordinary, individual and consolidated accounts to the General Meeting for
approval;
–
A
pproves the proposed distribution of current and/or past proﬁts;
–
Approves rules for the creation and use of other
funds created by VUB, a.s.;
–
Approves the draft plan for the settlement of unsettled loss and/or unsettled losses from past years;
–
Approves proposed changes to the internal audit and internal control system;
–
Approves the charter, annual audit plan of control activities and the annual report on the results of the activities
of the Internal Audit Department;
–
Reviews and approves the following matters before their submission to the General Meeting by the Management
Board:
–
Proposals for changes to the Articles of Association; and
–
Proposals for an increase or decrease in the registered share capital of VUB, a.s. and/or for the issue of
preference or convertible bonds, according to the relevant provisions of the Commercial Code;
–
Elects members of VUB, a.s., Management Board and approves the Management Board Agreement;
–
Approves any proposal for an increase or decrease in the registered capital of VUB, a.s.;
–
Approves any substantial change in the nature of the business of VUB, a.s. or the way in which the business of
VUB
, a.s. is carried out, unless already approved in the printed business and ﬁnancial conditions forecasts for
any relevant year;
–
Approves remuneration policies for rewarding the managers who report directly to the Management Board and
the Supervisory Board;
–
Decides on other issues falling within the authority of the Supervisory Board under the cogent provisions of legal
regulations and the Articles of Association;
–
Approves the Bank Remuneration Policies;
–
Approves major business transactions pursuant to Article 220ga
of the Commercial Code.
The Supervisory Board is authorized to review the following:
–
A Management Board proposal regarding the termination of trading in company’s securities on the stock
exchange, and a decision on whether the company should cease to operate as a public joint-stock company;
–
Information provided by the Management Board on the major business-related objectives for the upcoming
period, and expected development in VUB assets, liabilities and revenues;
–
The report by the Management Board on the business activities and assets of the company along with the
expected development.
Corporate Governance Statement
27
Committees of the Supervisory Board:
Audit Committee
The Audit Committee comprised of three members (including the Chairwoman) as of 31 December 2025. The Audit
Committee held seven meetings (of which three per rollam) during the 2025
ﬁnancial year. The issues discussed at
the meetings mainly related to: preparation of the ﬁnancial statements and observation of the special regulations;
efﬁciency of internal control and risk management system at the Bank; compliance with regulatory r
equirements;
the audit of the individual
ﬁnancial statements
;
the audit of the consolidated ﬁnancial statements
and monitoring
of the results in the area of sustainability information reporting. Furthermore, the Audit Committee examines and
monitors the independence of the auditor, especially services provided by the auditor according to a special
regulation, recommends the appointment of an auditor for carrying out the audit of the Bank, and sets a date for
an auditor to submit a statutory declaration about his independence. The Audit Committee regularly invited an
external auditor to attend its meetings.
The Internal Audit Department, the rights and duties of which are deﬁned by the Supervisory Board, excluding those
deﬁned by law, is in charge of the oversight. The Head of the Internal Audit Department may be appointed
to/removed from the position upon a recommendation and prior consent issued by the Supervisory Board.
Furthermore, the Supervisory Board also deﬁnes the remuneration and compensation scheme for this position. In
2025, the Chairwoman of the Audit Committee (being also the Vice Chairwoman of the Supervisory Board) and the
Head of the Internal Audit and Control Department participated in the meetings of the Supervisory Board. The
Chairwoman of the Audit Committee regularly informed the Supervisory Board of the most important issues
discussed at the Audit Committee Meetings.
Members of the Audit Committee in 2025:
Elena Kohútiková
Chairwoman of the Audit Committee – until 19 November 2025
Elena Kohútková
Raymond Edmond Schadeck
Christian Schaack
Member of the Audit Committee – from 20 November 2025
Chairman of the Audit Committee – from 20 November 2025
Member of the Audit Committee – until 19 November 2025
Marco Fabris
Member of the Audit Committee
Remuneration Committee
Remuneration Committee as a body was established in VUB a.s. by the decision of the Supervisory Board of VUB,
a.s. in July 2012, (hereinafter to as ‘VUB‘ or ‘Bank‘) in accordance with the Act on Banks and related legislation, the
Bank´s Articles of association and the Parent Company´s Guidelines on Remuneration. Committee has 3 (three)
members appointed and recalled by the VUB Supervisory Board. All of them must be Members of the Supervisory
Board of the Bank. One Member of the Committee must be appointed as the Chairman of the Committee. The
Committee meets at least once a year. It holds a fundamental position in preparation, adoption, changes and
oversight of implementation of the Remuneration Policies across selected positions (according to the Act on Banks).
It also provides support to the Supervisory Board and Management Board concerning the adoption and regular
review of the general principles of VUB, a.s.’ policies. The Remuneration Committee shall be constituted in such a
way that it can competently and independently assess remuneration policies and procedures and the impact of
remuneration on risk, capital and liquidity management.
Risk and Sustainability Committee
The Risk and Sustainability Committee was established by a decision of the Supervisory Board of VUB in September
2015. It has 3 members who are also members of the Supervisory Board. The Committee meets at least twice a year.
The Risk and Sustainability Committee is part of the risk management scheme and performs supervisory, advisory
and supportive functions primarily in the area of risk management system and strategy and its implementation
monitoring.
Nomination Committee
The Nomination Committee was established by decision of the Supervisory Board in April 2024. It has 3 members
who are members of the Supervisory Board. The Committee meets at least once a year. The Nomination Committee
has a decisive role in identifying and recommending candidates for appointment to managerial/executive positions
by the Supervisory Board or the General Meeting.
Corporate Governance Statement
28
Management Board
Management Board Members in 2025
Jozef Kausich
Chairman of the Management Board and Chief Executive Officer
Gabriele Pace
Member of the Management Board and Deputy Chief Executive Officer
Andrej Viceník
Member of the Management Board and Head of Corporate and SME Division
Peter Magala
Member of the Management Board and Chief Operating Officer –
till 30 November 2025
Martin Techman
Member of the Management Board and Head of Retail Division
Branislav Kováčik
Member of the Management Board and Chief Risk Officer
Darina Kmeťová
Member of the Management Board and Chief Financial Officer
Jozef Kausich
– Chairman of the Management Board and CEO of VUB bank
Jozef Kausich has been the CEO and Chairman of the
Management Board of VUB Bank since 1 March 2023.
Prior to that, he serv
ed for ﬁve years as
C
hairman of the
Management Board at Banka Intesa Sanpaolo in Slovenia. Before
his tenure in Slovenia, he spent 12 years at VUB Bank as a member
of the Board of Directors and Director of Corporate Banking.
Additionally, he served as a member of the Supervisory Board of
VUB Bank´s subsidiaries, including VUB Leasing and VUB
Factoring.
Jozef Kausich graduated from the University of Economics in
Bratislava and subsequently gained experience
in several ﬁnancial
institutions. At Bank Austria – Creditanstalt Slovakia a.s., he served
as Deputy Head of the Large Clients Department, where he began
to focus on corporate banking. He later joined HVB Bank Slovakia
a.s., where he became the Director of the Corporate Clients
Department.
Gabriele Pace – Member of the Management Board and Deputy CEO of VUB Bank
Gabriele Pace has been a member of the Management Board since
2023 also serves as Deputy CEO of VUB Bank. In this position, he
is primarily responsible for the Bank´s
control and support
departments.
Before coming to Slovakia, he led ISP International Value Services
in Croatia, an innovative international IT service provider
supporting the digital transformation of banking. He previously
served as DCEO at Banca Intesa Beograd in Serbia. From 2004, he
worked at Privredna banka Zagreb in Croatia, where he served as
a member of the bank's Board of Directors and later also DCEO.
He has been working in the Intesa Sanpaolo banking group since
1987, where he started as an IT analyst in New York.
Corporate Governance Statement
29
Andrej Viceník– Member of the Management Board and Head of Corporate and SME Division
Andrej Viceník is a member of the Management Board and Head of
Corporate and SME Division and Chairman of the Supervisory Board
of VUB Operating Leasing a.s. He has been working in VUB since
2006. He held the position of Director of Corporate Clients until
2010 and subsequently led
the Small and Medium Enterprises
Division until November 2017.
Since December 2017, he has been serving at his current role.
Previously, he held the leading positions
at Česká pojišťovna
, Zurich
Insurance Company, and HVB Bank Slovakia. He graduated from the
University of Economics in Bratislava and also obtained the Executive
MBA degree at Webster University during his career.
Martin Techman Member of the Management Board and Head of Retail Division
Martin Techman has been a member of the Management Board of
VUB Bank and the Head of the Retail Division since March 2015. He
joined VUB Bank
from Česká spořitelna, where he
served as Director
of the Distribution Network.
Martin Techman is responsible for branch ofﬁce
s
and customer
relationship management, banking products for natural persons and
small businesses, payment cards, and private banking.
He has been working in ﬁnancial services and banking since 1994.
He started his career at Multiservis, which was later acquired by GE
Capital. Over the years, he held several key positions, including
Consumer Finance Manager, Product Development Manager, Third
Party Product Manager, and Mortgage Credit Manager. Between
2004 and 2005, he held the position of Director of Product
Development and Management at VUB Bank, where he was
responsible for managing retail products, the network of mortgage
centres, and external sales. Since 2005, he has been Director of
Business Development at Česká spořitelna
, and since 2011 has
managed the network of branches in the Czech Republic.
Martin Techman holds an MBA degree in Managerial Studies and
“Senior Executive” Management from Nottingham Trent University.
Darina Kmeťová
– Member of the Management Board
and Chief Financial Ofﬁcer
Darina Kmeťová
is a member of the Management Board of VUB
Bank and
serves as Chief Financial Ofﬁcer
(CFO).
She joined VUB Bank in October 2019 as the Director of the Planning
and Control Department. Prior to that, she served as a Finance and
Controlling Leader across
various sectors (automotive, media,
marketing and banking) of foreign companies. She has many years
of experience in senior ﬁnancial
, controlling
and in managerial
positions with international coverage. She studied at the University
of Economics in Bratislava.
Corporate Governance Statement
30
Branislav Kováčik
– Member of the Management Board and Chief
Risk Ofﬁcer
Branislav Kováčik became a member of the
Management Board of
VUB Bank and Chief Risk
Ofﬁcer
on 22 November 2024.
Mr.
Kováčik
headed the subsidiary VUB Leasing for over 8 years,
which was gradually integrated into the Bank's structures. Later on
2021, he moved to IVS (International Value Services) within the
banking group.
He has extensive
experience in the ﬁnancial
sector, banking and
leasing. He studied at the University of Economics in Bratislava.
Competencies of the Management Board
The Management Board is authorized to manage the activities of VUB, a.s. and to take decisions on any matters
related to VUB which, under legal regulations or the Articles of Association, have not been reserved to the authority
of other VUB bodies. The Management Board is primarily responsible for the following matters:
–
manages VUB, a.s. and exercises employer rights;
–
implements decisions taken by the General Meeting and the Supervisory Board;
–
ensures the accuracy of the books and other accounting-related records, trade books and other documentation
of VUB, a.s.;
–
after prior approval and on the recommendation of the Supervisory Board, submits the following matters to the
General Meeting for approval:
–
amendments to the Articles of Association of the Bank;
–
proposals for increasing/decreasing registered capital and bond issues;
–
proposals for issuing shares or redemption of shares;
–
ordinary, extraordinary, individual or consolidated ﬁnancial statements;
–
proposals for distribution of current or retained proﬁts and/or proposals for settlement of outstanding losses
from the current and/or previous years;
–
the annual report;
–
a proposal for approval or withdrawal of the auditor of VUB, a.s. for the relevant accounting period;
–
approves and regularly examines Remuneration Policies.
The conditions for the performance of the position of a Management Board Member are deﬁned in the Management
Board Agreement in line with the relevant provisions of the Commercial Code, Act No. 483/2001 Coll. on Banks,
Remuneration Policies and other relevant legislation.
Committees of the Management Board
The Credit Committee
The Credit Committee is the highest permanent decision-making committee of the Bank regarding counterparties.
Its main responsibility is to adopt credit decisions in line with the issued strategic guidelines and credit policies while
acting within the credit prerogatives of the Bank and in compliance with the applicable laws and Group regulations.
The Credit Risk Governance Committee
The Credit Risk Governance Committee is a permanent decision-making and advisory committee tasked with
ensuring a qualiﬁed and coordinated management of credit risk and compliance with the applicable laws, ISP Group
regulations and Parent Company’s strate
gic decisions. The Committee’s main responsibility is to deﬁne and update
credit risk strategic guidelines and credit management policies based on the results of credit portfolio monitoring.
With regard to Product Governance, the Committee analyses and assesses the issues related to the launch and
monitoring of the products that imply credit risk.
Corporate Governance Statement
31
The Assets and Liabilities Management Committee
The Asset and Liabilities Committee is a permanent decision-
making and consultative committee focused on ﬁnancial
risks governance, the active value management issues, the strategic and operative management of assets and
liabilities and on ﬁnancial produ
cts governance. The main objective of ALCO is to protect the Bank’s equity and
supervise its allocation, to harmonize the assets and liabilities of the Bank taking into consideration pricing structures
and maturity proﬁles in compliance with Parent Compan
y guidelines, Bank’s internal regulations, laws, rules, and
regulations set by the competent Authorities.
The Operational Risk Committee
The Operational Risk Committee is a permanent decision-making and advisory committee whose mission is to ensure
a qualiﬁed and competent management of operational risk issues (ICT/cyber risk inclusive), in compliance with the
applicable laws, Group regulations and internal procedures.
Change Management Committee
The Committee represents a platform that links the business and IT strategies (and their priorities) with the
operational management of business priorities in the context of IT resources and capacity planning. In urgent cases,
the Committee acts as the superior and decision-
making body with respect to problems and conﬂicts in business
priorities, and it resolves conﬂicts concerning the allocation of resources based on business requirements.
Internal Control Coordination Committee
The aim of the Internal Control Coordination Committee is to strengthen coordination and the tools for cooperation
among the various Bank´s control departments and to enable the integration of the risk management process.
The Problem Asset Committee
The Problem Asset Committee is the supreme permanent decision-making committee of the Bank in terms of risky
and non-performing counterparties. Its main responsibility is to take the necessary measures in order to prevent and
mitigate credit losses connected with risky and deteriorated assets, while acting within the credit prerogatives of the
Bank and in compliance with the applicable laws and ISP Group regulations.
The Crisis Committee
The Crisis Committee is management and coordination body that issues orders for key bank areas with the aim to
prevent, mitigate and remove the impact of extraordinary events or crisis situations on business activity and the
goodwill of the Bank. Crisis Committee has a right to be informed about BIA results, as well as about creation,
implementation and testing of Business Continuity Plan for system and critical processes.
The members of the relevant committees established by the Bank's bodies are designated members of the
Management Board and designated employees of the Bank.
The Environmental Social and Governance Committee
The Environmental Social and Governance Committee is a permanent consultative and decision-making committee
of the Bank with the main goal to coordinate and steer ESG related matters and to ensure the correct implementation
of the ISBD ESG strategy and respective ISP Group guidelines within the Bank.
Relations between the Company and its shareholders
The Bank observes the provisions of the Commercial Code and other relevant valid legislation applicable to the
protection of shareholders’ rights, as well as the regulation on the timely provision of all relevant information on the
Company and provisions on convening and conducting its General Meetings.
The Company follows the principle of shareholders’ rights, equal access to information for all shareholders and other
relevant principles pursuant to the Corporate Governance Code for Slovakia.
The Company’s approach to shareholders
The Bank’s corporate governance principles ensure, facilitate and protect the exercise of shareholders’ rights. The
Company duly and timely performs all its duties and obligations towards shareholders in compliance with relevant
legislation and the Corporate Governance Code for Slovakia. The Company enables shareholders to duly and
transparently exercise their rights in compliance with relevant valid legislation.
Corporate Governance Statement
32
Disclosure of information and transparency
–
The Bank enforces strict rules in the area of insider dealing, and continually maintains and updates a list of
insiders.
–
Information about corporate governance is published on the VUB’s web site www.vub.sk in the section ‘About
the Bank‘. Information for shareholders is available on the VUB’s web site www.vub.sk in the ‘Information for
VUB shareholders‘ section.
–
Members of the Management Board and Supervisory Board do not have any personal interest in the business
activities of the Bank. The Bank strictly observes the provisions of the Banking Act No. 483/2001 Coll. (hereinafter
the ‘Banking Act’) as amended, applicable to the provision of deals to the
Bank’s related parties. Under the
Banking Act, the closing of such a deal requires the unanimous consent of all the Management Board members
once they have been acquainted with a written analysis of the deal concerned; a person with a personal interest
in the given deal is excluded from decision making. With regard to the persons who have a special relationship
with the Bank, the Bank does enter into deals, which owing to their nature, purpose or risk entailed, would not
be entered into with other clients under the same circumstances.
–
The Bank abides by the Corporate Governance Code for Slovakia, the rules of the Bratislava Stock Exchange and
Luxemburg Stock Exchange governing disclosure of all substantial information. The fact that the Company
observes the mentioned regulations ensures that all the bondholders and potential bondholders have access to
information on the ﬁnancial standing, performance, ownership and management of the
company, enabling them
to take competent investment decisions. The Corporate Governance Code for Slovakia is available on The Slovak
Association Corporate Governance web site:
http://www.bsse.sk/Portals/2/Issuers%20Guide/2018/kodex_ENG_akt.pdf.
The Bratislava Stock Exchange Rules are available on the Bratislava Stock Exchange web site www. bsse.sk and
Luxemburg Stock Exchange Rules on web site
www.luxse.com
. The Bank is not aware of any deviations from
the Corporate Governance Code.
–
The Company actively supports a constructive dialogue with institutional investors.
–
The Bank enforces changes arising from Act No. 566/2001 Coll. on Securities and Investment Services, as
amended (hereinafter the ‘Securities Act’), at a European level, and the MiFID Directive (Markets in Financial
Instruments Directive), and undertakes activities directed at investor protection and strengthening client trust in
the provision of investment services. The main objective of the MiFID Directive is to
enhance ﬁnancial consumer
protection in the ﬁeld of investment services. The essence of the M
iFID Directive lies in the new categorization
of clients according to their knowledge and experience in investing to provide clients with an adequate level of
protection, in the Bank’s obligation to act in the best interests of the client in carrying out their orders in relation
to their ﬁnancial
instruments (best execution), in higher requirements as regards market transparency, and
management of the Bank as a securities trader, to be ensured by internal control systems and the prevention of
conﬂict of
interests. Information related to investment services is published on the VUB web site www.vub.sk in the
section ‘Mission and values/Investor protection‘ .
–
The Bank continues to provide payment services according to the Act on Payment services No. 492/2009 Coll,
as well as EU Directive 2015/2366 of the European Parliament and of the Council of 25 November 2015, on
payment services in the internal market, amending Directives 2002/65/EC, 2009/110/EC and 2013/36/EU and
Regulation (EU) No. 1093/2010, and repealing Directive 2007/64/EC. The aim of this law is to ensure that
consumers receive clear, high-quality information about payment services, enabling them to make informed
decisions and compare options when shopping within the EU. In the interests of transparency, the harmonized
requirements are laid down in order to ensure the necessary and sufﬁcient information to payment service users
with regard to the payment service contract and payment transactions.
33
Consolidated Financial Statements
Consolidated ﬁnancial statements
drawn up in accordance with International Financial Reporting Standards (‘IFRS®’)
as adopted by the European Union (‘EU’) for the year ended 31 December 2025
34
Contents
Independent auditor´s report
......................................................................................................................
35
Consolidated statement of financial position as at 31 December 2025
............................................................
42
Consolidated statement of profit or loss and other comprehensive income for the year ended 31 December 2025 ..
...............................................................................................................................................................
43
Consolidated statement of changes in equity for the year ended 31 December 2025
........................................
45
Consolidated statement of cash flows for the year ended 31 December 2025
..................................................
46
1.
Basis of preparation
.........................................................................................................................
48
2.
Changes in accounting policies
..........................................................................................................
51
3.
Material accounting policies
..............................................................................................................
53
4.
Financial and operational risk management
........................................................................................
69
5.
Estimated fair value of financial assets and financial liabilities
..............................................................
101
6.
Segment reporting
.........................................................................................................................
104
7.
Cash and cash equivalents
..............................................................................................................
106
8.
Financial assets and financial liabilities at fair value through profit or loss
.............................................
106
9.
Derivatives – Hedge accounting
.......................................................................................................
107
10.
Financial assets at fair value through other comprehensive income
......................................................
110
11.
Financial assets and financial liabilities at amortized cost
....................................................................
111
12.
Fair value changes of the hedged items in portfolio hedge of interest rate risk
......................................
114
13.
Investments in joint ventures and associates
......................................................................................
114
14.
Property and equipment and non-current assets classified as held for sale
............................................
114
15.
Intangible assets
............................................................................................................................
118
16.
Goodwill
.......................................................................................................................................
119
17.
Deferred income tax assets and liabilities
..........................................................................................
119
18.
Other assets
..................................................................................................................................
120
19.
Provisions
......................................................................................................................................
120
20.
Other liabilities
..............................................................................................................................
120
21.
Movements in impairment losses and provisions for loan commitments and financial guarantees
............
121
22.
Equity
...........................................................................................................................................
122
23.
Off-balance sheet items
..................................................................................................................
124
24.
Net interest income
........................................................................................................................
126
25.
Net fee and commission income
......................................................................................................
127
26.
Net trading result
...........................................................................................................................
128
27.
Other operating income
.................................................................................................................
128
28.
Other operating expenses
...............................................................................................................
128
29.
Salaries and employee benefits
........................................................................................................
128
30.
Other administrative expenses
.........................................................................................................
129
31.
Income tax expense and special levy
................................................................................................
129
32.
Related parties
..............................................................................................................................
130
33.
Events after the end of the reporting period
.....................................................................................
133
Spoločnosť zo skupiny Ernst & Young Global Limited
Ernst & Young Slovakia, spol. s r.o., IČO: 35 840 463,
zapísaná v Obchodnom registri Mestského súdu Bratislava III
, oddiel: Sro, vložka číslo: 27004/B a v zozname audítorov vedenom
Slovenskou komorou audítorov pod č. 257.
Ernst & Young Slovakia, spol. s. r.o.
Žižkova 9
811 02 Bratislava
Slovenská republika
Tel:
+421 2 3333 9111
www.ey.com/sk
Independent Auditor’s Report
To the Shareholder, Supervisory Board, Board of Directors and to the Audit Committee of
Všeobecná
úverová banka, a.s.:
Report on the Audit of the Consolidated Financial Statements
Opinion
We have audited the consolidated financial statements of
Všeobecná úverová banka, a.s.
(
”
the Bank
”
)
and its subsidiaries (“the Group”)
, which comprise the consolidated statement of financial position as at
31 December 2025, consolidated statement of profit or loss and other comprehensive income,
consolidated statement of changes in equity and consolidated statement of cash flows for the year then
ended, and notes to the consolidated financial statements, including material accounting policy
information and other explanatory information.
In our opinion, the accompanying consolidated financial statements of the Group give a true and fair
view of the consolidated financial position of the Group as at 31 December 2025, and of its consolidated
financial performance and its consolidated cash flows for the year then ended in accordance with IFRS
accounting standards (International Financial Reporting Standards) as adopted by the European union.
Basis for Opinion
We conducted our audit in accordance with International Standards on Auditing (ISA). Our
responsibilities under those standards are further described in the
Auditor’s Responsibilities for the Audit
of the Consolidated Financial Statements section of our report. We are independent of the Group in
accordance with the International Ethics Standards Board for Accountants’ International Code of Ethics
for Professional Accountants (including International Independence Standards) as adopted by the
Slovak Chamber of Auditors (
“
Code of Ethics for Auditors
”
) within the scope applicable to audits of
financial statements of public interest entities, including the ethical requirements of the Regulation of the
European Parliament and of the Council (EU) No 537/2014 from 16 April 2014 on specific requirements,
as applicable to audits of the financial statements of public interest entities (
“
Regulation No 537/2014
”
)
and Act No. 423/2015 on Statutory Audit and on the amendments and supplements to the Act on
Accounting No. 431/2002, as amended (
“
Act on Statutory Audit
”
), that are relevant to audits of the
financial statements of public interest entities in the Slovak Republic. We have also fulfilled our other
ethical responsibilities in accordance with the Code of Ethics for Auditors, the ethical requirements of
the Regulation No 537/2014 and the Act on Statutory Audit. We believe that the audit evidence we have
obtained is sufficient and appropriate to provide a basis for our opinion.
Key audit matters
Key audit matters are those matters that, in our professional judgment, were of most significance in our
audit of the consolidated financial statements of the current period. These matters were addressed in
the context of our audit of the consolidated financial statements as a whole, and in forming our opinion
thereon, and we do not provide a separate opinion on these matters.
Impairment allowances for loans and advances to customers
Due from customers valued at amortized cost less
impairment as at 31 December 2025 amount to
EUR 21 827
322
thousand
and
represent
a
significant portion of the Group’s total assets.
As disclosed in Note 11.2 (Due from customers) to
the consolidated financial statements, it included the
gross book value of due from customers valued at
amortized cost of EUR 22 187 041 thousand and
impairment allowance of EUR 359 719 thousand.
Determining the amount and the moment of
recognizing impairment allowances for expected
credit losses requires significant judgments and
complex estimates of the management disclosed in
Note 4.1.2 (Impairment losses) to the separate
financial statements. For performing exposures and
non-performing exposures below EUR 500 thousand
individually, it comprises assumptions built into
statistical credit loss models, such as assessment of
significant increase in credit risk, definition of default,
incorporation
of
forward-looking
information,
calculation of the loss given default parameter and
recovery rates. For exposures above EUR 500
thousand
individually,
the
Group
performs
an individual assessment based on the detailed
review and analysis of the borrower’s situation and
for non-performing exposures, the judgments include
identification of loss events other than overdue
payments and estimation of timing and amount of
expected cash flows from repayments and realization
of collaterals.
The individual basis for calculating expected credit
losses
(“
ECL
”),
based
on
probability
-weighted
scenarios, is then used for individually assessed
exposures in Stage 3. Portfolio ECL calculation is
used for all other instances.
Due to the significance of loans and advances in
relation to the total assets and significance of the
management’s judgments and estimates and their
complexity regarding the expected credit losses
described
above,
we
evaluated
impairment
allowances for loans and advances as a key audit
matter.
As part of our audit procedures, we documented our
understanding of the Group’s credit risk management
policies. We obtained an understanding, evaluated
the design and tested the operating effectiveness of
the internal controls over the approval, recording and
monitoring of the loans, identification of loss events
and
impairment
triggers and
the
process of
calculating impairment allowances for due from
customers.
We reconciled a register of due from customers with
accounting records to assess completeness of the
recognition of due from customers, which create the
basis for the calculation of impairment allowances for
expected credit losses.
We involved credit risk specialists to assist us with
assessment
of
the
impairment
allowances
methodology, methods, results of the Bank’s tests of
credit risk parameters (so called “back
-
testing”),
credit rating models and credit risk parameter
models, their assumptions and implementation in the
system in accordance with the IFRS 9 requirements.
We evaluated post-model adjustments for expected
credit losses (so called “overlays”) that were recorded
to
address
the
back-testing
results
and
management’s expectations of additional credit
losses in the retail and corporate segment in the light
of economic volatility.
On a selected sample, we analyzed loan exposures
assessed individually by the Group. For selected
performing exposures, we analyzed the economic
and financial situation of borrowers and fulfillment of
the
terms
of
loan
agreements
to
evaluate
appropriateness
of
the
classification
into
risk
categories, so-called
“
staging
”
. In case of selected
non-performing
exposures,
we
assessed
the
reasonableness of the expected cash flows from
repayments and recoverable amounts of collateral
based on available financial and market data and we
recalculated the individual impairment allowance.
We
performed
analytical
procedures
on
disaggregated data on the quarterly development of
the impairment allowance per portfolios, products and
stages related to the development of the structure
and characteristics of the credit portfolio including the
impairment allowances, reflecting the quality of the
loan portfolio in the light of the impairment allowances
for expected credit losses for loans to customers
aimed at identifying portfolios of loans to customers
with understated impairment provisions.
We involved specialists in the field of IT systems to
assist us with the testing of effectiveness of the
control mechanisms of IT systems, in which the
Group calculates the credit risk parameters and the
impairment allowances for expected credit losses.
We also assessed the disclosures in Note 4.1.2
(Impairment losses) and Note 11.2 (Due from
customers) regarding expected credit losses for due
from customers included in the consolidated financial
statements in terms of their completeness and
compliance
with
IFRS
accounting
standards
(International Financial Reporting Standards) as
adopted by the European union.
Responsibilities of Management and Those Charged with Governance for the Consolidated Financial
Statements
Management is responsible for the preparation and fair presentation of these consolidated financial
statements in accordance with IFRS accounting standards (International Financial Reporting Standards)
as adopted by the European union, and for such internal control as management determines is
necessary to enable the preparation of consolidated financial statements that are free from material
misstatement, whether due to fraud or error.
In preparing the consolidated financial statements, management is responsible for assessing the
Group
’s
ability to continue as a going concern, disclosing, as applicable, matters related to going
concern and using the going concern basis of accounting unless management either intends to liquidate
the Group or to cease operations, or has no realistic alternative but to do so.
Those charged with governance are responsible for overseeing the Group
’s financial reporting process.
Auditor’s Responsibilities for the Audit of the Consolidated Financial Statements
Our objectives are to obtain reasonable assurance about whether the consolidated financial statements
as a whole are free from material misstatement, whether due to fraud or error, and to issue an auditor’s
report that includes our opinion. Reasonable assurance is a high level of assurance, but is not a
guarantee that an audit conducted in accordance with International Standards on Auditing will always
detect a material misstatement when it exists. Misstatements can arise from fraud or error and are
considered material if, individually or in the aggregate, they could reasonably be expected to influence
the economic decisions of users taken on the basis of these consolidated financial statements.
As part of an audit in accordance with International Standards on Auditing, we exercise professional
judgment and maintain professional scepticism throughout the audit. We also:
•
Identify and assess the risks of material misstatement of the consolidated financial statements,
whether due to fraud or error, design and perform audit procedures responsive to those risks,
and obtain audit evidence that is sufficient and appropriate to provide a basis for our opinion.
The risk of not detecting a material misstatement resulting from fraud is higher than for one
resulting from error, as fraud may involve collusion, forgery, intentional omissions,
misrepresentations, or the override of internal control.
•
Obtain an understanding of internal control relevant to the audit in order to design audit
procedures that are appropriate in the circumstances, but not for the purpose of expressing an
opinion on the effectiveness of the Group
’s
internal control.
•
Evaluate the appropriateness of accounting policies used and the reasonableness of accounting
estimates and related disclosures made by management.
•
Conclude on the appropriateness of management’s use of the going concern basis of
accounting and, based on the audit evidence obtained, whether a material uncertainty exists
related to events or conditions that may cast significant doubt on the Group
’s
ability to continue
as a going concern. If we conclude that a material uncertainty exists, we are required to draw
attention in our auditor’s report to the related disclosures in the
consolidated financial
statements or, if such disclosures are inadequate, to modify our opinion. Our conclusions are
based on the audit evidence obtained up to the date of our auditor’s report. However, future
events or conditions may cause the Group to cease to continue as a going concern.
•
Evaluate the overall presentation, structure and content of the consolidated financial statements
including the presented information as well as whether the consolidated financial statements
capture the underlying transactions and events in a manner that leads to their fair presentation.
•
Plan and perform the Group audit to obtain sufficient appropriate audit evidence regarding the
financial information of the entities within the Group as a basis for forming an opinion on the
Group financial statements. We are responsible for the direction, supervision and review of the
audit work performed for the purpose of the Group audit. We remain solely responsible for our
audit opinion.
We communicate with those charged with governance regarding, among other matters, the planned
scope and timing of the audit and significant audit findings, including any significant deficiencies in
internal control that we identify during our audit.
We also provide those charged with governance with a statement that we have complied with relevant
ethical requirements regarding independence, and to communicate with them all relationships and other
matters that may reasonably be thought to bear on our independence, and where applicable, actions
taken to eliminate threats or safeguards applied.
From the matters communicated with those charged with governance, we determine those matters that
were of most significance in the audit of the consolidated financial statements of the current period and
are therefore the key audit matters.
We describe these matters in our auditor’s report unless law or regulation precludes public disclosure
about the matter or when, in extremely rare circumstances, we determine that a matter should not be
communicated in our report because the adverse consequences of doing so would reasonably be
expected to outweigh the public interest benefits of such communication.
Report on Other Legal and Regulatory Requirements
Report on Information Disclosed in the Consolidated Annual Report
Management is responsible for the information disclosed in the consolidated annual report, prepared
based on requirements of the Act on Accounting No 431/2002 Coll., as amended by later legislation
(“the Act on Accounting”)
. Our opinion on the consolidated financial statements expressed above does
not apply to other information contained in the consolidated annual report.
In connection with audit of the consolidated financial statements it is our responsibility to understand the
information disclosed in the consolidated annual report and to consider whether such information is not
materially inconsistent with audited consolidated financial statements or our knowledge about the Group
and its situation obtained in the audit of the consolidated financial statements, or otherwise appears to
be materially misstated.
We considered whether the Group
’s
consolidated annual report (except for the requirements related to
sustainability reporting) contains information, disclosure of which is required by the Act on Accounting.
Based on procedures performed during the audit of consolidated financial statements, in our opinion:
-
Information disclosed in the consolidated annual report prepared for 2025 is consistent with the
consolidated financial statements for the relevant year,
-
The consolidated annual report (except for the requirements related to sustainability reporting)
contains information based on the Act on Accounting.
Additionally, based on our understanding of the Group and its situation, obtained in the audit of the
consolidated financial statements, we are required to disclose whether material misstatements were
identified in the consolidated
annual report, which we received prior to the date of issue of this auditor’s
report. In this regard, there are no findings which we should disclose.
Independent assurance report on the compliance of the presentation of the Consolidated Financial
Statements with the requirements of the European Single Electronic Format (“ESEF”)
We have been engaged by the Bank to conduct a reasonable assurance engagement to verify the
compliance of the presentation of the consolidated financial statements of the Group for the year ended
31 December 2025
included in the Annual Financial Report (“the Presentation of the Consolidated
Financial Statements”) with the requirements of the Commission Delegated Regulation (EU) 2019/815
of 17 December 2018 supplementing Directive 2004/109/EC of the European Parliament and of the
Council with regard to regulatory technical standards on the specification of a single electronic reporting
format (“the ESEF Regulation”).
Description of subject matter and applicable criteria
The Presentation of the Consolidated Financial Statements has been applied by the management to
comply with the requirements of the ESEF Regulation. The applicable requirements regarding the
Presentation of the Consolidated Financial Statements are contained in the ESEF Regulation.
The requirements described in the preceding paragraph with respect to the Presentation of the
Consolidated Financial Statements constitute, in our view, appropriate criteria to form a reasonable
assurance conclusion.
Responsibility of the management and those charged with governance
The management is responsible for the Presentation of the Consolidated Financial Statements that
complies with the requirements of the ESEF Regulation.
This responsibility includes:
•
preparation of the consolidated financial statements in XHTML format;
•
selection and application of appropriate markups in iXBRL using ESEF taxonomy; and
•
designing, implementing and maintaining internal controls relevant for the preparation of the
Presentation of the Consolidated Financial Statements which is free from material non-
compliance with the requirements of the ESEF Regulation.
Those charged with governance are responsible for overseeing the Group’s financial reporting process,
which also includes the preparation of the consolidated financial statements that also comply with the
requirements of the ESEF Regulation.
Auditor’s responsibility
Our responsibility is to express a reasonable assurance conclusion whether the Presentation of the
Consolidated Financial Statements complies, in all material respects, with the requirements of the ESEF
Regulation.
We conducted our reasonable assurance engagement in accordance with the International Standard on
Assurance Engagements 3000 (Revised), Assurance Engagements Other than Audits and Reviews of
Historical Financial Information,
(“the ISAE 3000(R)”), issued by the International Auditing and
Assurance Standards Board (“the IAASB”). This standard requires that we comply
with ethical
requirements, plan and perform procedures to obtain reasonable assurance whether the Presentation
of the Consolidated Financial Statements complies, in all material respects, with the requirements of the
ESEF Regulation.
The nature, timing, and extent of procedures performed depend on the auditor’s judgment. Reasonable
assurance is a high level of assurance, but it does not guarantee that the service performed in
accordance with ISAE 3000(R) always detects material non-compliance.
Auditor’s quality control and independence requirements
We apply the provisions of International Standard on Quality Management (ISQM) 1 (issued by the
IAASB) and, accordingly, maintain a comprehensive system of quality control, including documented
policies and procedures regarding compliance with ethical requirements, professional standards and
applicable legal and regulatory requirements.
We comply with independence and other ethical requirements of the International Code of Ethics for
Professional Accountants (including International Independence Standards) issued by the International
Ethics Standards Board for Accountants, which is founded on fundamental principles of integrity,
objectivity, professional competence and due care, confidentiality and professional behaviour.
Summary of the work performed
Our planned and performed procedures were aimed at obtaining reasonable assurance that the
Presentation of the Consolidated Financial Statements complies, in all material respects, with the
requirements of the ESEF Regulation. Our procedures included in particular:
•
obtaining an understanding of the internal control system and processes relevant to the
application of the electronic reporting format of the consolidated financial statements, including
the preparation of the XHTML format and marking up the consolidated financial statements;
•
verification whether the XHTML format was properly applied;
•
evaluating the completeness of marking up the consolidated financial statements using the
XBRL markup language according to the requirements of the implementation of the electronic
format, as described in the ESEF Regulation;
•
evaluating the appropriateness of the Group’s' use of XBRL markups selected from the ESEF
taxonomy and the creation of extension markups where no suitable element in the ESEF core
taxonomy has been identified; and
•
evaluating the appropriateness of the anchoring of the extension elements to the ESEF core
taxonomy.
We believe that the evidence we have obtained is sufficient and appropriate to provide a basis for our
conclusion.
Conclusion
In our opinion, based on the procedures performed, the Presentation of the Consolidated Financial
Statements complies, in all material respects, with the requirements of the ESEF Regulation.
Other requirements on content of auditor’s report in compliance with Regulation (EU) No. 537/2014 of
the European Parliament and of the Council of 16 April 2014 on specific requirements regarding
statutory audit of public-interest entities
Appointment and approval of Auditor
We were appointed as the statutory auditor by statutory body of the Bank on 24 April 2025 based on
our approval by the General Meeting of Shareholder of the Bank on 18 March 2024.
Total uninterrupted
engagement period, including previous renewals (extension of the period for which we were originally
appointed) and reappointments for the statutory auditor
,
has lasted for 5 years.
Consistence with Additional Report to the Audit Committee
Our audit opinion expressed herein is consistent with the additional report to the audit committee of the
Bank, which we issued on 23 February 2026.
Non-audit Services
No prohibited non-audit services referred to in Article 5(1) of Regulation (EU) No. 537/2014 of the
European Parliament and of the Council of 16 April 2014 on specific requirements regarding statutory
audit of public-interest entities were provided and we remain independent from the Group in conducting
the audit.
In addition to statutory audit services and services disclosed in the consolidated annual report and in
the consolidated financial statements, no other services were provided by us to the Group.
26 February 2026,
except for the section of our report “Independent assurance report on the compliance
of the presentation of the Consolidated Financial Statements with the requirements of the European
Single Electronic Format (“ESEF”)”, for which the date of our report is
8 April 2026.
Bratislava, Slovak Republic
Ernst & Young Slovakia, spol. s r.o.
SKAU Licence No. 257
Ing. Dalimil Draganovský, statutory auditor
SKAU Licence No. 893
Consolidated financial statements
42
Consolidated statement of ﬁnancial position as
at 31 December 2025
€ ‘000
Note
2025
2024
Assets
Cash and cash equivalents
7
2 149 318
2 272 663
Financial assets at fair value through profit or loss
8
Financial assets held for trading
164 248
188 305
Non-trading financial assets at fair value through profit or loss
1 541
3 410
Derivatives – Hedge accounting
9
89 038
75 566
Financial assets at fair value
through other comprehensive income
10
1 440 284
1 489 654
of which pledged as collateral
53 807
548 012
Financial assets at amortized cost
11
Due from banks
213 075
317 938
Due from customers
21 827 322
20 455 952
of which pledged as collateral
612 239
178 495
Fair value changes of the hedged items
in portfolio hedge of interest rate risk
12
1 262
775
Investments in joint ventures and associates
13
1 507
1 197
Property and equipment
14
111 147
119 156
Intangible assets
15
171 311
173 749
Goodwill
16
29 305
29 305
Current income tax assets
5 155
-
Deferred income tax assets
17
61 396
68 406
Other assets
18
54 272
58 241
26 320 181
25 254 317
Liabilities
Financial liabilities at fair value through profit or loss
8
Financial liabilities held for trading
51 033
69 941
Derivatives – Hedge accounting
9
100 343
173 282
Financial liabilities at amortized cost
11
Due to banks
1 154 208
831 368
Due to customers
18 067 421
17 146 438
Lease liabilities
22 082
21 156
Subordinated debt
300 386
300 401
Debt securities in issue
4 007 222
4 203 983
Fair value changes of the hedged items
in portfolio hedge of interest rate risk
12
(5 770)
(8 193)
Current income tax liabilities
-
44 016
Provisions
19
27 482
30 309
Other liabilities
20
166 894
177 109
23 891 301
22 989 810
Equity
Share capital
22
510 819
510 819
Share premium
13 719
13 719
Legal reserve fund
102 454
102 454
Other capital funds
8 464
8 464
Retained earnings
1 768 450
1 624 197
Equity reserves
24 974
4 854
2 428 880
2 264 507
26 320 181
25 254 317
The accompanying notes on pages 48 to 133
form an integral part of these ﬁnancial statements.
Consolidated Financial Statements
43
Consolidated statement of proﬁt or loss
and other comprehensive income
for the year ended 31 December 2025
€ ‘000
Note
2025
2024
Interest income calculated using the effective interest method
927 622
1 011 972
Other interest income
11 654
3 768
Interest and similar expense
(350 565)
(441 853)
Net interest income
24
588 711
573 887
Fee and commission income
256 123
230 092
Fee and commission expense
(38 938)
(40 698)
Net fee and commission income
25
217 185
189 394
Net trading result
26
19 542
16 931
Other operating income
27
3 552
5 130
Other operating expenses
28
(23 716)
(21 618)
Salaries and employee benefits
29
(164 236)
(162 047)
Other administrative expenses
30
(96 264)
(92 429)
Amortisation
15
(27 134)
(33 401)
Depreciation
14
(12 308)
(12 916)
Profit before provisions, impairment and tax
505 332
462 931
Net modification (loss)/gain
(19 944)
158
Provisions
19
55
(67)
Impairment losses and
provisions for loan commitments and financial guarantees
21
(56 604)
(36 824)
Net gain
/(loss) arising from the derecognition of financial assets
at amortised cost
7 245
(21)
Share of the profit of investments in joint ventures and
associates accounted for using the equity method
308
321
Profit before tax
436 392
426 498
Income tax expense
31
(166 271)
(172 941)
NET PROFIT FOR THE YEAR
270 121
253 557
(Table continues on the next page)
Consolidated Financial Statements
44
Consolidated statement of proﬁt or loss and
other comprehensive income for the
year ended 31 December 2025
(continued)
€ ‘000
Note
2025
2024
Other comprehensive income for the year, after tax
Items that shall not be reclassified to profit or loss in the future
Change in value of financial assets at fair value
through other comprehensive income (equity instruments)
Revaluation gain arising during the year
313
(67)
Reclassification adjustment
for profit on sale of FVOCI equities within equity
(95)
60
Total items that shall not be reclassified
to profit or loss in the future, before tax
218
(7)
Income tax relating to components
of other comprehensive income
(29)
(668)
Total items that shall not be reclassified
to profit or loss in the future, after tax
189
(675)
Items that may be reclassified to profit or loss in the future
Change in value of financial assets at fair value
through other comprehensive income (debt instruments)
Revaluation gain/(loss) arising during the year
21 242
(4 015)
Reclassification adjustment for profit on sale
of FVOCI bonds included in the profit or loss
6 124
3 843
Exchange difference on translation of foreign operations
587
850
Change in value of cash flow hedges
(342)
(182)
Total items that may be reclassified to profit or loss
in the future, before tax
27 611
496
Income tax relating to components
of other comprehensive income
(7 584)
1 042
Total items that may be reclassified to profit or loss
in the future, after tax
20 027
1 538
Other comprehensive income for the year, after tax
20 216
863
TOTAL COMPREHENSIVE INCOME FOR THE YEAR
290 337
254 420
In 2025, the presentation of other comprehensive income was revised. Items related to other comprehensive income
that were presented in separate notes in the previous year have been clearly integrated directly into the statement
‘Consolidated statement of
proﬁt or loss and other comprehensive income for the year ended 31 December 2025’.
This change represents only a reclassiﬁcation of information and does not affect the reported amounts of total
comprehensive income or the comparability of the data.
The accompanying notes on pages 48 to 133
form an integral part of these ﬁnancial statements.
Consolidated Financial Statements
45
Consolidated statement of changes in equity for the year ended
31 December 2025
€ ‘000
Share
capital
Share
premium
Other
capital
funds
Legal
reserve
fund
Retained
earnings
Reva-
luation
surplus of
buildings
and land
Financial
assets
at FVOCI
Cash
flow
hedges
Translation
of foreign
operation
Total
1 January 2025
510 819
13 719
8 464
102 454
1 624 197
16 595
(11 485)
(164)
(92)
2 264 507
Total comprehensive income
for the year, after tax
-
-
-
-
270 121
-
19 889
(260)
587
290 337
Transfers
-
-
-
-
-
-
-
-
-
-
Losses on the sale of shares
at FVOCI
-
-
-
-
95
-
(95)
-
-
-
Gain on disposal of property
and equipment
-
-
-
-
1
(1)
-
-
-
-
Exchange difference
-
-
-
-
2
-
-
-
-
2
Transactions with owners,
recorded directly in equity
Dividends to shareholders
-
-
-
-
(125 966)
-
-
-
-
(125 966)
Reversal of dividends
distributed but not collected
-
-
-
-
-
-
-
-
-
-
31 December 2025
510 819
13 719
8 464
102 454
1 768 450
16 594
8 309
(424)
495
2 428 880
€ ‘000
Share
capital
Share
premium
Other
capital
funds
Legal
reserve
fund
Retained
earnings
Reva-
luation
surplus of
buildings
and land
Financial
assets
at FVOCI
Cash
flow
hedges
Translation
of foreign
operation
Total
At 1 January 2024
510 819
13 719
8 464
87 783
1 519 808
17 250
(12 350)
(27)
(942)
2 144 524
Total comprehensive income
for the year, after tax
-
-
-
-
253 557
(655)
805
(137)
850
254 420
Transfers
-
-
-
14 671
(14 671)
-
-
-
-
-
Losses on the sale of shares
at FVOCI
-
-
-
-
(60)
-
60
-
-
-
Gain on disposal of property
and equipment
-
-
-
-
-
-
-
-
-
-
Exchange difference
-
-
-
-
(3)
-
-
-
-
(3)
Transactions with owners,
recorded directly in equity
Dividends to shareholders
-
-
-
-
(134 783)
-
-
-
-
(134 783)
Reversal of dividends
distributed but not collected
-
-
-
-
349
-
-
-
-
349
At 31 December 2024
510 819
13 719
8 464
102 454
1 624 197
16 595
(11 485)
(164)
(92)
2 264 507
The accompanying notes on pages 48 to 133
form an integral part of these ﬁnancial statements.
Consolidated Financial Statements
46
Consolidated statement of cash ﬂows for the year ended 31
December 2025
€ ‘000
Note
2025
2024
Cash flows from operating activities
Profit before tax
436 392
426 498
Adjustments for
Interest income
24
(939 276)
(1 015 740)
Interest expense
24
350 565
441 853
Gain from sale/revaluation of financial assets at fair value
through other comprehensive income
26
(10 052)
(28 618)
Gain on sale of intangible assets and property and equipment
27
(492)
(1 581)
Loss from revaluation of financial liabilities at amortized cost
26
11 952
45 478
Amortisation
15
27 134
33 401
Depreciation
14
12 308
12 916
Impairment losses and similar charges
21
73 335
70 172
Share of the profit or loss of investments in joint ventures and
associates accounted for using the equity method and
related items
(310)
(316)
Exchange difference on translation of foreign operations
589
847
Interest received
938 156
1 012 094
Interest paid
(353 088)
(429 453)
Tax paid
(208 432)
(182 114)
Decrease/(increase) in financial assets at fair value
through profit or loss
23 477
(127 649)
(Increase)/decrease in derivatives – hedge accounting (assets)
(13 472)
108 111
Financial assets at amortized cost
Decrease/(increase) in due from banks
102 044
(83 253)
Increase in due from customers
(1 451 982)
(2 066 257)
Increase in fair value changes of the hedged items
in portfolio hedge of interest rate risk (assets)
(487)
(58 180)
Decrease/(increase) in other assets
3 969
(18 358)
(Decrease)/increase in financial liabilities
at fair value through profit or loss
(18 908)
33 491
Decrease in derivatives – hedge accounting (liabilities)
(72 939)
(72 378)
Financial liabilities measured at amortized cost
Decrease in due to banks
(11 966)
(123 822)
Increase in due to customers
931 121
1 121 183
Increase in fair value changes of the hedged items in portfolio
hedge of interest rate risk (liabilities)
2 423
3 725
Increase in provisions
1 814
1 466
(Decrease)/increase in other liabilities
(10 215)
17 297
Net cash used in operating activities
(176 340)
(879 187)
Cash flows from investing activities
Purchase of financial assets at fair value
through other comprehensive income
(694 551)
(450 564)
Disposal of financial assets at fair value
through other comprehensive income
777 604
207 488
Repayments of financial assets at fair value
through other comprehensive income
-
52 400
Purchase of intangible assets and property and equipment
(19 298)
(23 914)
Disposal of intangible assets and property and equipment
3 593
2 806
Investments in Monilogi, s.r.o.
-
(162)
Net cash from/(used in) investing activities
67 348
(211 946)
(Table continues on the next page)
Consolidated Financial Statements
47
Consolidated statement of cash ﬂows for the year ended 31 December 202
5
(continued)
€ ‘000
Note
2025
2024
Cash flows from financing activities
Proceeds from issue of debt securities
500 000
500 000
Repayments of debt securities in issue
(716 597)
(788 000)
Proceeds from loans received from other banks
595 000
100 000
Repayments of loans received from other banks
(260 200)
(107 304)
Repayments of lease liabilities
(6 590)
(8 641)
Dividends paid
(125 966)
(134 783)
Net cash used in financing activities
(14 353)
(438 728)
Net change in cash and cash equivalents
(123 345)
(1 529 861)
Cash and cash equivalents at the beginning of the year
7
2 272 663
3 802 524
Cash and cash equivalents at 31 December
7
2 149 318
2 272 663
The accompanying notes on pages 48 to 133
form an integral part of these ﬁnancial statements.
Consolidated Financial Statements
48
1.
Basis of preparation
1.1.
Reporting entity – general information
Všeobecná úverová banka, a.s. (‘the Bank’ or ‘VUB’) provides
retail and commercial banking services. The Bank is
domiciled in the Slovak Republic with its registered ofﬁce at Mlynské nivy 1, 829 90 Bratislava 25
, with the
identiﬁcation number (IČO) 313 20 155 and the tax identiﬁcation number (DIČ) 2020411811.
The VUB Group is part of the Intesa Sanpaolo Group (’ISP Group’), which is one of the leading banking groups in
Europe (103.1 billion euros
market capitalization), with a signiﬁcant ESG commitment,
including on climate, and a
world-class position in social impact. The ISP Group is a leader in Italy in all business areas (retail, corporate, wealth
management) and has a strategic international presence, including subsidiaries operating in commercial banking in
12 countries in Central and Eastern Europe and in the Middle East and North Africa regions, and an international
network of specialists supporting corporate customers in 24 countries, particularly in the Middle East and North
Africa and in those areas where Italian companies are most active.
The VUB Group’s ultimate parent company is Intesa Sanpaolo S.p.A. (‘ISP’ or ‘the Parent Company’), which is a joint-
stock company incorporated and domiciled in Italy. The consolidated ﬁnancial statements of the
Company are
available at the address of its registered ofﬁce at Piazza San Carlo 156, 10121 Torino, Italy.
At 31 December 2025, the VUB Group operated a network of 163 points of sale (including retail branches, corporate
branches, and mortgage centres) throughout Slovakia (31 December 2024: 165). The VUB Group also operated one
branch in the Czech Republic (31 December 2024: 1).
At 31 December 2025, the members of the Management Board are
Jozef Kausich
(Chairman), Gabriele Pace, Andrej
Viceník, Martin Techman, Darina Kmeťová
and Branislav Kováčik
.
At 31 December 2025, the members of the Supervisory Board are Massimo Enrico Proverbio (Chairmain), Elena
Kohútiková (
Vice Chairwoman), Marco Fabris, Laura Asperti, Raymond Edmond Schadeck, Draginja Djuric, Peter
Gutten, Dana Kondrótová
and
Andrea Fumačová
.
At 31 December 2025, the total number of employees of the VUB Group was 3 215 (31 December 2024: 3 364).
The average number of employees of the VUB Group during the year ended as at 31 December 2025 was 3 286
(31 December 2024: 3 354).
1.2.
The VUB Group
The consolidated ﬁnancial statements comprise the Bank and its subsidiaries (
jointly referred to as ‘the VUB Group’
or ‘the Group’) and the Group’s interest in associates and joint ventures. All entities are incorporated in the Slovak
Republic.

| Share | Share |
| December | December |
| 2025 | 2024 | Main activity
Subsidiaries |  |  |
VUB Operating Leasing, a.s. (‘VUB Operating Leasing’) | 100.00% | 100.00% | Operating leasing
VUB Generali d. s. s., a.s. (‘VUB Generali’) | 55.26% | 55.26% | Pension fund administration
Joint ventures |  |  |
Monilogi, s.r.o. (‘Monilogi’) | 33.00% | 33.00% | Cash processing
Associates |  |  |
Slovak Banking Credit Bureau, s. r. o. (‘SBCB’) | 33.33% | 33.33% | Credit database administration

1.3.
Basis of accounting
The consolidated ﬁnancial statements of the VUB Group (‘the ﬁnancial statements’) have been prepared in
accordance with International Financial Reporting Standards (‘IFRS’) issued by the International Accounting Standards
Board (‘IASB’) and with interpretations issued by the International Financial Reporting Interpretations Committee of
the IASB (‘IFRIC’) as approved by the European Union Commission in accordance with the Regulation of European
Parliament and the Council of European Union and in accordance with the Act No. 431/2002.
Consolidated Financial Statements
49
The ﬁnancial statements have been prepared under historical prices adjusted by the revaluation of ﬁnancial assets
and liabilities at fair value though proﬁt or loss, ﬁnancial assets at fair value
through other comprehensive income,
derivatives – hedge accounting, buildings and land in falling under the property and equipment under revaluation
model to fair value and in the case of the ﬁnancial assets or ﬁnancial liabilities designated as hedged items in
qualifying fair value hedge relationships modiﬁed by the changes in fair value attributable to the risk being hedged.
The ﬁnancial statements were prepared using the going concern assumption that the VUB Group will continue in
operation for the foreseeable future.
1.4.
Basis of consolidation
Subsidiaries
Subsidiaries are entities controlled by the Bank. Control is established when the Bank has power over the investee,
is exposed to or has rights to variable returns from its involvement with the investee, and can use its power to
inﬂuence those returns. The ﬁnancial statements of subsidiaries
are included in the consolidated
ﬁnancial
statements
from the date at which effective control commences until the date at which control ceases.
The ﬁnancial statements of the Bank and its subsidiaries are combined on a line
-by-line basis by adding together like
items of assets, liabilities, equity, income and expenses. Intra-group balances, transactions and
resulting proﬁts are
eliminated in full.
The purchase acquisition of accounting is used to account for the acquisition of subsidiaries by the VUB Group. The
cost of an acquisition is measured as the fair value of the assets acquired, equity instruments issued and liabilities
incurred or assumed at the date of exchange, plus costs directly attributable to the acquisition. Identiﬁable assets
acquired and liabilities and contingent liabilities assumed in a business combination are measured initially at their fair
values at the acquisition date, irrespective of the extent of any non-controlling interest.
The excess of the cost of the acquisition over the fair value of the VUB Group’s share of the
identiﬁable
net assets
acquired is recognized as goodwill.
Associates
Associates are entities in which the VUB Group has signiﬁcant inﬂuence, but not control, over the ﬁnancial and
operating policies. The ﬁnancial statements include the Group’s share of the total
recognized gains and losses of
associates on an equity accounted basis from the date when
signiﬁcant inﬂuence commences until the date that
signiﬁcant inﬂuence ceases.
Joint ventures
A joint venture is a joint arrangement whereby the parties that have joint control of the arrangement have rights to
the net assets of the arrangement. The ﬁnancial statements include the VUB Group’s share of the total
recognized
gains and losses of joint ventures on an equity accounted basis, from the date that joint control commences until
the date that joint control ceases.
To determine the nature of interest in another entity an assessment of the control indicators described above is
performed by the management of the VUB Group, applying certain level of judgement.
1.5.
Functional and presentation currency
EUR is the functional and presentation currency of the VUB Group.
The ﬁnancial statements are presented in
thousands of EUR (‘€’ or ‘EUR’), unless indicated otherwise. Negative balances are presented in brackets.
1.6.
Use of judgements and estimates
In preparing the ﬁnancial statements,
the management made judgements, estimates and assumptions that affect
the application of the VUB Group‘s accounting policies and the reported amounts of assets, liabilities, income and
expenses. Actual results may differ from these estimates.
Estimates and underlying assumptions are reviewed on an ongoing basis. Revisions to estimates are recognized
prospectively.
Consolidated Financial Statements
50
1.6.1.
Judgements
Information about judgements of the
accounting policies that have the most signiﬁcant effects on the amounts
recognized
in the ﬁnancial statements is included in the following notes. The most signiﬁcant judgements relate to
the classiﬁcation of ﬁnancial instruments.
–
Classiﬁcation of ﬁnancial instruments: assessment of the business model
under which the assets are held and
assessment of whether the contractual terms of the ﬁnancial asset are solely payments of principal and interest
(‘SPPI’) on the principal amount outstanding (note 3.4.2).
–
Establishing the criteria for determining whether credit risk on the ﬁnancial asset has increased signiﬁcantly since
initial recognition, determining methodology for incorporating forward-looking information into measurement
of expected credit loss (‘ECL’) and selection and approval of models used to measure ECL (note 4.1.2).
–
Valuation of lease liabilities and right-of-use assets (note 14).
The use of International Financial Reporting Standard 16 Leases (‘IFRS 16’) requires the VUB Group to make
judgments that affect valuation of not only the lease liabilities but also the right-of-use assets. These include:
determining contracts in scope of IFRS 16, determining the contract term and determining the interest rate used for
discounting of future cash ﬂows.
The lease term determined by the VUB Group generally comprises non-cancellable period of lease contracts, periods
covered by an option to extend the lease if the VUB Group is reasonably certain to exercise that option, and periods
covered by an option to terminate the lease if the VUB Group is reasonably certain not to exercise that option. The
same term is applied as economic useful life of right-of-use assets.
For contracts relating to branch and ofﬁce premises, the VUB Group has concluded that there are a number of
scenarios where the VUB Group might elect not to exercise the extension options. Therefore, the IFRS 16 criterion
of being reasonably certain to ex
ercise the extension options is not fulﬁled. The periods covered by a potential use
of an option to extend the lease were excluded from the lease term.
For leases of branch and ofﬁce premises
concluded for an
indeﬁnite term
, the VUB Group generally estimates the
length of the contract to be ﬁve years. The
VUB Group monitors these assumptions, reviews the industry practices
and the latest
accounting interpretations in relation to the estimation of the lease terms among peer ﬁnancial entities
.
The Bank is prepared to make adjustments, if necessary.
The present value of the lease payment is determined using the discount rate representing the rate of interest rate
swap applicable for currency of the lease contract and for similar tenor, corrected by the average credit spread of
entities with rating similar to the VUB Group’s rating, observed in the period when the lease contract commences
or is modiﬁed.
1.6.2.
Assumptions and estimation uncertainties
Estimates are used for (include but not limited to)
: fair values of ﬁnancial instruments, fair value of buildings
and land
under the revaluation model, impairment losses on due from banks and due from customers and impairment losses
related to ﬁnancial assets at fair value through other comprehensive income, provisions for
loan commitments and
ﬁnancial guarantees
, useful lives and residual values of tangible and intangible assets, impairment losses on tangible
and intangible assets, valuation of lease liabilities and right-of-
use assets, liabilities from employee beneﬁts,
provisions for legal claims and deferred tax assets.
Information about assumptions and estimation uncertainties that run a risk of causing a material adjustment is
included in the following notes.
–
Determination of the fair value of ﬁnancial instruments with signiﬁcant unobservable inputs (note 5)
. Where the
fair values of ﬁnancial assets and ﬁnancial liabilities recorded on the statement of ﬁnancial position cannot be
derived from active markets, they are determined using a variety of valuation techniques which include the use
of mathematical models. The inputs to these models are taken from observable markets where possible, but
where this is not feasible, a degree of judgement is required in establishing fair values. The judgements include
considerations of liquidity and model inputs such as correlation and volatility for longer dated ﬁnancial
instruments.
–
Impairment of ﬁnancial instruments: determining inputs into the
expected credit losses (ECL) model, including
incorporation of forward-looking information. (note 4.1.2)
Consolidated Financial Statements
51
The VUB Group reviews its loans and advances at each reporting date to assess whether any individually assessed
impairment loss should be recorded in the statement of proﬁt or loss.
Management judgment is particularly necessary
when estimating the amount and timing of future cash ﬂows
to determine the required impairment loss. Such
estimates are based on assumptions about a number of factors and actual results may differ, resulting in future
changes to the individually assessed impairment losses.
–
Recognition and measurement of legal claims: key assumptions about the likelihood and magnitude of an
outﬂow of resources.
–
Recognition of deferred tax assets: availability of future taxable proﬁt against which deferred tax assets can be
used.
–
Impairment testing for cash generating units containing goodwill: key assumptions underlying recoverable
amounts.
2.
Changes in accounting policies
A few of the new standards and amendments to standards became effective for annual periods beginning after
1 January
2025. These, however, have no material effect on the ﬁnancial statements.
Except for the changes below, the VUB Group has consistently applied the accounting policies as set out in note 3
to all periods presented in the ﬁnancial statements.
2.1.
Standards and interpretations relevant to the VUB Group’s operations issued that are effective for the current
year and have been endorsed by the European Union
Lack of exchangeability (Amendments to IAS 21)
Amendments to IAS 21 The Effects of Changes in Foreign Exchange Rates speciﬁes how the
VUB Group should
assess whether a currency is exchangeable and how it should determine a spot exchange rate when exchangeability
is lacking. The amendments also require disclosure of information that enables users of the VUB Group
’s ﬁnancial
statements to understand how the currency not being exchangeable into the other currency affects, or is expected
to affect, the VUB Group
’s ﬁnancial performance, ﬁnancial position
and cash ﬂows.
This amendment did not have a material impact on the VUB Group
’s ﬁnancial statements.
2.2.
Standards and interpretations issued but not yet effective or not early adopted by the VUB Group
A few new standards and amendments to standards are not yet effective or not yet adopted by the European Union.
Early adoption is permitted; however, the VUB Group has not adopted the new and amended standards in preparing
these consolidated ﬁnancial statements. The
VUB Group intends to adopt these standards when they become
effective.
Classiﬁcation and Measurement of Financial Instruments (Amendments to IFRS 9 and IFRS 7)
In May 2024, the IASB issued Amendments to the classiﬁcation and Measurement of Financial Instruments which
amended IFRS 9 and IFRS 7.
The requirements will be effective for annual reporting periods beginning on or after 1 January 2026, with early
application permitted, and are related to:
–
S
ettling ﬁnancial liabilities using electronic payments system; and
–
A
ssessing contractual cash ﬂow characteristics of ﬁnancial assets, including those with sustainability
-linked
features.
The VUB Group has performed an assessment of all material electronic payment systems used. Most of the electronic
settlement systems used by the VUB Group result in real-time settlement.
There is a number of electronic settlement systems used by the VUB Group that do not result in real-time settlement.
The VUB Group
derecognises the ﬁnancial liability and the associated cash when the payment has reached the
beneﬁciary, which is when the obligation is discharged. The amendments are not expected to have a material impact.
In addition, the VUB Group
has assessed the impact of the Amendments on its ﬁnancial assets
with sustainability-
linked features and other similar contingent features, as well as on non-
recourse ﬁnancing and contractually linked
instruments. Based on the assessments, the amendments in these areas are not expected to have a material impact
on the ﬁna
ncial statements.
Consolidated Financial Statements
52
IFRS 18 Presentation and Disclosures in Financial Statements
IFRS 18 will replace lAS 1 Presentation of Financial Statements and applies for annual reporting periods beginning
on or after 1 January 2027.
The new standard introduces the following key new requirements:
–
The VUB Group is
required to classify all income and expenses into ﬁve categories in the statement of proﬁt or
loss, namely the operating, investing, ﬁnancing, discontinued operations and income tax categories.
The VUB
Group is also required to present a
newly deﬁned
operating proﬁt subtotal.
The VUB Group 's
net proﬁt will not
change.
–
Management-
deﬁned performance measures (
‘MPMs‘
) are disclosed in a single note in the ﬁnancial statements.
–
Enhanced guidance is provided on how to group information in the ﬁnancial statements.
In addition, all entities are required to use the operating proﬁt subtotal as the starting point for the statement of
cash ﬂows when presenting operating cash ﬂows under the indirect method.
The VUB Group
is currently working to identify the impacts the standard will have on the primary ﬁnancial statements
and notes to the ﬁnancial statements. The
VUB Group considers its main business activities to include the provision
of ﬁnancing to customers and investing in ﬁnancial assets. In accordance with IFRS 18, some of the income and
expenses related to those activities are classiﬁed in the operating category,
as an exception to the general
requirements that would otherwise have resulted in thei
r classiﬁcation in the investing or ﬁnancing categories.
The initial expected impacts of IFRS 18 on the VUB Group
’s ﬁnancial statements are, as follows:
–
Income and expenses from the following will be classiﬁed in the operating category within the statement of
proﬁt or loss: cash and cash equivalents; liabilities from transactions that involve only the raising of ﬁnance;
generally, assets invested in as part of the VUB Group
’s main business activity of investing in ﬁnancial assets that
generate a return individually and largely independently of the VUB Group’s other resources;
–
Foreign exchange differences will be classiﬁed in the same category as the related income and expense giving
rising to the foreign exchange difference, with some exceptions;
–
Gains and losses on hedging instruments, including those not designated as such, but used to manage exposure
to identiﬁed risks, will be classiﬁed in the same category as the income and expenses relating to the risk being
covered, with some exceptions;
–
For the statement of cash ﬂows, the ‘operating proﬁt’ subtotal will be used as the starting point for determining
cash ﬂows from operating activities. Furthermore, the classiﬁcation of the total cash ﬂows from all dividends
received, all interest paid
and all interest received will each, respectively, be classiﬁed in a single category in the
statement of cash ﬂows following the classiﬁcation of the related income and expenses in the statement of proﬁt
or loss;
–
New disclosures will be added for management-
deﬁned performance measures;
–
A reconciliation for each line item in the statement of proﬁt or loss between the restated amounts presented
applying IFRS 18, and the amounts previously presented applying IAS 1.
The VUB Group
is also assessing the impact on how information is grouped in the ﬁnancial statements, including for
items currently labelled as 'other'.
The following new and amended standards are not expected to have a signiﬁcant impact on the ﬁnancial statements:
–
Contracts Referencing Nature-dependent Electricity (Amendments to IFRS 9 and IFRS 7);
–
Annual Improvements to IFRS Accounting Standards (Volume 11);
–
IFRS 19 Subsidiaries without Public Accountability: Disclosures;
–
Translation to a Hyperinﬂationary Presentation Currency (Amendments to IAS 21);
–
Sale or Contribution of Assets between an Investor and its Associate or Joint Venture (Amendment in IFRS 10
and IAS 28).
Consolidated Financial Statements
53
3.
Material accounting policies
3.1.
Foreign currency transactions
Transactions in foreign currencies are translated into the EUR
at the ofﬁcial European Central Bank (’ECB’) spot
exchange rate at the date of the transactions.
Monetary assets and liabilities denominated in foreign currencies are translated into EUR at the
ofﬁcial
ECB spot
exchange rate at the reporting date. The foreign currency gain or loss on monetary items is the difference between
the amortized cost in the functional currency at the beginning of the year, adjusted for effective interest and payments
during the year, and the amortized cost in the foreign currency translated at the spot exchange rate at the end of
the year.
Non-monetary assets and liabilities that are measured at fair value in a foreign currency are translated into EUR at
the
ofﬁcial
ECB spot exchange rate at the date on which the fair value is determined. Non-monetary items that are
measured based on historical cost in a foreign currency are translated using the ofﬁcial ECB spot exchange rate at
the date of the transaction.
The foreign currency gain or loss is the difference between the contractual exchange rate of a transaction and the
ofﬁcial ECB exchange rate at the date of the transaction. Foreign currency gain or loss is included in
‘Net trading
result’, as well as gains or losses arising from movements in exchange rates after the date of the transaction.
Foreign currency differences arising on translation are generally recognized
in proﬁt or loss.
However, foreign
currency differences arising from the translation of the following items are recognized in other comprehensive
income (’OCI’):
–
Q
ualifying cash ﬂow hedges to the extent that the hedge is effective; and
–
Equity instruments in respect of which an election has been made to present subsequent changes in fair value
in OCI.
3.2.
Foreign operations
The ﬁnancial statements include foreign operations in the Czech Republic. The assets and liabilities of foreign
operations are translated into EUR at the spot exchange rate at the reporting date. The income and expenses of
foreign operations are translated to EUR at rates approximating the foreign exchange rates at the dates of the
transactions.
Foreign currency differences arising on these translations are recognized in OCI and accumulated in the foreign
currency translation reserve (‘Translation of foreign operation’ reserve).
3.3.
Cash and cash equivalents
‘Cash and cash equivalents’ include notes and coins on hand, balances held with central banks, including compulsory
minimum reserves, and highly liquid ﬁnancial assets with original maturities of three months or less from the date
of acquisition that are
subject to an insigniﬁcant risk of changes in their fair value, and are used by the VUB Group
in the management of its short-term commitments.
‘Cash and cash equivalents’ are carried at amortized
cost in the statement of ﬁnancial position (note 7).
3.4.
Financial assets and ﬁnancial liabilities
3.4.1.
Recognition and initial measurement
The VUB Group initially recognises loans and advances (e.g. ‘Due from banks’, ‘Due from customers’), deposits (e.g.
‘Due to banks’, ‘Due to customers‘), debt securities issued and subordinated debt on the date on which they
originated. All other ﬁnancial instruments (including regular
-way purchases and sales
of ﬁnancial assets) are
recognized on the trade date, which is the date on which the VUB Group becomes a party to the contractual
provisions of the instrument.
A ﬁnancial asset or ﬁnancial liability is initially
measured at fair value. For items not
classiﬁed
at fair value through
proﬁt or loss,
the initial measurement also includes transaction costs directly attributable to their acquisition or
issuance.
Consolidated Financial Statements
54
3.4.2.
Classiﬁcation
On initial recognition, a ﬁnancial asset is classiﬁed as measured at:
–
Amortised cost (‘AC’),
–
Fair value through other comprehensive income (‘FVOCI’), or
–
Fair value through proﬁt or loss (‘FVTPL’).
A ﬁnancial asset is measured at AC, if it meets both of the following conditions and is not designated as at FVTPL:
–
The asset is held within a business model whose objective is to hold assets to collect contractual cash
ﬂows; and
–
The contractual terms of the ﬁnancial asset give rise on speciﬁed dates to cash ﬂows that are SPPI.
A debt instrument is measured at FVOCI only if it meets both of the following conditions and is not designated as
at FVTPL:
–
The asset is held within a business model whose objective is achieved by both collecting contractual cash
ﬂows
and selling ﬁnancial assets; and
–
The contractual terms of the ﬁnancial asset give rise on speciﬁed dates to cash ﬂows that are SPPI.
On initial recognition of an equity investment that is not held for trading, the VUB Group may irrevocably elect to
present subsequent changes in fair value in OCI (note 3.6.2). This election is made on an investment-by-investment
basis.
All other ﬁnancial assets are classiﬁed as measured at FVTPL.
In addition, on initial recognition, the VUB Group may irrevocably designate a ﬁnancial asset that otherwise meets
the requirements to be measured at amortized
cost or at FVOCI as at FVTPL if doing so eliminates or signiﬁcantly
reduces an accounting mismatch that would otherwise arise (note 3.4.7).
Business model assessment
The VUB Group uses the following business models:
–
Held to collect,
–
Held to collect and sell,
–
Held for trading/Other.
The VUB Group assesses of the objective of a business model in which an asset is held at a portfolio level, as this
best reﬂects
how the business is managed and information is provided to management. The information considered
includes:
–
The stated policies and objectives for the portfolio and the operation of those policies in practice. In particular,
whether management’s strategy focuses on earning contractual interest revenue, maintaining a
speciﬁc
interest
rate proﬁle,
aligning
the duration of ﬁnancial assets
with that of the corresponding liabilities, or realizing cash
ﬂows through
asset sales;
–
How the performance of the portfolio is evaluated and reported to the Bank’s management;
–
The risks that affect the performance of the business model (and the ﬁnancial assets held within that business
model) and its risk management strategy;
–
How managers of the business are compensated (e.g. whether compensation is based on the fair value of the
assets managed or the contractual cash ﬂows collected); and
–
The frequency, volume and timing of sales in prior periods, the reasons for such sales and future sales activity
expectations. However, information about sales activity is not considered in isolation but rather as part of an
overall assessment of how the VUB Group states objective for managing the ﬁnancial assets is achieved and how
cash ﬂows are realised.
Financial assets that are held for trading, managed and whose performance is evaluated on a fair value basis are
measured at FVTPL because they are neither held to collect contractual cash ﬂows nor to collect contractual cash
ﬂows and to sell ﬁnancial assets.
Consolidated Financial Statements
55
Assessment of whether contractual cash ﬂows are SPPI
For the purposes of this assessment, ‘principal’ is
deﬁned
as the fair value of the
ﬁnancial
asset on initial recognition.
‘Interest’ is
deﬁned
as consideration for the time value of money and for the credit risk associated with the principal
amount outstanding during a particular period of time and for other basic lending risks and costs (e.g. liquidity risk
and administrative costs), as well as proﬁt
margin.
In assessing whether the contractual cash ﬂows are SPPI, the VUB Group considers the contractual terms of the
instrument. This includes assessing whether the ﬁnancial asset contains a contractual term that could change the
timing or amount of contractual
cash ﬂows
, preventing it from meeting this condition. In making the assessment,
the VUB Group considers:
–
Contingent events that would change the amount and timing of cash ﬂows;
–
Leverage features;
–
Prepayment and extension terms;
–
Terms that limit the VUB Group’s claim to cash ﬂows from speciﬁed assets (e.g. non
-recourse loans); and
–
Features that modify consideration of the time value of money (e.g. periodical reset of interest rates).
The VUB Group holds a portfolio of long-
term ﬁxed
-rate loans for which the VUB Group has the option to propose
to revise the interest rate at periodic reset dates. These reset rights are limited to the market rate at the time of revision.
The borrowers have an option to either accept the revised rate or redeem the loan at par without penalty. The VUB
Group has determined that the contractual cash
ﬂows
of these loans meet the SPPI criterion, because the option
modiﬁ
es the interest rate in a way that takes into account the time value of money, credit risk, other basic lending
risks and costs associated with the principal amount outstanding.
The VUB Group classiﬁes its ﬁnancial liabilities, other than ﬁnancial guarantees and loan commitments, as measured
at amortized cost or FVTPL.
Reclassiﬁcations
Financial assets are not
reclassiﬁed
subsequent to their initial recognition, except in the period following a change in
the VUB Group´s
business model for managing ﬁnancial assets. Financial liabilities are never
reclassiﬁed.
3.4.3.
Subsequent measurement
After initial recognition, the VUB Group measures ﬁnancial assets and ﬁnancial liabilities in accordance
with the
classiﬁcation at fair value through proﬁt or loss (note 3.5), fair value through other comprehensive income (note 3.6)
and at amortized cost (note 3.7).
3.4.4.
Derecognition
Derecognition due to substantial modiﬁcation of terms and conditions
The VUB Group derecognises a
ﬁnancial
asset, such as a loan provided to a customer, when the terms and conditions
have been renegotiated to the extent that the loan becomes a new loan. In such a case, the difference isrecognized
as a derecognition gain or loss, to the extent that an impairment loss has not already been recorded. When assessing
whether to derecognise a loan to a customer, the VUB Group considers the factors such as a change in currency of
the loan, the introduction of an equity feature, a change in counterparty, and
whether the modiﬁcation
would cause
the instrument to no longer meet the SPPI criterion.
Where an existing ﬁnancial liability is replaced by another from the same lender
under substantially different terms,
or the terms of an existing liability are substantially modiﬁed, such an exchange or modiﬁcation is treated as a
derecognition of the original liability and the recognition of a new liability. The difference between the carrying value
of the original
ﬁnancial
liability and the consideration paid is recognized in profit or loss.
Consolidated Financial Statements
56
Derecognition other than due to substantial modiﬁcation
The VUB Group derecognises a
ﬁnancial
asset when the contractual rights to its
cash ﬂows expire or
when it transfers
the rights to receive those
cash ﬂows in a transaction
where substantially all the risks and rewards of ownership are
transferred. Additionally, derecognition occurs if the VUB Group neither transfers nor retains substantially all of the
risks and rewards of ownership, and does not maintain control over
the ﬁnancial asset.
On derecognition of a
ﬁnancial
asset, the difference between the carrying amount of the asset (or the carrying amount
allocated to the portion of the asset derecognized) and the sum of (i) the consideration received (including any new
asset obtained less any new liability assumed), and (ii) any cumulative gain or loss that had been recognized in OCI
is recognized
in proﬁt or
loss.
Any cumulative gain or loss recognized in OCI in respect of equity investment securities designated as at FVOCI is
not recognized
in proﬁt or loss on derecognition of such securities, as explained above. Any interest
in transferred
ﬁnancial
assets that qualify for derecognition that is created or retained by the VUB Group is recognized as a separate
asset or liability.
The VUB Group enters into transactions in which it transfers assets recognized in its statement of
ﬁnancial position
but retains either all or substantially all of the risks and rewards of the transferred assets or a portion of thereof. In
such cases, the transferred assets are not derecognized. Examples of such transactions are securities lending and
sale-and-repurchase transactions. (note 3.8)
In transactions in which the VUB Group neither retains nor transfers all of the risks and rewards of ownership of a
ﬁnancial asset
but retains control over the asset instead, the VUB Group continues to recognise the asset to the
extent of its continuing involvement, which is determined by the extent to which it is exposed to changes in the
value of the transferred asset.
The VUB Group derecognises
a ﬁnancial liability when its contractual obligations are fulﬁled or cancelled, or when
they expire.
3.4.5.
Modiﬁcations
If the terms of a ﬁnancial asset are modiﬁed, then the VUB Group evaluates whether the cash ﬂows of the modiﬁed
asset are substantially different.
If the cash
ﬂows
are substantially different, then the contractual rights to cash
ﬂows
from the original financial asset
are deemed to have expired. In this case, the original ﬁnancial asset is
derecognized (see above under Derecognition
other than due to substantial modiﬁcation) and a new ﬁnancial asset is
recognized at fair value plus any eligible
transaction costs. Any fees received as part of the
modiﬁcation
are accounted for as follows:
–
Fees that are considered in determining the fair value of the new asset and fees that represent reimbursement
of eligible transaction costs are included in the initial measurement of the asset;
–
Other fees are included in proﬁt or loss as part of the gain or loss on derecognition.
If cash ﬂows are modiﬁed when the borrower is in ﬁnancial difﬁculties, then the objective of the
modification is
usually to maximise recovery of the original contractual terms rather than to create a new asset with substantially
different terms. If the VUB Group plans to modify a ﬁnancial asset in a way that would
result in release of cash
ﬂows, then it ﬁrst considers whether a portion of the asset should be written off before the modiﬁcation takes place
(see below for write-off policy, note 4.1.5). This approach impacts the result of the quantitative evaluation and means
that the derecognition criteria are not usually met in such cases.
If the
modiﬁcation
of a
ﬁnancial
asset measured at amortized cost or FVOCI does not result in derecognition of the
ﬁnancial
asset, then the VUB Group
ﬁrst
recalculates the gross carrying amount of the
ﬁnancial
asset using the original
effective interest rate of the asset and recognises the resulting adjustment as a
modiﬁcation gain or loss in proﬁt or
loss. For ﬂoating
-rate as well
as ﬁxed
-
rate ﬁnancial assets where reset to market is expected,
the original effective
interest rate used to calculate the modiﬁcation gain or loss is adjusted to reﬂect current market terms at the
time of
the
modiﬁcation.
The effective interest rate is therefore altered. Any costs or fees incurred, and fees received as part of
the
modiﬁcation
adjust the gross carrying amount of the
modiﬁed
ﬁnancial
asset and are amortized over the
remaining term of the
modiﬁed ﬁnancial asset.
If such a modiﬁcation is carried out because of ﬁnancial difﬁculties of the borrower (note 4.1.2), then the gain or
loss is presented together with impairment losses.
Consolidated Financial Statements
57
3.4.6.
Offsetting
Financial assets and ﬁnancial liabilities are offset
, with
the net amount presented in the statement of ﬁnancial position
only when the VUB Group has a legally enforceable right to set off the amounts and it intends either to settle them
on a net basis or to realise the asset and settle the liability simultaneously.
Income and expenses are presented on a net basis only when permitted under IFRS, or for gains and losses arising
from a group of similar transactions such as in the VUB Group’s trading activity.
3.4.7.
Fair value measurement
‘Fair value’ is the price that would be received for the sale of an asset or paid for the transfer of a liability in an
orderly transaction between market participants at the measurement date in the principal on the main market, or if
such a market does not exist, the most advantageous market to which the VUB Group has access at that date. The fair
value of a liability reﬂects its non
-performance risk.
When one is available, the VUB Group measures the fair value of an instrument using the quoted price in an active
market for that instrument. A market is regarded as ‘active’ if transactions for the asset or liability take place with
sufﬁcient frequency and volume to provide pricing information on an ongoing
basis.
If there is no quoted price in an active market, then the VUB Group uses valuation techniques that maximise the use
of relevant observable inputs and minimise the use of unobservable inputs. The chosen valuation technique
incorporates all of the factors that market participants would take into account in pricing a transaction. The hierarchy
of valuation techniques is explained in note 5.
The best evidence of the fair value of a
ﬁnancial
instrument on initial recognition is normally the transaction price, i.e.
the fair value of the consideration given or received.
If the VUB Group determines that the fair value on initial recognition differs from the transaction price, and the fair
value is neither evidenced by a quoted price in an active market for an identical asset or liability, nor based on a
valuation technique for which any unobservable inputs are judged
insigniﬁcant
for
measurement, then the ﬁnancial
instrument is initially measured at fair value according to the model, adjusted to defer the difference between the
fair value on initial recognition and the transaction price. Subsequently, that difference is recognized
in proﬁt or loss
on an appropriate basis over the life of the instrument but no later than when the valuation is fully supported by
observable market data or when the transaction is closed out.
3.5.
Financial assets and ﬁnancial liabilities at fair value through proﬁt or loss
Financial assets and ﬁnancial liabilities at fair value through proﬁt or loss comprise ﬁnancial assets held for trading,
including derivative ﬁnancial instruments and ﬁnancial assets at fair value through proﬁt or loss.
3.5.1.
Financial assets and ﬁnancial liabilities held for trading
The VUB Group classiﬁes trading portfolio as ﬁnancial assets or ﬁnancial liabilities measured at fair value through
proﬁt or loss when they have been purchased or issued primarily for short
-
term proﬁt making through
trading
activities or form part of a
ﬁnancial
instruments portfolio that is managed together to achieve short-term profit.
Financial assets and ﬁnancial liabilities
held for trading are recorded and measured in the statement of
ﬁnancial
position at fair value.
Changes in fair value are recorded in proﬁt or loss
except for movements in fair value of
liabilities designated at FVTPL due to changes in the VUB Group’s own credit risk. Such changes in fair value are
recorded in the ‘Fair value gains and losses arising from the VUB Group‘s own credit risk related to derivative
liabilities’ and
are not reﬂected in
the proﬁt or loss. Interest earned or incurred on instruments designated at FVTPL
is presented in ‘Other interest income’. Dividend income from equity instruments measured at FVTPL is considered to
be incidental to the VUB Group’s trading operations and is recorded in
proﬁt
or loss as ‘Net trading result’ when the
right to the payment has been established.
Included in this
classiﬁcation
are debt securities, equities, short positions and customer loans that were acquired
principally for the purpose of their sale in the near term.
The VUB Group monitors changes in fair values daily
and recognises unrealised gains and losses in the proﬁt or loss
statement in ‘Net trading result’.
Consolidated Financial Statements
58
Derivative ﬁnancial instruments
In the normal course of business, the VUB Group is a party to contracts with derivative
ﬁnancial
instruments, which
require a very low initial investment compared to the notional value of the contract. The
derivative ﬁnancial
instruments used include forward rate agreements, foreign exchange and commodity forwards, interest rate, foreign
exchange and commodity swaps, interest rate, foreign exchange, equity options, cross currency swaps and futures.
The VUB Group also uses ﬁnancial instruments to hedge interest rate risk
and currency exposures associated with its
transactions in the
ﬁnancial
markets. They are accounted for as trading derivatives if they do not fully comply with
the deﬁnition of a hedging derivative as prescribed by IFRS. The VUB Group also acts as an intermediary provider of
these instruments to certain customers.
Derivative ﬁnancial instruments not used for hedge accounting purposes are initially
recognized and subsequently
re-
measured in the statement of ﬁnancial position at fair value as part of ‘Financial assets held
for trading’.
All derivatives are carried as assets when the fair value is positive and as liabilities when the fair value is negative.
Changes in the fair value of derivatives are included in ‘Net trading result’.
Fair values are obtained from quoted market prices. If such values are not available, discounted cash ﬂow models
and option pricing models are used instead. The fair values of derivative positions are calculated using standard
formulas and prevailing interest rates applicable for respective currencies available on the market at reporting dates.
Embedded derivatives
An embedded derivative is a component of a hybrid (combined) instrument that also includes a non-derivative host
contract, causing some of the cash
ﬂows
of the combined instrument vary in a way similar to a stand-alone derivative.
An embedded derivative alters
some or all of the cash ﬂows that
would otherwise be required by the contract,
adjusting them based on
a speciﬁed interest rate, ﬁnancial instrument price, commodity price, foreign exchange
rate, price or rate index, credit rating or credit index, or another variable. In the case of a non-
ﬁnancial variable,
the
modiﬁcation applies only if it is not speciﬁc to a party to the contract.
A derivative that is attached to a ﬁnancial
instrument, but is contractually transferable independently of that instrument, or has a different counterparty from
that instrument, is not an embedded derivative, but a separate ﬁnancial instrument.
The VUB Group assesses whether any embedded derivatives contained in a contract are required to be separated
from the host contract and accounted for as derivatives.
Derivatives may be embedded in another contractual arrangement (a host contract). The VUB Group accounts for
an embedded derivative separately from the host contract when:
–
The host contract is not an asset in the scope of International Financial Reporting Standard 9 Financial
Instruments (‘IFRS 9’);
–
The host contract is not itself held at FVTPL;
–
T
he terms of the embedded derivative would meet the deﬁnition of a derivative if they were contained in a
separate contract; and
–
The economic characteristics and risks of the embedded derivative are not closely related to the economic
characteristics and risks of the host contract.
Separated embedded derivatives are measured at fair value, with all changes in fair value recognized
in proﬁt or loss
in net trading result unless they form part of a qualifying cash ﬂow hedging relationship. Separated embedded
derivatives are presented in the statement of ﬁnancial position together with other derivatives.
3.5.2.
Financial assets at fair value through proﬁt or loss
Financial assets in this category are those that are not held for trading and are required to be measured at fair value
under IFRS 9, as they do not meet the requirements of the SPPI test.
Financial assets at fair value also comprise equity instruments not held for trading where the Bank did not choose to
classify investments at
FVOCI. Financial assets at fair value through proﬁt or loss are recorded in the statement of
ﬁnancial position at fair value. Changes in fair value are
recognized in ‘Net trading result’. Interest income is recorded
in ‘Other interest income’ and dividend income in ‘Net trading result’ according to the terms of the contract, or the
moment the right to payment has been established.
Consolidated Financial Statements
59
3.6.
Financial assets at fair value through other comprehensive income
3.6.1.
Debt instruments measured at fair value through other comprehensive income
The VUB Group
classiﬁes
debt instruments as measured at FVOCI under IFRS 9 if both of the following conditions
are met:
–
The instrument is held within a business model, the objective of which is achieved by both collecting contractual
cash ﬂows and selling ﬁnancial assets.
–
The contractual terms of the ﬁnancial asset meet the
requirements of the SPPI test.
Debt instruments at FVOCI are subsequently measured at fair value with gains and losses arising due to changes in
fair value recognized in equity. Interest income and foreign exchange gains and losses are recognized
in proﬁt or
loss in the same manner as for ﬁnancial assets at
amortized cost. The VUB Group applies the impairment
requirements to recognize and measure
a loss allowance for ﬁnancial assets that are measured at fair value through
other comprehensive income. However, the loss allowance is recognized in other comprehensive income and does
not reduce the carrying amount of the ﬁnancial asset in the statement of ﬁnancial position.
Where the VUB Group holds more than one investment in the same security, they are deemed to be disposed of on
a ﬁrst
-
in ﬁrst
-out basis. On derecognition, cumulative gains or losses previously recognized
in equity are reclassiﬁed
from equity to proﬁt or loss.
The fair value of debt instruments, for which an active market exists, and provided a market value can be estimated
reliably, is measured at quoted market prices. In circumstances where the quoted market prices are not readily
available, the fair value is estimated using the present value of future cash ﬂows.
In the case of debt instruments measured at fair value through other comprehensive income, impairment is assessed
based on the same criteria as ﬁnancial assets carried at
amortized cost. If, in a subsequent year, the fair value of a
debt instrument increases and the increase can be objectively related to an event taking place after the impairment
loss was recognized
in ‘Impairment losses’ in the statement of proﬁt or loss and other comprehensive income, the
impairment loss is reversed through the statemen
t of proﬁt or loss.
3.6.2.
Equity instruments measured at fair value through other comprehensive income
Upon initial recognition, the VUB Group occasionally elects to irrevocably classify some of its equity investments as
equity instruments at FVOCI when they meet the deﬁnition of Equity under IAS 32 Financial Instruments: Presentation
and are not held for trading. Such classiﬁcation is determined on an instrument
-by-instrument basis.
Gains and losses on these equity instruments are never recycled to proﬁt or loss. Dividends are
recognized
in proﬁt
or loss as ‘Net trading result’ when the right to the payment has been established, except when the VUB Group
beneﬁts from such proceeds as a recovery of part of the cost of the instrument
. In such a case, these gains are
recorded in OCI. Equity instruments at FVOCI are not subject to any impairment assessment.
3.7.
Financial assets and ﬁnancial liabilities at
amortized costs
Financial assets at amortized costs comprise balances due from banks and due from customers including debt
securities. Financial liabilities at amortized costs comprise balances due to banks, due to customers, subordinated
debt and debt securities in issue.
3.7.1.
Financial assets at amortized costs: Due from banks and Due from customers
The VUB Group only measures ‘Due from banks’ and ‘Due from customers’ at amortized cost if both of the following
conditions are met:
–
The ﬁnancial asset is held within a business model to collect contractual cash ﬂows
;
–
The contractual terms of the ﬁnancial asset give rise to cash ﬂows that
represent payments of principal and
interest on the principal amount outstanding
on speciﬁed dates
.
Due from banks
Due from banks include receivables from central banks with a maturity over 90 days, receivables from current
accounts in other than central banks, term deposits, loans provided and securities purchased from commercial banks.
Balances are presented at amortized cost including interest accruals less any impairment losses.
Consolidated Financial Statements
60
Due from customers
Due from customers balances comprise loans and advances and securities with ﬁxed or determinable
payments and
ﬁxed maturities. These receivables are recorded at
amortized cost less any impairment losses (note 11.2).
Impairment
The detailed description of policy is in the note 4.1.2.
The VUB Group writes off ‘Due from banks’ and ‘Due from customers’ when it determines that the loans and
advances are uncollectible. Loans and advances are written off against the impairment losses on
ﬁ
nancial assets
measured at amortized cost with the remaining part being written off
against proﬁt or loss reported under ‘Net
gain/(loss)
arising from the derecognition of ﬁnancial assets at
amortized cost‘. Any recoveries of loans written off
are credited to the same line in the statement of proﬁt or loss
upon receipt.
3.7.2.
Financial liabilities at amortized costs: Due to banks, Due to customers, Subordinated debt and Debt securities
in issue
Deposits, debt securities issued and subordinated liabilities are the VUB Group’s sources of debt funding.
The VUB Group classiﬁes capital instruments as ﬁnancial liabilities or equity instruments in accordance with the
contractual terms of the instruments.
Deposits, debt securities issued and subordinated liabilities are initially measured at fair value minus incremental
direct transaction costs, and subsequently measured at their amortized cost using the effective interest rate method.
Due to customers covers also lease liabilities.
3.8.
Repurchase and reverse repurchase agreements
Securities sold under sale and repurchase agreements (‘repo transactions’) remain as assets in the statement of
ﬁnancial position under the original caption
while liabilities from received loans are included in ‘Financial assets at
amortized cost: Due to banks’ or ‘Financial assets at amortized cost: Due to customers’.
Securities purchased under agreements to purchase and resell (‘reverse repo transactions’) are recorded only in the
off-balance sheet and loans provided are
reported in the statement of ﬁnancial position in
‘Cash, cash balances at
central banks’, ‘Financial assets at amortized cost: Due from banks’ or ‘Financial assets at amortized cost: Due from
customers’, as appropriate.
The difference between the purchase and sale price of securities fall under the category interest income or expense
and is deferred over the life of the agreement.
3.9.
Derivatives – Hedge accounting
When introducing IFRS 9, the VUB Group has elected to continue applying the requirements of IAS 39 instead of
those of IFRS 9.
Derivatives held for risk management purposes include all derivative assets and liabilities that are not
classiﬁed
as
trading assets or liabilities. Derivatives held for risk management purposes are measured at fair value in the statement
of ﬁnancial position in ‘Derivatives
– Hedge accounting’.
The VUB Group makes use of derivative instruments to manage exposures to interest rate risks, foreign currency risk,
inﬂation risk and credit risk including exposures arising from highly probable transactions. In
order to manage
individual risks, the VUB Group uses
hedge accounting for transactions which meet the speciﬁed criteria.
Consolidated Financial Statements
61
At the inception of the hedge relationship, the VUB Group formally documents the relationship between the hedged
item and the hedging instrument, including the nature of the risk, the objective and strategy for undertaking the
hedge and the method that will be used to assess the effectiveness of the hedging relationship.
When a hedging relationship is established, a formal assessment is carried out to ensure that the hedging instrument
will be highly effective in offsetting the designated risk in the hedged item. Hedges are formally assessed each month.
A hedge is regarded as highly effective if the changes in fair value or cash
ﬂows
attributable to the hedged risk during
the period for which the hedge is designated reach 80% to 125% offset.
In situations where the hedged item is treated as an expected transaction, the VUB Group assesses whether the
transaction is highly probable and
whether it represents an exposure to variability in cash ﬂows that will affect the
proﬁt and loss statement
.
Cash ﬂow hedges
For designated and qualifying cash
ﬂow
hedges, the gain or loss on the effective portion of the hedging instrument
is initially recognized
in other comprehensive income as ‘Cash ﬂow hedges’. The gain
or loss on the ineffective portion
of the hedging instrument is immediately recognised as gain or loss in the
statement of proﬁt or loss in ‘Net trading
result’.
When the hedged cash ﬂow affects proﬁt or loss, the gain or loss on the hedging instrument is reclassiﬁed from
other comprehensive income to proﬁt or loss as a reclassiﬁcation adjustment in ‘Net trading result’.
When a hedging
instrument expires, or is sold, terminated, exercised, or when a hedge no longer meets the criteria for hedge
accounting while
the hedged cash ﬂows are still probable
, any cumulative gain or loss that has been recognized in
other comprehensive income remains in equity separately
and is reclassiﬁed from other comprehensive income to
statement of proﬁt or loss as a reclassiﬁcation adjustment
at the moment the hedged expected transaction is
ultimately recognized. When an expected transaction is no longer expected to occur, the cumulative gain or loss that
was
reported in equity is immediately reclassiﬁed from other comprehensive income to statement of proﬁt
or loss as
a reclassiﬁcation
adjustment.
Fair value hedges
For designated and qualifying fair value hedges, the change in the fair value of a hedging derivative is recognized in
the proﬁt or loss
statement in ‘Net trading result’. Meanwhile, the change in the fair value of the hedged item
attributable to the risk hedged is recorded as part of the carrying value of the hedged item and is also recognized in
the statement of proﬁt or loss
under ‘Net trading result’.
In case of macro hedge, the change in the fair value of the hedged items attributable to the risk hedged is presented
separately as ‘Fair value changes of the hedged items in portfolio hedge of interest rate risk.’
If the hedging instrument expires or is sold, terminated or exercised, or where the hedge no longer meets the criteria
for hedge accounting, the hedge relationship is terminated. For hedged items recorded at amortized cost, the
difference between the carrying value of the hedged item on termination and the face value is amortized over the
remaining term of the original hedge using the effective interest rate (‘EIR’). If the hedged item is derecognized, the
unamortised fair value adjustment is recognized
immediately in proﬁt or loss when the item is
derecognized.
Speciﬁc policies for hedges affected by IBOR reform
The Phase 1 amendments
If a hedging relationship is directly affected by IBOR reform, then certain exceptions can apply (referred to as ‘the
Phase 1 amendments’) to the general hedge accounting policy.
All hedges affected by IBOR reform either matured or were discontinued. Therefore, the VUB Group ceased to apply
the respective Phase 1 amendments.
Consolidated Financial Statements
62
The Phase 2 amendments
Policies speciﬁc to non
-
contractually speciﬁed risk portions
:
When the VUB Group designates an alternative benchmark rate as a hedged risk, and the alternative benchmark rate
is a non-
contractually speciﬁed risk portion that is not separately identiﬁable at the
time of designation, the VUB
Group deems that the rate meets the separately identiﬁable criterion if it reasonably expects that the alternative
benchmark rate will be separately identiﬁable within a 24
-month period. The 24-month period applies on a rate-by-
rate basis and starts on the date when the VUB Group
ﬁrst
designates the alternative benchmark rate as a hedged
risk.
If the VUB Group subsequently expects that a non-
contractually speciﬁed alternative benchmark rate risk
component
will not be separately identiﬁable within the 24
-month period, it discontinues the prospective hedge accounting from
the date of that reassessment for all hedging relationships in which the alternative benchmark rate is designated as
a non-
contractually speciﬁed risk
portion.
Policies speciﬁc to cash ﬂow hedges
:
When the interest rate benchmark on which the hedged future cash ﬂows had been based is changed
to meet
requirements posed by the IBOR reform (in order to determine
whether the hedged future cash ﬂows are expected
to occur), the VUB Group deems that the hedging reserve recognized in OCI for that hedging relationship is based
on the alternative benchmark rate on which the hedged future cash ﬂows will be
determined.
3.10.
Property and equipment
Land and buildings are recognized at fair value based on regular, at least annual, valuations by external independent
specialized companies, reduced by building subsequent depreciation.
For buildings and land, the VUB Group uses the revaluation model for subsequent measurement. Management
determined that these constitute one class of asset based on the nature, characteristics and risks. The VUB Group
uses the income method, using market rents and yields as key inputs. Fair values are based on valuations performed
by an accredited independent valuer. The revaluation model aligned the book value to the current market value.
Level
3 revaluation was recognized due to signiﬁcant unobservable estimated valuation inputs.
The recoverable amount is determined with reference to the fair value less costs to sell or the value in use, if
determinable and if it is higher than fair value. For property and equipment other than buildings and land is assumed
that the carrying amount normally corresponds to the value in use, since it is determined by a depreciation process
estimated on the basis of the effective contribution of the asset to the production process and since the determination
of fair value is extremely subjective. The two values diverge and lead to impairment in case of damages, exit from the
production process or other similar non-recurring circumstances. The VUB Group measures buildings and land
according to the revaluation model. In this case, any impairment loss on a revalued asset must be treated as a decrease
in the revaluation up to the relevant amount after which any difference is taken to the income statement.
If the new fair value is higher than the carrying amount, the value of the asset on the balance sheet is increased
through other components of comprehensive income and accumulated in equity under the heading ‘Revaluation
surplus of buildings and land’. In case that an impairment loss was previously recorded in the income statement, the
reversal of this impairment is recorded in the income statement up to the amount previously recognized in the income
statement. If the new fair value is lower than the carrying amount, the decrease is recognized
in proﬁt or
loss
statement. The ISP Group chose to apply the elimination approach, which means that the accumulated depreciation
is eliminated against the gross carrying amount of the asset at revaluation date. The assets subject to the revaluation
model are depreciated based on their revalued value.
Signiﬁcant part of branch premises that the VUB Group uses is a result of sale and leaseback transactions. These
leasebacks are recognized as rights of use assets and lease liabilities. Average lease term of these premises was
estimated to four years.
All other property and equipment are recorded at historical cost less accumulated depreciation and impairment
losses. Acquisition cost includes the purchase price plus other costs related to acquisition such as freight, duties or
commissions. The costs of expansion, modernisation or improvements leading to increased productivity, capacity or
efﬁciency are capitalised. Repairs and renovations are charged to the proﬁt or loss
statement when the expenditure
is incurred.
Consolidated Financial Statements
63
Depreciation charge is calculated on a straight-line basis to allocate the cost of each asset to its residual value over
its estimated useful economic life as follows:

| Years
Buildings | 10 – 33
Equipment | 4 – 12
Other tangibles | 4 – 12

Land, assets under construction and art collections are not depreciated. The depreciation of the assets under
construction begins when the related assets are put into use.
The VUB Group checks its assets for impairment on annual basis. Where the carrying amount of an asset is greater
than its estimated recoverable amount, it is written down to this recoverable value.
Depreciation methods, useful lives and residual values are reassessed at the reporting date. Property and equipment
contain also right-of-use assets.
3.11.
Intangible assets
Intangible assets are recorded at historical cost less accumulated amortization and impairment losses. Amortisation
is calculated on a straight-line basis in order to amortise the cost of each asset to its residual value over its estimated
useful economic life as follows:

| Years
Software and Other intangible assets | 7 – 10

Amortisation methods, useful lives and residual values are reassessed at the reporting date.
Assets under development are not amortised. The amortization of the assets under development begins when the
related assets are put into use.
3.12.
Goodwill
Goodwill represents the excess of the cost of an acquisition over the fair value of the VUB Group’s share of the
identiﬁable assets, liabilities and contingent liabilities of the acquired subsidiary at the date of acquisition.
Goodwill is measured at cost less impairment, if any. Goodwill is tested for impairment annually or more frequently
if events or changes in circumstances indicate that the carrying amount may be impaired.
The VUB Group uses Capital Asset Pricing Model (‘CAPM’)
for impairment testing, using cash ﬂow projections based
on the most recent ﬁnancial budgets approved by senior management covering a budgeted ﬁve
-year period. The
discount rates applied to future cash ﬂow projections beyond the ﬁve
-year period are adjusted by the projected
growth rate. Both discount rates and growth rates are determined on ISP Group level speciﬁcally for the Slovak
market.
The calculation of the recoverable amount considers the following key assumptions:
–
Interest margins – the development of margins and volumes by product line,
–
Discount rates – based on CAPM,
–
Market share during the budget period,
–
P
rojected growth rates used to extrapolate cash ﬂows beyond the budget period,
–
Current local GDP,
–
L
ocal inﬂation rates.
The following rates are used by the VUB Group:

€ ’000 | 2025 | 2024
Pre-tax discount rate – cash flows | 15.87% | 14.71%
Pre-tax discount rate – terminal value | 16.23% | 15.70%
Projected growth rate | 4.33% | 4.44%

Consolidated Financial Statements
64
3.13.
Leasing
Leases in which the VUB Group is a lessor
In case of lease contracts based on which the VUB Group is acting as a lessor,
each of its leases is classiﬁed as either
operating or ﬁnance lease. Leases where a signiﬁcant portion of the risks and rewards of ownership are retained by
the lessor are classiﬁed as operating leases.
Finance leases
A lease is classiﬁed as a ﬁnance lease if it transfers substantially all the risks and rewards
associated with ownership
to the lessee. Examples of situations where the risks and rewards of ownership are considered as having been
transferred to the lessee are as follows:
–
The lease transfers ownership of the asset to the lessee by the end of the lease term,
–
The lessee has the option to purchase the asset at a price that is expected to be substantially lower than the fair
value at the date the option becomes exercisable for it to be reasonably certain, at the inception of the lease,
that the option will be exercised,
–
The lease term is for at least 3/4 of the economic life of the asset even if title is not transferred,
–
At the inception of the lease the present value of the minimum lease payments amounts to at least 90% of the
fair value of the leased asset, or
–
The leased assets are of such a specialized nature that only the lessee can use them without major modiﬁcations.
Lease classiﬁcation is made at the inception date and is reassessed only if there is a lease modiﬁcation.
At the commencement date, receivable from ﬁnance
leasing equal to the net investment in the lease is recognized
in the statement of ﬁnancial position in ‘Due from customers’.
Initial measurement of the lease payments included in the net investment in the lease:
–
Fixed payments, less any lease incentives payable;
–
Any residual value guarantees provided to the lessor by the lessee, a party related to the lessee or a third party
unrelated to the lessor that is ﬁnancially capable of discharging the obligations under the guarantee;
–
The exercise price of a purchase option if the lessee is reasonably certain to exercise that option; and
–
P
ayments of penalties for terminating the lease, if the lease term reﬂects the lessee exercising an option to
terminate the lease.
Subsequent measurement
Interest income is recognized
in proﬁt or loss statement in ‘Other interest income’ over the lease term using rate
implicit in the lease, which represents the discount rate that, at the inception of the lease, causes the aggregate
present value of the minimum lease payments and the unguaranteed residual value to be equal to the sum of the
fair value of the leased asset and any initial direct costs of the lessor.
The lease payments are applied against the gross investment in the lease and reduce both the principal and the
unearned ﬁnance income.
The detailed description of impairment of the net investment in the lease is described in the note 4.1.2.
Unguaranteed residual values are reviewed and estimated regularly in order to calculate the gross investment in the
lease. If there has been a reduction in the estimated unguaranteed residual value, income allocation over the lease
term is revised and any reduction in respect of amounts accrued is recognized immediately.
Operating leases
Recognition and measurement:
Lease payments from operating leases are recognized as income on a straight-
line basis in proﬁt or loss in ‘Other
operating income’.
Initial direct costs incurred in obtaining an operating lease are added to the carrying amount of the underlying asset
and this asset is being depreciated over the lease term on a straight-line basis.
Lease modiﬁcations:
In case of modiﬁcation to an operating lease a new lease is booked from the effective date of the modiﬁcation,
considering any prepaid or accrued lease payments relating to the original lease as part of the lease payments for
the new lease.
Consolidated Financial Statements
65
3.14.
Provisions
Provisions comprise litigations and claims, ﬁnancial guarantees and loan commitments.
Provisions for litigations and claims are recognized when the VUB Group has a present obligation (legal or
constructive) resulting from
a past event, and it is probable that an outﬂow of resources embodying economic
beneﬁts will be required to settle the obligation
, and a reliable estimate can be made of the amount of the obligation.
Financial guarantees are contracts that require the VUB Group to make speciﬁed payments to reimburse the holder
for a loss it incurs because a speciﬁed debtor fails to make a payment when it falls due, in accordance with the terms
of a debt instrument consisting of letters of credit, guarantees and acceptances.
Provisions for ﬁnancial guarantees are initially
recognized
in the ﬁnancial statements at fair value, being the premium
received. Subsequent to initial recognition, the Bank’s liability under each guarantee is measured at the higher of
the amount initially recognized less cumulative amortization recognized
in the statement of proﬁt or loss in ‘Fee and
commission income’ on a straight-line basis over the lifetime of the guarantee, and an ECL allowance.
ECL allowances for ﬁnancial guarantees are
recognized based on the
stage of ﬁnancial instrument (three
-stage
approach) which affects expected loss calculation for the ﬁnancial guarantee. Any increase or decrease in the
provision deriving from changes in ECL allowances relating to ﬁnancial guarantees is recorded in the
statement of
proﬁt or loss
under ‘Impairment losses’.
In the event
the VUB Group is called to fulﬁl
a guarantee, and the guarantee is paid to the holder of the guarantee,
the guarantee ceases to exist. Instead, a receivable against the counterparty for which the VUB Group issued the
guarantee is created and the former provision for ﬁnancial guarantees is converted into impairment losses allowance
on such receivable along with the record, if any, under ‘Impairment losses’.
Loan commitments are ﬁrm commitments to provide credit under pre
-
speciﬁed terms and conditions.
For loan
commitments the VUB Group also recognises Provisions based on stage of ﬁnancial instrument. Any increase or
decrease in the provision for loan commitments is recognized in
proﬁt or loss
under ‘Impairment losses’.
3.15.
Liabilities
for employee beneﬁts
The VUB Group’s obligation in respect of retirement and jubilee employee beneﬁts is the amount of future beneﬁt
that employees have earned in return for their service in the current and prior periods. Employee beneﬁt reserves
are disclosed in the statem
ent of ﬁnancial position in ‘Other liabilities’. All gains or losses in relation to the employee
beneﬁts are
recognized
in ‘Salaries and employee beneﬁts’.
‘
Severance and Jubilee beneﬁts
‘ are discounted to determine their present value. The discount rate is determined
with reference to yield curve of
Slovak government bonds with a ﬁfteen
-year duration, which represents the period
which is closest to the average beneﬁt duration. The calculation is performed using the Projected Unit Credit Method.
For the calculation, the VUB Group used an average turnover rate which is based on historical data on employees’
turnover at the VUB Group for the last three years. The average age-
speciﬁc turnover rate is calculated as the ratio
of number of terminations and the average number of employees. All employees are covered by the retirement and
jubilee employee beneﬁts program.
3.16.
Equity reserves
The reserves recorded in equity that are disclosed in the statement of ﬁnancial position include:
–
‘Revaluation surplus of buildings and land’ reserve which consists of the revaluation surplus of buildings and
land measured at fair value using a revaluation model.
–
‘Cash ﬂow hedges’ reserve which comprises the portion of the gain or loss on a hedging instrument in a cash
ﬂow hedge that is determined to be an effective hedge.
–
‘Financial assets at fair value through other comprehensive income’ reserve which comprises changes in the fair
value of ﬁnancial assets at FVOCI.
–
‘Translation of foreign operation’ reserve which is used to record exchange differences arising from the
translation of the net investment in foreign operations.
Consolidated Financial Statements
66
3.17.
Net interest income
Net interest income comprises interest income and interest expense calculated using both the effective interest
method and other methods. These are disclosed separately on the face of the income statement for both interest
income and interest expense to provide symmetrical and comparable information.
Interest income and expense are recognized
in the statement of proﬁt or loss on an accrual basis using the effective
interest rate method (EIR) for all ﬁnancial instruments measured at
amortized cost (note 3.7.1. and 3.7.2).
In case of a
hedging relationship (as deﬁned in note 3.9)
, interest from interest rate swap effectively replaces the
contractual interest rate of the hedged item and such interest is disclosed under in ‘Interest income calculated using
the effective interest method’.
The IBOR reform Phase 2 amendments permit a practical expedient for changes to the basis for determining
contractual cash ﬂows to be treated as changes to a ﬂoating rate of interest, provided certain conditions are met.
One of the conditions is that the change is necessary as a direct consequence of IBOR reform and that the transition
takes place on an economically equivalent basis.
Other interest income includes interest received on ﬁnancial assets at fair value through proﬁt or loss other than
interest on derivatives using the contractual interest rate and ﬁnance leases where the rate implicit in the lease is
being used.
Interest income/expense on all derivatives is recognized as a part of the fair value change in ‘Net trading result’.
Negative interest arising from ﬁnancial assets is presented in interest expense and negative interest arising from
ﬁnancial liabilities is presented in interest income.
According to the VUB Group´s accounting policy, the revision of the conditions of the instrument by the ECB is
considered as a change to a ﬂoating rate pursuant to par. B5.4.5 of IFRS 9, with a forward
-looking adjustment to
the interest rate, considering the fact that the ECB has the option to change i
nterest rates at its discretion in deﬁning
monetary policy rates. The interest is therefore recognised periodically based on the interest rate of the instrument
for each period as required by paragraph B5.4.5 of IFRS 9.
3.18.
Net fee and commission income
The VUB Group earns fee and commission income from a diverse range of financial services it provides to its
customers. Fee and commission income is recognized at an amount that reflects the consideration to which the
Bank expects to be entitled in exchange for providing the services.
Fee and commission income and expense such as up-front and commitment fees that are integral to the effective
interest rate on a financial asset or financial liability are included in the effective interest rate (see note 3.17).
Other fee and commission income arises on financial services provided by the VUB Group including account
maintenance, cash management services, brokerage services, administrative services regarding loans, investment
advice and financial planning, investment banking services, project finance transactions, asset management services,
factoring services, operating leasing and other. Fee and commission income and expense are recognized when the
corresponding service is provided. If a loan commitment is not expected to result in the drawdown of a loan, then
the related loan commitment fee is recognized on a straight-line basis over the commitment period.
The performance obligations, as well as the timing of their satisfaction, are identified and determined, at the
inception of the contract. The VUB Group’s revenue contracts do not contain multiple performance obligations.
The Bank has generally determined that it acts as the principal in its revenue arrangements, as it typically controls
the services before transferring them to the customer.
When the VUB Group provides a service to its customers, consideration is invoiced and is generally due immediately
upon satisfaction of a service provided at a point in time, or at the end of the contract period for a service provided
over time.
Consolidated Financial Statements
67
Nature and timing of the satisfaction of performance obligations, including key payment terms:

Current accounts | Fees for ongoing account management are charged to the customer‘s account on a monthly
| basis. The VUB Group sets the rates separately for retail and corporate banking customers in
| each jurisdiction on an annual basis.
Cards | Credit card and debit card fees relate to both fees for issuance of credit card for the period of
| card‘s validity as well as fees for specific transactions.
Payments and cash | Transaction-based fees for interchange and foreign currency transactions are charged to the
management | customer‘s account when the transaction takes place.
Loans | Loan-related services comprise mainly fees for overdrafts, which are recognized on a straight-
| line basis over the overdraft duration.
| They also include other servicing fees, including finance leases, which are charged on a
| monthly basis, and are based on fixed rates reviewed annually by the VUB Group.
Indirect deposits | These fees mainly relate to provision of the Bank’s retail network for the mediation of
| investments into funds. These fees are paid to the VUB Group by Eurizon Asset Management
| Slovakia , správ. spol., a.s. Since the Bank does not have any ongoing performance obligation
| related to these fees, they are recognized in full when charged.
Insurance | The VUB Group provides insurance mediation along with selling its products. Except for life
| insurance mediation, only an aliquot part of commission is sent by the insurance company on
| a monthly basis. Therefore, the VUB Group only recognises an aliquot part of commission as
| income with the passage of time. In case the client cancels insurance contract with the
| insurance company, the insurance company stops paying the aliquot part of the commission,
| and the VUB Group therefore stops recognising these fees. The VUB Group is not liable to
| return this aliquot part of commissions recognized in fees to the insurance company.
| Regarding life insurance mediation the VUB Group is exposed to clawbacks if a client cancels
| the insurance contract within certain periods. The VUB Group calculated effect of IFRS 15
| impact and evaluated this impact as non-material and continues to recognise income on these
| fees as the related mediation service is provided.
Trade finance, Structured | Fees for loan commitments which are not expected to result in the draw-down of a loan are
finance | recognized on a straight-line basis over the commitment period.
| Administration of a loan syndication, execution of client transactions with ex-changes and
| securities underwriting, charges for premature termination of loans and other are charged
| when a transaction takes place.
Factoring | Services related to factoring include:
| - Facility commitment, where fee is recognized on a straight-line basis over the commitment
| period;
| - Invoice processing fee, where fixed amount for each processed invoice is charged;
| - Factoring fee, where fee represent a percentage on a total receivable amount factored.

Revenue recognition under IFRS 15:

Current accounts | Revenue from account service and servicing fees is recognized over time as the services are
| provided.
Cards | Revenue from card issuance is recognized over time as the services are provided.
| Revenue related to transactions is recognized at the point in time when the transaction takes
| place.
Payments and cash | Revenue related to transactions is recognized at the point in time when the transaction takes
management | place.
Loans | Overdraft fee is recognized on a straight-line basis over the overdraft duration.
| Revenue related to transactions, including finance leases, is recognized at the point in time
| when the transaction takes place.
Indirect deposits | Revenue related to transactions is recognized at the point in time when the transaction takes
| place.
Insurance | Revenue from insurance mediation services is recognized over time for the duration of
| contract, except for life insurance mediation where service fee is recognized when service is
| provided and clawbacks are recognized when they occur.
Trade finance, Structured | Loan commitment fee is recognized on a straight-line basis over the commitment period.
finance | Revenue related to transactions is recognized at the point in time when the transaction takes
| place.
Factoring | Facility fee is recognized on a straight-line basis over the commitment period.
| Revenues related to invoice processing and factoring fee are recognized at the point in time
| when the transaction takes place.

Consolidated Financial Statements
68
3.19.
Net trading result
‘Net trading result’ includes gains and losses arising from purchases, disposals and changes in the fair value of
ﬁnancial assets and ﬁnancial liabilities including securities and derivative instruments. It also includes the result of all
foreign currency transactions.
3.20.
Current and deferred income tax, special levy and other taxes
Income tax is calculated in accordance with the regulations of the Slovak Republic and other jurisdictions in which
the VUB Group operates.
Income tax expense is recognized at each time interval during the accounting year based on the best estimate of the
weighted average annual income tax rate expected for the entire accounting year. In the event of a change in the
estimate of the annual income tax rate, the accrued amount of income tax costs for one of the periods during the
accounting year may be adjusted in the subsequent period of that accounting year.
With effect from January 2024, a new type of special levy for the banking sector came into force in Slovakia. For the
year 2025, the amount of the special levy is set at 24.96% of the proﬁt before tax, and in the following years, it will
gradually decrease to 15% in 2027. From 2028, banks will be subject to the standard rate of the special levy on
business in regulated sectors. The special levy for regulated entities is a tax-deductible expense.
Deferred income tax assets and liabilities are recognized, using the balance sheet method, for all temporary
differences arising between the carrying amounts of assets and liabilities and their tax bases. Expected tax rates,
applicable for the periods when assets and liabilities are realised, are used to determine deferred tax.
The VUB Group is also subject to various indirect operating taxes, which are included in ‘Other operating expenses’.
Consolidated Financial Statements
69
4.
Financial and operational risk management
This note presents information about the VUB Group’s exposure to each of the above risks, the VUB Group’s objectives,
policies and processes for measuring and managing risk.
The Management Board is the statutory body governing the executive management of the VUB Group, and has
absolute authority over all matters concerning risk. The Management Board has primary responsibility for the creation
and dissolution of risk related governance bodies. The primary governance bodies overseeing risk issues are:
–
Assets and Liabilities Management Committee (‘ALCO’),
–
Credit Risk Governance Committee (‘CRGC’),
–
Operational Risk Committee (‘ORC’).
The Management Board delegates its risk authority to these governance bodies through statutes identifying
members of the governance bodies, competencies and responsibilities of the members. The competency of each
governance body is established in relevant Charters.
The VUB Group’s risk management policies were established to identify and analyse the risks faced by the VUB Group,
to set appropriate risk limits and controls and to monitor risks and adherence to limits. Risk management policies
and systems are reviewed regularly to reﬂect changes in market condit
ions, products and services offered. The VUB
Group, through its training and management standards and procedures, aims to develop a disciplined and
constructive control environment in which all employees understand their roles and obligations. The Internal Audit
Department of VUB Group is responsible for monitoring compliance with VUB Group's risk management policies and
procedures and for reviewing the adequacy of the risk management framework to which VUB Group is exposed. Internal
audit performs both regular and ad-hoc reviews of control mechanisms and processes in the area of risk management.
4.1.
Credit risk
Credit risk refers to the potential
ﬁnancial
loss to the VUB Group if a customer or counterparty to a
ﬁnancial
instrument fails to meet its contractual obligations. This risk primarily stems from the Group’s loans and advances to
customers and banks, as well as its investment securities. For risk management reporting purposes, the VUB Group
considers and consolidates all elements of credit risk exposure (such as individual obligor default risk, country and
sector risk). For risk management purposes, the credit risk arising on trading securities is managed independently,
but reported as a component of market risk exposure.
The Credit Risk Charter (‘CRC’) establishes the guidelines for measurement, control and management of credit risk
by deﬁning the legal framework, main responsibilities, policies and methodologies that support the credit risk
management process of VUB.
More speciﬁcally, CRC deﬁnes both the general and speciﬁc (retail, corporate) credit risk requirements for applied
methodologies and procedures, and includes, as separate sections, the policies governing the key aspects of the VUB
Group’s credit risk management process:
–
Authorised Approval Authority,
–
Collateral Management Policy,
–
Provisioning Policy,
–
Credit Concentration Limits,
–
Default Deﬁnition,
–
Risk Management Client Segmentation Policy,
–
Corporate Credit Policy, Retail Credit Policy,
–
Retail and Corporate Remedial Management and Collections.
Consolidated Financial Statements
70
4.1.1.
Management of credit risk
The Risk Management Division was established within the VUB Group as a Control Unit managed by the Chief Risk
Officer, who is a member of the VUB Group’s Management Board. The Risk Management Division is organisationally
structured to provide support to the Business Units, as well as to report on credit, market and operational risks to the
Supervisory Board and Management Board. The Risk Management Division is responsible for overseeing VUB Group’s
credit risk including:
–
The development of credit risk strategies, policies, processes and procedures covering rules for credit assessment,
collateral requirements, risk grading and reporting;
–
Setting limits for the concentration of exposure to counterparties, related parties, countries and total assets and
monitoring compliance with those limits;
–
Establishment of the authorisation structure for the approval and renewal of credit facilities. Authorisation limits
are set in the CRC;
–
Credit risk assessment according to deﬁned policy;
–
Monitoring of quality portfolio performance and its compliance with set limits (regulatory, internal). Regular
reports are provided to the Management Board and the CRC on the credit quality of the VUB Group’s portfolios;
–
Development, maintenance and validation of scoring and rating models – both application and behavioural;
–
Development, maintenance and back-testing of impairment loss models.
4.1.2.
Impairment losses
The VUB Group establishes an allowance for impairment losses, which represents its ECL in its loan portfolio.
If there is evidence of impairment for any individually signiﬁcant client of the VUB Group, such as a breach of
contract, problems with repayments or collateral, the VUB Group transfers such a client to management of the
Recovery Department for collection activities. Clients exceeding materiality thresholds (EUR 500 thousand, and EUR
100 thousand for clients of VUB and VUB Operating Leasing, respectively) are considered to be individually impaired.
For collective impairment (other than individually signiﬁcant client), the VUB Group uses historical
evidence of
impairment and forward-looking information on a portfolio basis, primarily based on the payment discipline of the
clients.
Rules for
identiﬁcation
of
signiﬁcant
clients and methodology for calculation are set in the Credit Risk Charter or
stated in the Provisioning Policy procedure.
The individual assessment of exposures is based on the detailed review and analysis of the borrower’s situation.
The individual assessment, formulated analytically for each exposure, shall be based on the detailed and
comprehensive review of all elements that are available.
Inputs, assumptions and techniques used for estimating impairment
The calculation of ECL on a collective basis is based on particular regulatory segment, exposure at default (‘EAD‘),
probability of default (‘PD’), loss given default (‘LGD’), credit conversion factor (‘CCF’). For each segment were
developed models for such risk parameters. These models are regularly reviewed by the team responsible for credit
risk model development,
ofﬁce
Internal Validation and Department Internal Audit.
The methodology of risk parameters used by ECL calculation is compliant with the ISP Group methodology provided
by the Parent Company.
For PD models of the portfolios where the Bank uses internal models, the advanced approach is used.
For the portfolios where it is unable to follow this approach (unavailability of internal model, low number of
observations, low number of defaults, unavailability of macroeconomic model for the portfolio), the Bank follows a
simpliﬁed approach, e.g. ﬁnal values provided from the Parent Company, notching criteria, using the country rating
and LGD, etc.
The counterparties with low number of observations and a low number of observed defaults, for which the Bank
was unable to create reliable migration matrices or develop the macroeconomic satellite models for predicting
default rates, a
re deﬁned as the Low
Default Portfolio. The parameters for these portfolios are obtained from the
Parent Company.
EAD is calculated separately for amortizing and non-amortizing products. EAD for amortizing products is based on
the repayment plans, while EAD for non-amortizing products is calculated using Credit Conversion Factor (CCF).
Currently, the Bank uses CCF models only for Retail Credit Cards, Retail Overdrafts and Corporate. For all other
segments, regulatory CCF values are used.
Consolidated Financial Statements
71
Financial assets exposed to credit risk, broken down by institutional sector based on the ESA 2010 methodology:

| 2025 | 2024
| Gross | Impairment | Net | Gross | Impairment | Net
€ ’000 | amount | losses | amount | amount | losses | amount
Financial assets at AC |  |  |  |  |  |
Due from banks | 219 786 | (6 711) | 213 075 | 323 807 | (5 869) | 317 938
Due from customers |  |  |  |  |  |
Financial corporations | 1 141 417 | (3 143) | 1 138 274 | 1 319 636 | (488) | 1 319 148
Non-financial corporations | 6 925 253 | (147 064) | 6 778 189 | 6 907 617 | (139 343) | 6 768 274
Retail | 12 127 781 | (207 747) | 11 920 034 | 11 587 892 | (198 957) | 11 388 935
Public administration | 1 992 590 | (1 765) | 1 990 825 | 981 052 | (1 457) | 979 595
Total due from customers | 22 187 041 | (359 719) | 21 827 322 | 20 796 197 | (340 245) | 20 455 952
Total financial assets at AC | 22 406 827 | (366 430) | 22 040 397 | 21 120 004 | (346 114) | 20 773 890
Financial assets at FVOCI |  |  |  |  |  |
– debt securities | 1 440 267 | (270) | 1 439 997 | 1 489 641 | (212) | 1 489 429
Loan commitments |  |  |  |  |  |
and financial guarantees | 5 825 301 | (19 997) | 5 805 304 | 5 682 652 | (23 169) | 5 659 483

Staging methodology
The three-stage approach is based on changes in credit quality following the initial recognition:
–
Stage 1 includes ﬁnancial instruments that have not
experienced
a signiﬁcant
deterioration in credit quality since
initial recognition or that have low credit risk at the reporting date.
–
Stage 2 includes ﬁnancial instruments that have experienced a signiﬁcant
deterioration in credit quality since
initial recognition but that do not have objective evidence of a credit loss event.
–
Stage 3 includes ﬁnancial assets
for which there is objective evidence of impairment at the reporting date.
The VUB Group implemented internal rules using signiﬁcant days past due, signiﬁcant increase of PD, forbearance
measures, early warning system, proactive credit management (‘PCM’) process, non-performing categories to assess
correct stage for expected loss calculation. These indicators are described in more detail below.
The VUB Group’s classiﬁcation of exposures into the stages is based on the following criteria:

STAGE 1 | STAGE 2 | STAGE 3
Performing exposures with DPD less | Performing non-defaulted contracts | Non-performing Past Due
than 30 | with more than 30 days past due |
| Forborne performing exposures | Non-performing Unlikely to Pay
| Performing exposures under PCM | Non-performing Doubtful
| Performing exposures with significant |
| increase in PD |

In general, the following rules apply:
–
At origination ﬁnancial instruments are classiﬁed in Stage 1, except instruments which are credit
-impaired at the
date of acquisition, which are classiﬁed in the relevant stage;
–
If there is not enough information to determine if credit has deteriorated signiﬁcantly since origination, a ﬁnancial
instrument is classiﬁed into Stage 2.
As of 31 December 2025,
the Bank did not classify any ﬁnancial assets as Purchased or Originated Credit Impaired
(‘POCI‘).
Stage 2 criterion: Performing exposures with more than 30 past due days
There is a rebuttable presumption that the credit risk on a fi
nancial asset has increased signiﬁcantly since initial
recognition when contractual payments are more than 30 days past due.
Stage 2 criterion: Forborne performing exposures
Forborne status for performing exposures is identiﬁed as another criterion of credit deterioration since
it represents
concessions towards a client facing, or about to face,
difﬁculties in meeting its ﬁnancial commitments.
Forborne
performing exposures represent Forborne (originally) performing and Forborne performing stemming from Non-
performing. The minimum probation period for these contracts is 24 months. After this period, the contract might
migrate to Stage 1 if it meets exit criteria from Forborne classiﬁcation (for
example there is not more than 30 DPD,
contract is Performing or counterparty has repaid more than
signiﬁcant amount of its debt since entering to
Forborne).
Consolidated Financial Statements
72
Stage 2 criterion: Performing exposures under proactive credit management
Exposures under
PCM are classiﬁed in Stage 2 since they can be considered as exposures that have deteriorated
signiﬁcantly in credit quality since
their recognition.
Stage 2 criterion: Performing exposures with signiﬁcant increase in PD
A signiﬁcant increase of PD between origination (or initial recognition) and reporting date is used as
indicator of
credit quality deterioration: ‘At each reporting date, an entity shall assess whether the credit risk on a ﬁnancial
instrument has increased signiﬁcantly since initial recognition. When making the assessment, an entity shall use the
change in th
e risk of a default occurring over the expected life of the ﬁnancial instrument.’ PD at origination is used
solely for the purposes of staging.
This criterion is applied to all the portfolios. The thresholds for each portfolio can vary. In order to assess whether
credit risk has increased signiﬁcantly since the origination, it is necessary to compare Lifetime PD between origination
and reporting date.
This criterion is set individually for each portfolio; however, the main features of the methodology are consistent
across portfolios.
The proper setting of PD threshold is the core of this criterion. The Group methodology states the PD threshold could
be different based on portfolio/model, residual maturity, rating class or other potential drivers. Indeed, the cumulative
PDs and their relative differences (between some two rating grades) are changing very swiftly with increasing residual
maturity. That’s why the one common threshold for all maturities would not lead to proper staging. The differentiation
of thresholds between rating classes is important; generally, a lower rating corresponds to a lower threshold.
Stage 3 criterion
Stage 3 ﬁnancial assets are considered credit impaired.
This happens when one or more events that have a
detrimental impact on the estimated future cash ﬂows have occurred.
Evidence that a ﬁnancial asset is credit
-impaired includes the following observable data:
–
Signiﬁcant ﬁnancial difﬁculty of the borrower or issuer;
–
A breach of contract such as a default or past due event;
–
The restructuring of a loan or advance by the VUB Group on terms that the VUB Group would not consider
otherwise;
–
It is becoming probable that the borrower will enter bankruptcy or another form of
ﬁnancial reorganisation; or
–
The disappearance of an active market for a security because of ﬁnancial difﬁculties.
A loan that has been renegotiated due to a deterioration in the borrower’s condition is usually considered to be
credit-impaired,
unless there is evidence that the risk of not receiving the contractual cash ﬂows has reduced
signiﬁcantly and there are no other indicators of impairment.
Staging criteria for debt securities
Staging process for bonds is performed in parallel with the staging of loans. The criterion used to assess whether
the credit quality of a
bond has deteriorated signiﬁcantly since origination is
the comparison of Lifetime PDs.
The following criteria are approved for each stage for debt securities:

STAGE 1 | STAGE 2 | STAGE 3
Bonds with no significant credit quality | Bonds with significant increase in PD | Defaulted bonds
deterioration | since origination |
Investment grade bonds (Low Credit |  |
Risk Exemption rule valid only for |  |
FVOCI Bonds for First Time Adoption of |  |
IFRS 9 (‘FTA’)) |  |

In addition to the above-mentioned criteria, the following rules should be followed for Stage Assignment:
–
A
t origination ﬁnancial instruments are classiﬁed in Stage 1;
–
If there is not enough information to determine whether
credit has deteriorated signiﬁcantly since origination, a
ﬁnancial instrument is classiﬁed into Stage 2.
Consolidated Financial Statements
73
Staging criteria for Low Default Portfolio and Intragroup exposures
Low Default Portfolio consists of exposures with the following parties:
–
Sovereign (Central Banks, Governments, Municipalities, Public Sector Entities);
–
Institutions (Banks, and Other Non-banking Financial Institutions);
–
Large Corporate (Corporate with turnover more than EUR 500 million).
Intragroup exposures are exposures with the following parties:
–
Parent Company;
–
Bank’s own subsidiaries;
–
Other ISP Group subsidiaries.
Given their particular nature (exposures are within the Bank´s own group and have a low risk
proﬁle),
intragroup
transactions are always classiﬁed as Stage 1 with a 12
-month ECL.
Since the models for Low Default Portfolio were developed by the Parent Company, the staging rules for Low Default
Portfolio and Intragroup exposures are set by the Parent Company for loans and bonds and valid at ISP Group level.
Exposures are
classiﬁed
to Stage 2 based on the
signiﬁcant
increase of the credit risk criterion measured by Lifetime
PD comparison. This criterion for Low Default Portfolio is
deﬁned
based on
the speciﬁc rating and residual maturity
of exposure. Thresholds are provided by the Parent Company. The thresholds are applied in the same way as
described above in Stage 2 criterion: Performing exposures with signiﬁcant increase in PD.
Expected credit loss calculation
Stage 1
The Expected Loss for exposures in Stage 1 is calculated based on 1-year risk parameters (i.e., PD, LGD and EAD). In
the calculation for positions expiring during the ﬁrst
year, in order to avoid the counting of an entire PD on yearly
basis, and to consider the real expiration date, PD can be adjusted appropriately. For the transactions without a
maturity date, it is conservatively assumed that they are subjected to annual review, and their maturity is assumed
to be equal to one year.
Stage 2
The Expected Loss for exposures in Stage 2 is based on a lifetime approach considering the residual maturity with
respect to the reporting date using appropriate cumulative values of risk parameters. In the calculation of Expected
Credit Loss for position expiring during the ﬁrst year in order to avoid the counting of an entire PD on yearly basis
and to consider the real expiration date, PD should be adjusted. For the transactions without a maturity date, it is
assumed that they are subjected to an annual review and their maturity is assumed to be equal to one year.
Stage 3
The VUB Group decided to determine the provision for Non Performing exposures (transactions in Stage 3) as IAS 39
provision including an Add-on, which estimation is based on forward looking elements, increasing the current level
of coverage on NPLs.
Incorporation of forward-looking information
In order to incorporate forward-looking information, the VUB Group follows the methodology provided by the Parent
Company by both PD and LGD models. The predicted values of macro variables used in the models are delivered by
Parent Company.
PD models incorporate forward-looking information by using the Base scenario from the internal satellite models.
Other scenarios are incorporated in the form of “add-on”. Add-
on is calculated as a combination of ﬁnal PD values
calculated for all three scenarios for 3 upcoming years.
The VUB Group uses internally developed satellite models for the prediction of default rate for various segments.
These models are based on relevant macroeconomic variables. The output of these models includes the base scenario
model along with other scenarios that are used to calculate the add-on.
For LGD models, the Bank uses internally developed macroeconomic satellite models for inclusion of forward-looking
information into LGD parameter. The outputs of those models are the predicted values of loss given default for base
scenario increased by add-on, which incorporates the other scenarios. For NPL positions, the add-on is derived only
from the baseline and worst scenario and applied on TTC LGD value.
The VUB Group carries out recalibration or update of scenarios of satellite models on a regular basis.
Consolidated Financial Statements
74
4.1.3.
Non-
performing loan classiﬁcation
The VUB Group considers a ﬁnancial asset to be in
non-performing status in compliance with the Commission’s
Implementing Regulation (EU) No 680/2014 and its further amendments (Implementing Technical Standards, ‘ITS’)
when:
–
The borrower is unlikely to pay its credit obligations to the VUB Group in full, without recourse by the VUB
Group to actions such as realising security (if any is held); or
–
The borrower is more than 90 days past due on any material credit obligations to the VUB Group.
The VUB Group uses the deﬁnitions of non
-performing loans derived from the Harmonisation project. The
Harmonisation project was driven by Intesa Sanpaolo in order to unify the deﬁnitions and categories
of non-
performing loans across the foreign subsidiaries of the ISP Group. The deﬁnition of non
-performing loans, which
comprise three
classiﬁcation
categories (past due, unlikely to pay, doubtful), is based on delinquency (days past due)
and judgmental criteria for the doubtful and unlikely to pay categories. In case of the past due category, DPD and
materiality thresholds of borrower are taken into account.
The description of the classiﬁcation categories of loans is as follows:

Classification category | Description
Doubtful | Exposures to borrowers being in a state of insolvency (although not yet legally), or in a de
| facto equivalent status, regardless of any loss forecasts made by the Bank.
Unlikely to pay | Exposures to borrowers assessed as improbable to thoroughly meet their credit obligations
| without recourse to actions such as the enforcement of guarantees/collateral.
Past due | Exposures other than those classified as doubtful or unlikely to pay that, as at the reporting
| date, are past due (DPD methodology above) for over 90 days.
Performing | All exposures that are not classified as doubtful, unlikely to pay or past due.

For the category Unlikely to pay following qualitative indicators are taken into account:
–
Borrowers facing difﬁculties in meeting payment obligations in a timely manner (thus exposed to their creditors’
tolerance), despite the conﬁdent expectation of positive future operating cash ﬂows;
–
Borrowers under negotiations with the Bank for deﬁning an out of Court restructuring/settlement agreement;
–
Borrowers which signed out of Court restructuring/settlement agreements and that are regularly servicing their
ﬁnancial obligations
–
Borrowers whose credit quality indicators signiﬁcantly worsened and where future cash ﬂows are not expected
to fully service the debt toward the Bank;
–
Serious difﬁculties in borrower’s business (additional equity required, liquidity seriously stretched)
.
For category Doubtful following qualitative indicators are taken into account:
–
If the borrower is under voluntary dissolution or under any legally binding liquidation, without possibility to
operate on ‘going concern basis‘;
–
If the Court already ordered the legal liquidation, even if the borrower’s operations are not suspended under
the legal procedures;
–
If according to any public Registry or by Court order the borrower ceases to exist as legal entity;
–
If the borrower has been registered (has to be registered) on the Fraud/Black List;
–
Borrowers from whom
expected cash ﬂows will not be generated from
through operations, but rather through
the enforcement of collateral/guarantees (‘gone concern’ approach);
–
Borrowers (typically, Individuals) against whom the Bank initiates receivership or enforcement proceedings.
Non-performing status is carried out at borrower level following the united rules of the Parent Company.
Consolidated Financial Statements
75
The following table describes the VUB Group’s credit portfolio in terms of classiﬁcation categories:

2025 |  |  |  |  |
€ ’000 | Performing | Past due | Unlikely to pay | Doubtful | Total
Financial assets at AC |  |  |  |  |
Due from banks | 182 675 | - | 37 111 | - | 219 786
Due from customers |  |  |  |  |
Financial corporations | 1 138 868 | - | 2 530 | 19 | 1 141 417
Non-financial corporations | 6 785 363 | 10 744 | 67 730 | 61 416 | 6 925 253
Retail | 11 861 601 | 50 164 | 69 434 | 146 582 | 12 127 781
Public administration | 1 992 590 | - | - | - | 1 992 590
Total due from customers | 21 778 422 | 60 908 | 139 694 | 208 017 | 22 187 041
Gross amount | 21 961 097 | 60 908 | 176 805 | 208 017 | 22 406 827
Impairment losses | (130 330) | (25 274) | (67 244) | (143 582) | (366 430)
Net amount | 21 830 767 | 35 634 | 109 561 | 64 435 | 22 040 397
Financial assets at FVOCI – |  |  |  |  |
debt securities | 1 440 267 | - | - | - | 1 440 267
Loan commitments |  |  |  |  |
and financial guarantees | 5 801 588 | 1 669 | 18 099 | 3 945 | 5 825 301

2024 |  |  |  |  |
€ ’000 | Performing | Past due | Unlikely to pay | Doubtful | Total
Financial assets at AC |  |  |  |  |
Due from banks | 268 086 | - | 55 721 | - | 323 807
Due from customers |  |  |  |  |
Financial corporations | 1 319 618 | - | - | 18 | 1 319 636
Non-financial corporations | 6 760 670 | 9 600 | 88 891 | 48 456 | 6 907 617
Retail | 11 367 917 | 41 397 | 51 325 | 127 253 | 11 587 892
Public administration | 981 052 | - | - | - | 981 052
Total due from customers | 20 429 257 | 50 997 | 140 216 | 175 727 | 20 796 197
Gross amount | 20 697 343 | 50 997 | 195 937 | 175 727 | 21 120 004
Impairment losses | (142 194) | (23 382) | (62 868) | (117 670) | (346 114)
Net amount | 20 555 149 | 27 615 | 133 069 | 58 057 | 20 773 890
Financial assets at FVOCI – |  |  |  |  |
debt securities | 1 489 641 | - | - | - | 1 489 641
Loan commitments |  |  |  |  |
and financial guarantees | 5 665 118 | 1 335 | 12 918 | 3 281 | 5 682 652

Consolidated Financial Statements
76
The table below shows the three-
stage approach based on changes in credit quality by days past due for all ﬁnancial
assets exposed to credit risk.

2025 | Gross amount | Impairment losses | Net amount
€ ’000 | Stage 1 | Stage 2 | Stage 3 | Stage 1 | Stage 2 | Stage 3 |
Financial assets at AC |  |  |  |  |  |  |
Due from banks |  |  |  |  |  |  |
No delinquency | 182 675 | - | - | - | - | - | 182 675
Over 181 days | - | - | 37 111 | - | - | (6 711) | 30 400
| 182 675 | - | 37 111 | - | - | (6 711) | 213 075
Due from customers |  |  |  |  |  |  |
Financial corporations |  |  |  |  |  |  |
No delinquency | 1 078 462 | 58 735 | - | (475) | (351) | - | 1 136 371
1 – 30 days | 1 671 | - | - | (3) | - | - | 1 668
91 – 180 days | - | - | 2 530 | - | - | (2 307) | 223
Over 181 days | - | - | 19 | - | - | (7) | 12
| 1 080 133 | 58 735 | 2 549 | (478) | (351) | (2 314) | 1 138 274
Non-financial corporations |  |  |  |  |  |  |
No delinquency | 5 906 110 | 814 682 | 64 285 | (15 276) | (51 461) | (26 724) | 6 691 616
1 – 30 days | 30 895 | 26 626 | 11 111 | (447) | (1 997) | (7 530) | 58 658
31 – 60 days | 803 | 4 315 | 1 636 | (15) | (494) | (371) | 5 874
61 – 90 days | - | 1 541 | 995 | - | (136) | (240) | 2 160
91 – 180 days | - | 303 | 7 299 | - | (8) | (3 654) | 3 940
Over 181 days | - | 88 | 54 564 | - | (14) | (38 697) | 15 941
| 5 937 808 | 847 555 | 139 890 | (15 738) | (54 110) | (77 216) | 6 778 189
Retail |  |  |  |  |  |  |
No delinquency | 11 031 355 | 597 834 | 48 523 | (8 702) | (31 185) | (16 242) | 11 621 583
1 – 30 days | 67 579 | 126 469 | 22 283 | (745) | (11 599) | (6 858) | 197 129
31 – 60 days | 2 287 | 23 122 | 18 779 | (20) | (3 349) | (5 998) | 34 821
61 – 90 days | 294 | 9 261 | 17 164 | (2) | (1 794) | (5 788) | 19 135
91 – 180 days | 7 | 2 901 | 38 751 | (1) | (422) | (17 715) | 23 521
Over 181 days | 24 | 468 | 120 680 | (1) | (68) | (97 258) | 23 845
| 11 101 546 | 760 055 | 266 180 | (9 471) | (48 417) | (149 859) | 11 920 034
Public administration |  |  |  |  |  |  |
No delinquency | 1 961 304 | 28 753 | - | (1 259) | (504) | - | 1 988 294
1 – 30 days | 2 477 | 13 | - | (1) | (1) | - | 2 488
31 – 60 days | - | - | - | - | - | - | -
61 – 90 days | - | 43 | - | - | - | - | 43
| 1 963 781 | 28 809 | - | (1 260) | (505) | - | 1 990 825
Total due from customers | 20 083 268 | 1 695 154 | 408 619 | (26 947) | (103 383) | (229 389) | 21 827 322
Total financial assets at AC | 20 265 943 | 1 695 154 | 445 730 | (26 947) | (103 383) | (236 100) | 22 040 397
Financial assets at FVOCI |  |  |  |  |  |  |
– debt securities |  |  |  |  |  |  |
No delinquency | 1 440 267 | - | - | (270) | - | - | 1 439 997
Loan commitments |  |  |  |  |  |  |
and financial guarantees |  |  |  |  |  |  |
No delinquency | 5 150 440 | 651 148 | 23 713 | (3 650) | (6 010) | (10 337) | 5 805 304

Consolidated Financial Statements
77

2024 | Gross amount | Impairment losses | Net amount
€ ’000 | Stage 1 | Stage 2 | Stage 3 | Stage 1 | Stage 2 | Stage 3 |
Financial assets at AC |  |  |  |  |  |  |
Due from banks |  |  |  |  |  |  |
No delinquency | 268 086 | - | - | (3) | - | - | 268 083
Over 181 days | - | - | 55 721 | - | - | (5 866) | 49 855
| 268 086 | - | 55 721 | (3) | - | (5 866) | 317 938
Due from customers |  |  |  |  |  |  |
Financial corporations |  |  |  |  |  |  |
No delinquency | 1 319 532 | 86 | - | (481) | - | - | 1 319 137
1 – 30 days | - | - | - | - | - | - | -
91 – 180 days | - | - | - | - | - | - | -
Over 181 days | - | - | 18 | - | - | (7) | 11
| 1 319 532 | 86 | 18 | (481) | - | (7) | 1 319 148
Non-financial corporations |  |  |  |  |  |  |
No delinquency | 5 527 675 | 1 166 648 | 73 841 | (16 707) | (51 072) | (27 119) | 6 673 266
1 – 30 days | 36 800 | 22 587 | 3 557 | (478) | (1 330) | (1 054) | 60 082
31 – 60 days | 537 | 3 882 | 2 835 | (10) | (181) | (1 043) | 6 020
61 – 90 days | 45 | 2 287 | 2 658 | (1) | (187) | (518) | 4 284
91 – 180 days | 26 | 94 | 7 455 | (1) | (11) | (2 551) | 5 012
Over 181 days | - | 89 | 56 601 | - | (14) | (37 066) | 19 610
| 5 565 083 | 1 195 587 | 146 947 | (17 197) | (52 795) | (69 351) | 6 768 274
Retail |  |  |  |  |  |  |
No delinquency | 10 575 409 | 596 505 | 44 116 | (10 133) | (39 533) | (17 469) | 11 148 895
1 – 30 days | 57 560 | 100 925 | 20 586 | (977) | (12 689) | (8 182) | 157 223
31 – 60 days | 2 506 | 21 816 | 15 839 | (59) | (4 017) | (6 189) | 29 896
61 – 90 days | 408 | 9 520 | 13 718 | (8) | (2 325) | (4 981) | 16 332
91 – 180 days | 12 | 2 696 | 27 908 | (1) | (445) | (14 709) | 15 461
Over 181 days | 181 | 379 | 97 808 | (2) | (72) | (77 166) | 21 128
| 10 636 076 | 731 841 | 219 975 | (11 180) | (59 081) | (128 696) | 11 388 935
Public administration |  |  |  |  |  |  |
No delinquency | 961 878 | 15 385 | - | (948) | (399) | - | 975 916
1 – 30 days | 958 | 2 590 | - | (3) | (107) | - | 3 438
31 – 60 days | 241 | - | - | - | - | - | 241
61 – 90 days | - | - | - | - | - | - | -
| 963 077 | 17 975 | - | (951) | (506) | - | 979 595
Total due from customers | 18 483 768 | 1 945 489 | 366 940 | (29 809) | (112 382) | (198 054) | 20 455 952
Total financial assets at AC | 18 751 854 | 1 945 489 | 422 661 | (29 812) | (112 382) | (203 920) | 20 773 890
Financial assets at FVOCI |  |  |  |  |  |  |
– debt securities |  |  |  |  |  |  |
No delinquency | 1 489 641 | - | - | (212) | - | - | 1 489 429
Loan commitments |  |  |  |  |  |  |
and financial guarantees |  |  |  |  |  |  |
No delinquency | 4 780 731 | 884 387 | 17 534 | (3 282) | (15 548) | (4 339) | 5 659 483

Consolidated Financial Statements
78
The reconciliation from the opening balance to the closing balance of the impairment losses to explain the changes
in the impairment losses and the reasons for those changes:

| 2025 | 2024
€ ’000 | Stage 1 | Stage 2 | Stage 3 | Stage 1 | Stage 2 | Stage 3
Financial assets at AC |  |  |  |  |  |
1 January | 29 812 | 112 382 | 203 920 | 42 603 | 123 781 | 211 034
Origination | 21 931 | - | - | 27 898 | - | -
Derecognition | (9 355) | (15 402) | (4 367) | (9 323) | (5 000) | (1)
Changes in credit risk (net) | (95 833) | 6 403 | 81 440 | (31 366) | (6 399) | 55 032
Assets written off/sold | - | - | (44 893) | - | - | (62 145)
31 December | (53 445) | 103 383 | 236 100 | 29 812 | 112 382 | 203 920
Financial assets at FVOCI |  |  |  | - | - | -
1 January | 212 | - | - | 232 | - | -
Origination | 57 | - | - | 25 | - | -
Derecognition | - | - | - | (13) | - | -
Changes in credit risk (net) | 49 | - | - | (32) | - | -
Assets written off/sold | (48) | - | - | - | - | -
31 December | 270 | - | - | 212 | - | -
Loan commitments and financial guarantees |  |  |  |  |  |
1 January | 3 282 | 15 548 | 4 339 | 4 722 | 7 776 | 4 390
Origination | 9 902 | - | - | 17 252 | - | -
Derecognition | (2 553) | (3 375) | (2 240) | (2 458) | (1 781) | (2 834)
Changes in credit risk (net) | (6 981) | (6 163) | 8 238 | (16 234) | 9 553 | 2 783
31 December | 3 650 | 6 010 | 10 337 | 3 282 | 15 548 | 4 339

When there is a transfer between stages, the original amount of the provision is transferred
ﬁrst
and then the change
in credit risk is reﬂected in the new
stage.
The changes due to modiﬁcations that does not result in derecognition of the ﬁnancial assets were immaterial.
The changes in the gross carrying amount of ﬁnancial instruments during the year contributed to changes in the
impairment losses:

| 2025 | 2024
€ ’000 | Stage 1 | Stage 2 | Stage 3 | Stage 1 | Stage 2 | Stage 3
Financial assets at AC |  |  |  |  |  |
1 January | 18 751 854 | 1 945 489 | 422 661 | 16 890 933 | 1 771 647 | 414 729
Origination | 22 701 944 | - | 615 881 | 21 832 163 | - | -
Derecognition | (20 447 139) | (815 785) | (101 153) | (19 229 943) | (389 936) | (96 151)
Changes in credit risk (net) | (883 036) | 707 770 | 175 266 | (741 299) | 563 778 | 177 521
Assets written-off/sold | - | - | (51 044) | - | - | (73 438)
31 December | 20 123 623 | 1 837 474 | 1 061 611 | 18 751 854 | 1 945 489 | 422 661
Financial assets at FVOCI |  |  |  |  |  |
1 January | 1 489 641 | - | - | 1 259 458 | - | -
Origination | 721 833 | - | - | 486 135 | - | -
Derecognition | - | - | - | (52 412) | - | -
Assets written-off/sold | (771 207) | - | - | (203 540) | - | -
31 December | 1 440 267 | - | - | 1 489 641 | - | -
Loan commitments and financial guarantees |  |  |  |  |  |
1 January | 4 780 731 | 884 387 | 17 534 | 4 630 725 | 683 854 | 16 240
Origination | 4 594 036 | - | - | 3 855 280 | - | -
Derecognition | (4 390 126) | (54 003) | (7 258) | (3 418 754) | (69 455) | (15 238)
Changes in credit risk (net) | 148 688 | (162 125) | 13 437 | (286 520) | 269 988 | 16 532
31 December | 5 133 329 | 668 259 | 23 713 | 4 780 731 | 884 387 | 17 534

In 2025, the presentation of the tables showing movements in impairment losses and in the gross carrying amounts
of ﬁnancial instruments was revised. Transfers between individual stages, which were presented in separate columns
in the previous year, are included in the current year within the ‘Changes in credit risk (net)’ line item. This
modiﬁcation represents a presentation change only, has no impact on the total amount of impairment losses or
gross carrying amounts, and enhances the clarity of the information disclosed.
Consolidated Financial Statements
79
4.1.4.
Loans with renegotiated terms and forbearance policy
Loans with renegotiated terms are loans that have been restructured due to deterioration in the borrower’s
ﬁnancial
position, where the VUB Group has made concessions by agreeing to terms and conditions that are more favourable
for the borrower than the VUB Group had provided initially. The revised terms usually include extending maturity,
changing timing of interest payments and amendments to the terms of loan covenants. The VUB Group implements
a forbearance policy in order to maximise collection opportunities and minimise the risk of default. Under the VUB
Group’s forbearance policy, an exposure is
identiﬁed
as forborne if both of these two conditions are
satisﬁed:
–
The VUB Group has identiﬁed ﬁnancial difﬁculties that the debtor is facing or is about to face;
–
The exposure has been subject to renegotiation or reﬁnancing, granted in relation to the borrower’s current
ﬁnancial difﬁculties or ﬁnancial difﬁculties that would have occurred in the absence of the renegotiation or
reﬁnancing
measures.
The VUB Group follows rules in ECB Guidance to VUB Groups on non-performing loans issued in March 2017.
Forborne exposures are those falling into the ‘Non-performing exposures with forbearance measures‘ and
‘Performing Forborne exposures‘ categories.
Forbearance measures consist of concessions towards a debtor facing or about to face difﬁculties in meeting its
ﬁnancial commitments (
‘
ﬁnancial difﬁculties
‘).
Forbearance measures entail:
–
Favou
rable contractual modiﬁcations granted to the debtor solely in consideration of its ﬁnancial difﬁculties
(modiﬁcation);
–
The granting of a new loan to
a debtor in ﬁnancial difﬁculties
to enable them to fulﬁl a
pre-existing obligation
(reﬁnancing);
–
C
ontractual modiﬁcations which may be requested by a debtor within the scope of a contract already subscribed
and granted by the VUB Group
in the knowledge that the debtor is in ﬁnancial difﬁculties (so
-called ‘embedded
forbearance clauses‘).
Therefore, the deﬁnition of forborne exposure excludes the renegotiations made for commercial reasons/practices.
The qualiﬁcation of
‘Forborne Exposure‘ refers to the individual transactions subject to renegotiation and/or
reﬁnancing and should not be extended to the entire counterparty. The ﬁnancial difﬁculty, however, shall be assessed
at a debtor level.
T
he ﬁnancial distress is always assumed if the counterparty is classiﬁed as non
-performing (absolute presumption).
The aim of forborne exposures is to prevent potential ﬁnancial difﬁculties of the debtor or to allow the return of the
exposure to a situation of sustainable repayment. In case of performing borrowers, such a measure should not be
used to delay the recla
ssiﬁcation to non
-
performing statuses of a borrower whose ﬁnancial conditions already justify
a downgrade of their
risk classiﬁcation.
The extension of Forbearance Measures does not automatically lead to the classiﬁcation of the forborne exposures
as Non-Performing. Instead, a net present value (NPV) test is performed by Finevare to identify whether a forbearance
measure leads to a dimin
ished ﬁnancial obligation according to:
where:
–
DO is diminished ﬁnancial obligation;
–
NPV0 is net present value of cash ﬂows (including unpaid interest and fees) expected under contractual
obligations before the changes in terms and conditions of the contract discounted using the customer’s original
effective interest rate;
–
NPV1 is net present value of the cash ﬂows expected based on the new arrangement discounted using the
customer’s original effective interest rate.
Then, if the diminished ﬁnancial obligation is higher than the threshold of 1%, the exposure is classiﬁed as Non
-
performing, otherwise it is Performing.
Consolidated Financial Statements
80
In order to identify forborne exposures, the European regulation envisages a distinction between absolute
presumptions and relative presumptions (rebuttable). Absolute presumptions refer to circumstances which always
fall within the concept of forborne, and don’t admit contrary evidence. Relative presumptions refer to circumstances
that fall within the concept of forborne until proven otherwise. O
n the basis of speciﬁc analyses
, the VUB Group can
prove that certain circumstances do not give rise to a forbearance measure.
Listed below are some examples of the most common forms of contractual modiﬁcations which may be qualiﬁed as
forbearance measures, when referred to counterparties in ‘
ﬁnancial difﬁculties
‘ (the list is not exhaustive):
–
Short term credit facilities subject to debt consolidation/debt rescheduling plan;
–
Medium/long-term loans subject to:
–
Restructuring of the amortization plan with reductions or temporary
suspensions of the instalments;
–
Extension of the maturity;
–
Extension of the pre-amortization period;
–
Conversion of the repayment terms from instalments into bullet repayment at
maturity;
–
Consolidation.
–
Contractual modiﬁcation/renegotiation resulting from the breach of ﬁnancial covenants (waiver, amendment,
cancellation) reﬁnancing;
–
Restructuring of performing exposures or past due exposures not yet classiﬁed as non
-performing, involving a
pool of VUB Groups;
–
Contractual modiﬁcation of the economic conditions i.e. granting a borrower a new, more favo
urable interest
rate (‘off-market conditions‘);
–
Reﬁnancing of exposure, even short
-
term, with new ﬁnancing that allow the debtor to postpone repayment to
the VUB Group;
–
Conversion of Debt to Equity;
–
In case of the Sale and Repurchase Agreements (REPOs), the capitalization of outﬂows when mark to market is
negative.
Furthermore, according to the European regulation, the following cases have to be recognized as forborne exposures
(they therefore represent ‘absolute‘ presumptions):
–
Contractual modiﬁcations that imply partial or total write
-off of exposure;
–
The exercise of clauses which, when enforced at the discretion of the debtor, enable him to change the terms
of the contract (‘embedded forbearance clauses‘);
–
Providing new ﬁnancing to the debtor simultaneously (or almost) to the payment of principal and/or interest on
another exposure.
Both retail and corporate customers are subject to the forbearance policy:

| Performing forborne | Non-performing forborne
2025 | Gross | Impairment | Net | Gross | Impairment | Net
€ ’000 | amount | losses | amount | amount | losses | amount
Financial assets at AC |  |  |  |  |  |
Due from banks | - | - | - | 37 111 | (6 711) | 30 400
Due from customers |  |  |  |  |  |
Non-financial corporations | 83 663 | (3 697) | 79 966 | 67 766 | (34 542) | 33 224
Retail | 70 349 | (3 885) | 66 464 | 42 438 | (23 396) | 19 042
Public administration | - | - | - | - | - | -
| 154 012 | (7 582) | 146 430 | 147 315 | (64 649) | 82 666
Loan commitments |  |  |  |  |  |
and financial guarantees | 15 727 | (11) | 15 716 | 1 491 | (871) | 620

Consolidated Financial Statements
81

| Performing forborne | Non-performing forborne
2024 | Gross | Impairment | Net | Gross | Impairment | Net
€ ’000 | amount | losses | amount | amount | losses | amount
Financial assets at AC |  |  |  |  |  |
Due from banks | - | - | - | 55 721 | (5 866) | 49 855
Due from customers |  |  |  |  |  |
Non-financial corporations | 64 496 | (1 780) | 62 716 | 68 018 | (39 762) | 28 256
Retail | 71 973 | (5 056) | 66 917 | 37 268 | (22 328) | 14 940
Public administration | 6 | - | 6 | - | - | -
| 136 475 | (6 836) | 129 639 | 161 007 | (67 956) | 93 051
Loan commitments |  |  |  |  |  |
and financial guarantees | 5 018 | (7) | 5 011 | 2 915 | (530) | 2 385

4.1.5.
Write-off Policy
The VUB Group writes off a loan or security balance when it determines that the loans or securities are uncollectible.
In principle, the VUB Group considers the credit balances to be uncollectible based on the past due days (1 080 days
past due). Credit balances may be written off only if the collateral has already been realized. Receivables subject to
write-off are being collected by external collection agencies until they qualify for write-off.
The credit balance can be written off earlier than deﬁned in the conditions described above if there is evidence that
the receivable cannot be collected. The write-off of such receivables is subject to the approval of the Credit Risk
Ofﬁcer.
Financial assets that are written-off are subject of continuous enforcement process. The majority of such assets are
subject of sale to third parties for the best offered prices.
The amount of loans written-off during the year that are still subject to enforcement activity is EUR 16 731 thousand
(31 December 2024: EUR 33 348 thousand).
4.1.6.
Collateral Policy
The VUB Group’s collateral policy is an integral and indispensable part of the credit risk management and credit risk
mitigation for VUB. Collateral is used primarily to provide the VUB Group with the means for repayment of an
exposure in the event of the default of the borrower. The principal objective of the policy is to clearly set up rules
for a common and standard set of collateral types used by the VUB Group in its lending activities. The rules, as the
minimum, describe and state:
–
Conditions for legal enforceability;
–
Conditions for the process of valuation and the maximum values accepted by the VUB Group at the origination
for speciﬁc types of collaterals; and
–
Conditions for the process of revaluation.
However, collateral management has a wider meaning than the simple taking of collateral in order to secure the
repayment of the VUB Group’s exposures. This includes the following:
–
The establishment and maintenance of a collateral policy deﬁning the types of collateral taken by the VUB Group,
the legal documentation used by the VUB Group to secure its right to this collateral in the event of default and
the valuation of this collateral at origination. These aspects of collateral management are addressed in the
internal policy document;
–
The relevant and proper implementation and registration of collateral to secure the VUB Group’s right to
collateral in the event of default by the borrower;
–
The regular monitoring and revaluation of collateral held by the VUB Group during the life of the exposure;
–
The analysis, monitoring and review of realization rates achieved by Recovery Department activities in order to
assess the effectiveness of the collateral policy as a risk mitigant.
The VUB Group’s decisions on the enforcement of collateral is individual and depends on factors such as the actual
amount of the receivable, the current condition and value of the collateral, the length of the collateral realization
period or collection related costs. The relevant competent body of the VUB Group decides which collateral instrument
will be used.
Consolidated Financial Statements
82
The VUB Group mainly uses the following means of enforcement of collateral:
–
Voluntary auction,
–
Foreclosure procedure,
–
Realization of the collateral for the receivable in a bankruptcy procedure,
–
Sale of receivables including collateral.
The VUB Group holds collateral and other credit enhancements against certain types of its credit exposures. Collateral
for loans and advances granted to customers primarily consists of pledges of property, other forms of collateral, and
guarantees. Estimates of fair value are based on the value of collateral assessed at the time of borrowing and the
VUB Group updates the fair value on a regular basis.
The VUB Group mitigates the credit risk of derivatives, reverse sale and repurchase agreements by entering into
master netting agreements and holding collateral in the form of cash and marketable securities. Derivative
transactions are either transacted on an exchange or over-the-counter (OTC). The relevant contractual
documentation for derivative transactions (e.g. the ISDA Master Agreement as a contractual standard published by
the International Swaps and Derivatives Association) contains provisions governing netting arrangements. In general,
under the ISDA Master Agreement or other similar types of master agreements for derivative transactions, in certain
circumstances, for example in the event of default, all or only some of the active transactions may be terminated, a
ﬁnal value determined and the net value used to settle the relevant affected transactions.
The value of collateral accepted by the VUB Group (fair value adjusted by internal haircuts limited to outstanding
amount of credit exposure) and other security enhancements held against ﬁnancial assets is shown below:

| 2025 | 2024
€ ’000 | Total | Stage 3 | Total | Stage 3
Property | 11 190 436 | 93 243 | 10 855 118 | 143 088
of which LTV* higher than 60% and lower than 80% | 4 915 773 | 39 763 | 3 159 036 | 12 586
of which LTV higher than 80% and lower than 100% | 1 739 577 | 11 628 | 1 500 481 | 6 912
of which LTV higher than 100% | 244 091 | 5 869 | 227 166 | 1 901
Debt securities | 899 053 | 8 | 54 499 | 515
Other | 893 583 | 15 390 | 612 622 | 71 830
| 12 983 072 | 108 641 | 11 522 239 | 215 433

* LTV (loan to value) is the ratio of the current balance sheet balance of a loan to the currently allocated value of collateral for a given contract.
4.1.7.
Offsetting ﬁnancial assets and ﬁnancial liabilities
Offsetting ﬁnancial assets and ﬁnancial liabilities relates to ﬁnancial assets and ﬁnancial liabilities that are:
–
Offset in the statement of ﬁnancial position; or
–
Subject to an enforceable master netting arrangement or similar agreement that covers similar ﬁnancial
instruments, irrespective of whether they are offset in the statement of ﬁnancial position.
In general, the similar agreements include derivative clearing agreements, global master repurchase agreements,
and global master securities lending agreements. Similar ﬁnancial instruments include derivatives, sales and
repurchase agreements, reverse sale and repurchase agreements, and securities borrowing and lending agreements.
Financial instruments such as loans and deposits are not disclosed in the tables below unless they are offset in the
statement of ﬁnancial position.
The ISDA and similar master netting arrangements do not meet the criteria for offsetting in the statement of ﬁnancial
position. This is because they create for the parties to the agreement a right of set-off of recognized amounts that
is enforceable only following an event of default, insolvency or bankruptcy of the VUB Group or the counterparties
or following other predetermined events. In addition, the VUB Group and its counterparties do not intend to settle
on a net basis or to realize the assets and settle the liabilities simultaneously.
The VUB Group receives and gives collateral in the form of cash and marketable securities in respect of the following
transactions:
–
Derivatives,
–
S
ecurity ﬁnancing transaction instruments
.
Such collateral is subject to standard industry terms including, when appropriate, an ISDA/Credit Support Annex
(CSA) and Global Master Repurchase Agreement (‘GMRA’). This means that securities received or given as collateral
can be pledged or sold during the term of the transaction but have to be returned on maturity of the transaction.
The terms also give each party the right to terminate the related transactions on the counterparty’s failure to post
collateral.
Consolidated Financial Statements
83
The following tables show the ﬁnancial assets and ﬁnancial liabilities that are subject to enforceable master netting
a
rrangements and similar agreements in the statement of ﬁnancial position (
‘SOFP‘):

|  |  |  |  | Related amounts not offset in SOFP
|  |  | Gross |  | Financial |  |
|  |  | amount | Net amount | instrument and | Cash |
2025 |  | Gross | offset | presented | non-cash | collateral | Net
€ ’000 | Note | amount | in SOFP | in SOFP | collateral | received | amount
Types of financial assets |  |  |  |  |  |  |
Reverse repo transactions | 7 | 825 233 | - | 825 233 | (825 233) | - | -
Derivative financial instruments | 8, 9 | 136 259 | - | 136 259 | - | (23 772) | 112 487
Types of financial liabilities |  |  |  |  |  |  |
Derivative financial instruments | 8, 9 | 150 779 | - | 150 779 | - | (182 411) | (31 632)

|  |  |  |  | Related amounts not offset in SOFP
|  |  | Gross |  | Financial |  |
|  |  | amount | Net amount | instrument and | Cash |
2024 |  | Gross | offset | presented | non-cash | collateral | Net
€ ’000 | Note | amount | in SOFP | in SOFP | collateral | received | amount
Types of financial assets |  |  |  |  |  |  |
Reverse repo transactions | 7 | 990 078 | - | 990 078 | (990 078) | - | -
Derivative financial instruments | 8, 9 | 123 545 | - | 123 545 | - | (660) | 122 885
Types of financial liabilities |  |  |  |  |  |  |
Derivative financial instruments | 8, 9 | 247 868 | - | 247 868 | - | (211 302) | 36 566

4.1.8.
Concentrations of credit risk
The VUB Group monitors concentrations of credit risk by geographic location. An analysis of concentrations of credit
risk at the reporting date is shown below.
p

|  |  | Other |  |  |  |
2025 |  | The Czech | European |  |  | Rest of the |
€ ’000 | Slovakia | Republic | countries | America | Asia | World | Total
Financial assets at AC |  |  |  |  |  |  |
Due from banks | 86 | - | 182 411 | 37 111 | 178 | - | 219 786
Due from customers |  |  |  |  |  |  |
Financial corporations | 239 896 | 499 737 | 401 784 | - | - | - | 1 141 417
Non-financial corporations | 4 343 697 | 733 080 | 1 591 393 | - | 257 083 | - | 6 925 253
Retail | 11 924 232 | 19 129 | 158 116 | 5 154 | 16 000 | 5 150 | 12 127 781
Public administration | 1 784 843 | - | 207 747 | - | - | - | 1 992 590
Total due from customers | 18 292 668 | 1 251 946 | 2 359 040 | 5 154 | 273 083 | 5 150 | 22 187 041
Gross amount | 18 292 754 | 1 251 946 | 2 541 451 | 42 265 | 273 261 | 5 150 | 22 406 827
Impairment losses | (349 043) | (1 549) | (8 739) | (6 718) | (329) | (52) | (366 430)
Net amount | 17 943 711 | 1 250 397 | 2 532 712 | 35 547 | 272 932 | 5 098 | 22 040 397
Financial assets at FVOCI – |  |  |  |  |  |  |
debt securities | 478 890 | 378 033 | 546 669 | 36 675 | - | - | 1 440 267
Loan commitments |  |  |  |  |  |  |
and financial guarantees | 3 519 187 | 1 393 819 | 816 405 | 389 | 95 275 | 226 | 5 825 301

Consolidated Financial Statements
84

|  |  | Other |  |  |  |
2024 |  | The Czech | European |  |  | Rest of the |
€ ’000 | Slovakia | Republic | countries | America | Asia | World | Total
Financial assets at AC |  |  |  |  |  |  |
Due from banks | 5 577 | - | 262 385 | 55 721 | 124 | - | 323 807
Due from customers |  |  |  |  |  |  |
Financial corporations | 196 283 | 420 826 | 702 527 | - | - | - | 1 319 636
Non-financial corporations | 4 321 448 | 861 727 | 1 377 978 | - | 345 745 | 719 | 6 907 617
Retail | 11 355 804 | 19 258 | 183 024 | 5 239 | 18 855 | 5 712 | 11 587 892
Public administration | 981 052 | - | - | - | - | - | 981 052
Total due from customers | 16 854 587 | 1 301 811 | 2 263 529 | 5 239 | 364 600 | 6 431 | 20 796 197
Gross amount | 16 860 164 | 1 301 811 | 2 525 914 | 60 960 | 364 724 | 6 431 | 21 120 004
Impairment losses | (315 461) | (2 136) | (22 335) | (5 885) | (243) | (54) | (346 114)
Net amount | 16 544 703 | 1 299 675 | 2 503 579 | 55 075 | 364 481 | 6 377 | 20 773 890
Financial assets at FVOCI – |  |  |  |  |  |  |
debt securities | 785 190 | 31 446 | 589 974 | 83 031 | - | - | 1 489 641
Loan commitments |  |  |  |  |  |  |
and financial guarantees | 3 778 160 | 1 154 198 | 640 886 | 312 | 108 761 | 335 | 5 682 652

An analysis of exposures based on the carrying amounts for the non-
ﬁnancial
sector is shown in the table below.

€ ’000 | 2025 | 2024
Non-financial corporations |  |
Agriculture, forestry and fishing | 298 929 | 314 119
Mining and quarrying | 119 771 | 139 794
Manufacturing | 1 033 383 | 1 184 300
Electricity, gas, steam and air conditioning supply | 642 186 | 569 325
Water supply | 43 951 | 54 467
Construction | 474 127 | 467 524
Wholesale and retail trade | 1 135 830 | 1 119 433
Transport and storage | 608 535 | 679 689
Accommodation and food service activities | 74 259 | 71 146
Information and communication | 98 565 | 78 100
Financial and insurance activities* | 40 422 | 36 642
Real estate activities | 715 409 | 749 833
Professional, scientific and technical activities | 504 899 | 504 932
Administrative and support service | 609 658 | 366 518
Public administration and defense, compulsory social security | 109 | 209
Education | 21 471 | 16 820
Human health services and social work activities | 70 838 | 79 351
Arts, entertainment and recreation | 14 259 | 13 119
Other services | 418 652 | 462 296
Gross amount | 6 925 253 | 6 907 617
Impairment losses | (147 064) | (139 343)
Net amount | 6 778 189 | 6 768 274

* ‘Financial and insurance activities’ involves ﬁnancial services, leasing and insurance.
Consolidated Financial Statements
85
4.1.9.
Internal and external ratings
The overview of the internal rating scales according to the risk proﬁle applicable for the corporate exposures and the
retail exposures from small business
, ﬂat
owners’ associations and public administrations shown below.

Risk Profile | Description
Very Low | Good quality of assets, strong market penetration, steady activity, proven distinctive managerial
| skills, broad debt coverage capacity.
Low | Satisfactory quality and chargeability of assets, market penetration and managerial
| quality on the average; well-set solvency, capital structure and debt composition; above average debt
| coverage capacity.
Lower–Intermediate | Acceptable quality and chargeability of available assets, even if with a not negligible degree of risk;
| well-balanced solvency, capital structure and debt composition with slight liquidity surplus and
| weaker debt coverage capacity.
Intermediate | Acceptable quality and chargeability of available assets even if with a significant degree of risk;
| vulnerable margin at times, capital structure and debt composition that show worsening signals; low
| level of liquidity and short debt coverage margin.
Upper–Intermediate | Still acceptable asset quality even if with possible liquidity stress; high level of gearing; managerial
| weakness, little market penetration and positioning; margins and competitiveness under pressure.
High | In addition to riskiness features for Upper–Intermediate profile, there are evident difficulties as well
| as problematic debt management.
Very high | Highly vulnerable to non-payment, dependent on favourable conditions, likely to default
Default | A default is considered to have occurred with regard to a particular obligor when one or both of the
| following two events have taken place:
| - The obligor is past due more than 90 days (Days past due methodology) on any material credit
| obligation to the Bank, the Parent Company undertaking or any of its subsidiaries;
| - The Bank considers that the obligor is unlikely to pay its credit obligations to the banking group
| in full, without recourse by the Bank to actions such as realizing security (if held).

Specialized Lending comprises of rating segment SPV. For Specialized Lending the Slotting approach is used by the
VUB Group. Clients are categorized
into ﬁve slotting categories based on a qualitative valuation and information
about the risk of default. Risk weights and expected loss used for the capital requirement calculation are also deﬁned
for each category. Categories are predeﬁned by the Regul
ation (EU) No 575/2013 on prudential requirements for
credit institutions and investment ﬁrms (‘CRR’) and
internally, the categories used are as follows:
Specialized Lending – SPV
–
Strong
–
Good
–
Satisfactory
–
Weak
–
Default
For mortgages and unsecured retail, the retail segment incorporates many individually insigniﬁcant exposures with
various characteristics, therefore the description of ratings correlates with these risk proﬁles.

Risk Profile | Description
Very Low | High level of client’s socio-demographic information and financial discipline.
Low | Above average level of client’s socio-demographic information and financial discipline.
Lower–Intermediate | Acceptable level of client’s socio-demographic information and financial discipline.
Intermediate | Acceptable level of client’s socio-demographic information and financial discipline, but there are some
| signals of worsening credit quality.
Upper–Intermediate | Acceptable level of client’s socio-demographic information and financial discipline, but there is
| worsening credit quality.
High | Acceptable level of client’s socio-demographic information and financial discipline, but there is
| negative credit behaviour.
Default | A default is considered to have occurred with regard to a particular mortgage or obligor when one or
| both of the following two events have taken place:
| - The obligor is past due more than 90 days (Days past due methodology) on any material credit
| obligation to the Bank (absolute threshold is set according to NBS directive);
| - The Bank considers that the obligor is unlikely to pay its credit obligations to the Banking group in
| full, without recourse by the Bank to actions such as realizing security (if held).

In the segments of the public sector entities, factoring and leasing, the VUB Group does not assign an internal rating
to the client.
Consolidated Financial Statements
(Table continues on the next page)
86
Capital requirement calculation
The Bank generally employs the standardized approach for the calculation of the capital requirements. However, for
the calculation of the credit and counterparty risk capital requirements, the Bank, having received authorisation from
the Supervisory Authority National Bank of Slovakia (’NBS’), uses the Advanced IRB approach for its portfolio of
residential mortgages from July 2012 and for the Corporate segment, Small and Medium size enterprises (SME) and
for Retail Small Business from June 2014. In December 2022, the VUB Group received authorisation to use IRB
approach also for Unsecured retail segment. Slotting approach is employed for portfolio of Specialised lending
exposures. After CCR III implementation Foundation IRB approach is used for Large Corporate segment, and in
November 2025 Foundation IRB approach has been approved also for Institutions exposure class. The Bank is also
proceeding with the development of IRB models in accordance with the gradual rollout plan for the advanced
approaches presented to the Supervisory Authority.
The following table shows the quality of the VUB Group’s credit portfolio in terms of internal ratings:

2025 | Gross amount | Impairment losses | Net amount
€ ’000 | Stage 1 | Stage 2 | Stage 3 | Stage 1 | Stage 2 | Stage 3 |
Financial assets at AC |  |  |  |  |  |  |
Due from banks |  |  |  |  |  |  |
Very Low | 12 258 | - | - | - | - | - | 12 258
Low | - | - | - | - | - | - | -
Lower–Intermediate | - | - | - | - | - | - | -
Intermediate | - | - | - | - | - | - | -
Upper–Intermediate | - | - | - | - | - | - | -
High | 170 331 | - | - | - | - | - | 170 331
Default | - | - | 37 111 | - | - | (6 711) | 30 400
Unrated | 86 | - | - | - | - | - | 86
| 182 675 | - | 37 111 | - | - | (6 711) | 213 075
Due from customers |  |  |  |  |  |  |
Financial corporations |  |  |  |  |  |  |
Very Low | 490 734 | 58 631 | - | (37) | (6) | - | 549 322
Low | 245 882 | - | - | (131) | - | - | 245 751
Lower–Intermediate | 52 887 | - | - | (156) | - | - | 52 731
Intermediate | 290 057 | 44 | - | (153) | (339) | - | 289 609
Upper–Intermediate | 19 | 60 | - | - | (6) | - | 73
High | - | - | - | - | - | - | -
Default | - | - | 2 549 | - | - | (2 314) | 235
Unrated | 554 | - | - | (1) | - | - | 553
| 1 080 133 | 58 735 | 2 549 | (478) | (351) | (2 314) | 1 138 274
Non-financial corporations |  |  |  |  |  |  |
Very Low | 1 679 887 | 31 997 | - | (854) | (169) | - | 1 710 861
Low | 1 540 240 | 1 700 | - | (458) | - | - | 1 541 482
Lower–Intermediate | 1 465 975 | 243 935 | - | (4 303) | (1 908) | - | 1 703 699
Intermediate | 326 586 | 107 934 | - | (1 265) | (1 896) | - | 431 359
Upper–Intermediate | 232 607 | 412 615 | - | (7 441) | (48 677) | - | 589 104
High | - | - | - | - | - | - | -
Very high | 45 | 1 | - | - | - | - | 46
Default | (5) | - | 134 713 | - | - | (73 340) | 61 368
Unrated | 769 | 20 | - | - | - | - | 789
| 5 246 104 | 798 202 | 134 713 | (14 321) | (52 650) | (73 340) | 6 038 708
Non-financial corporations – |  |  |  |  |  |  |
specialised lending |  |  |  |  |  |  |
Strong | 269 732 | 4 656 | - | (162) | (118) | - | 274 108
Good | 376 140 | 23 561 | - | (574) | (367) | - | 398 760
Satisfactory | 36 362 | 18 668 | - | (316) | (782) | - | 53 932
Weak | 9 470 | 2 468 | - | (365) | (193) | - | 11 380
Default | - | - | 5 177 | - | - | (3 876) | 1 301
Unrated | - | - | - | - | - | - | -
| 691 704 | 49 353 | 5 177 | (1 417) | (1 460) | (3 876) | 739 481
Retail |  |  |  |  |  |  |
Very Low | 7 063 631 | 31 908 | - | (594) | (317) | - | 7 094 628
Low | 1 579 134 | 19 878 | - | (278) | (161) | - | 1 598 573
Lower–Intermediate | 2 101 480 | 247 195 | - | (2 483) | (4 757) | - | 2 341 435
Intermediate | 226 587 | 194 553 | - | (1 922) | (6 709) | - | 412 509
Upper–Intermediate | 103 405 | 148 332 | - | (3 310) | (14 422) | - | 234 005
High | 9 662 | 117 983 | - | (884) | (22 051) | - | 104 710
Default | - | - | 266 180 | - | - | (149 859) | 116 321
Unrated | 17 647 | 206 | - | - | - | - | 17 853
| 11 101 546 | 760 055 | 266 180 | (9 471) | (48 417) | (149 859) | 11 920 034

Consolidated Financial Statements
(Table continues on the next page)
87

2025 | Gross amount | Impairment losses/Provisions | Net amount
€ ’000 | Stage 1 | Stage 2 | Stage 3 | Stage 1 | Stage 2 | Stage 3 |
Financial assets at AC |  |  |  |  |  |  |
Due from customers |  |  |  |  |  |  |
Public administration |  |  |  |  |  |  |
Very Low | 115 988 | 3 262 | - | (108) | (4) | - | 119 138
Low | 51 700 | 2 182 | - | (22) | (4) | - | 53 856
Lower–Intermediate | - | - | - | - | - | - | -
Intermediate | 11 498 | 2 794 | - | (8) | (27) | - | 14 257
Upper–Intermediate | 93 853 | 20 150 | - | (273) | (437) | - | 113 293
High | 442 | 328 | - | (17) | (27) | - | 726
Default | - | - | - | - | - | - | -
Unrated | 1 690 300 | 93 | - | (832) | (6) | - | 1 689 555
| 1 963 781 | 28 809 | - | (1 260) | (505) | - | 1 990 825
Total due from customers | 20 083 268 | 1 695 154 | 408 619 | (26 947) | (103 383) | (229 389) | 21 827 322
Total financial assets at AC | 20 265 943 | 1 695 154 | 445 730 | (26 947) | (103 383) | (236 100) | 22 040 397
Financial assets at FVOCI |  |  |  |  |  |  |
– debt securities |  |  |  |  |  |  |
Unrated | 1 440 267 | - | - | (270) | - | - | 1 439 997
Loan commitments |  |  |  |  |  |  |
and financial guarantees |  |  |  |  |  |  |
Due from banks |  |  |  |  |  |  |
Very Low | 10 987 | - | - | (1) | - | - | 10 986
Low | - | - | - | - | - | - | -
Lower–Intermediate | - | - | - | - | - | - | -
Intermediate | 185 | - | - | - | - | - | 185
Upper–Intermediate | - | - | - | - | - | - | -
High | 207 275 | - | - | (7) | - | - | 207 268
Default | - | - | - | - | - | - | -
Unrated | 1 909 | 5 | - | - | - | - | 1 914
| 220 356 | 5 | - | (8) | - | - | 220 353
Due from customers |  |  |  |  |  |  |
Financial corporations |  |  |  |  |  |  |
Very Low | 130 143 | 6 003 | - | (19) | - | - | 136 127
Low | 73 710 | - | - | (27) | - | - | 73 683
Lower–Intermediate | 6 092 | - | - | (25) | - | - | 6 067
Intermediate | 28 588 | 505 | - | - | (27) | - | 29 066
Upper–Intermediate | - | 3 | - | - | - | - | 3
High | - | - | - | - | - | - | -
Default | - | - | - | - | - | - | -
Unrated | 167 | - | - | - | - | - | 167
| 238 700 | 6 511 | - | (71) | (27) | - | 245 113
Non-financial corporations |  |  |  |  |  |  |
Very Low | 1 626 744 | 144 342 | - | (605) | (25) | - | 1 770 456
Low | 986 407 | 70 936 | - | (264) | (4) | - | 1 057 075
Lower–Intermediate | 706 992 | 120 044 | - | (737) | (391) | - | 825 908
Intermediate | 176 654 | 83 401 | - | (298) | (651) | - | 259 106
Upper–Intermediate | 45 070 | 120 314 | - | (1 129) | (4 395) | - | 159 860
High | - | - | - | - | - | - | -
Very high | 9 | - | - | - | - | - | 9
Default | - | - | 20 299 | - | - | (10 152) | 10 147
Unrated | 2 489 | 400 | - | - | - | - | 2 889
| 3 544 365 | 539 437 | 20 299 | (3 033) | (5 466) | (10 152) | 4 085 450

Consolidated Financial Statements
88

2025 | Gross amount | Provisions | Net amount
€ ’000 | Stage 1 | Stage 2 | Stage 3 | Stage 1 | Stage 2 | Stage 3 |
Loan commitments |  |  |  |  |  |  |
and financial guarantees |  |  |  |  |  |  |
Due from customers |  |  |  |  |  |  |
Non-financial corporations – |  |  |  |  |  |  |
specialised lending |  |  |  |  |  |  |
Strong | 160 977 | 3 669 | - | (38) | - | - | 164 608
Good | 150 071 | 18 033 | - | (94) | (58) | - | 167 952
Satisfactory | 606 | - | - | (2) | - | - | 604
Weak | - | - | - | - | - | - | -
Default | - | - | - | - | - | - | -
Unrated | - | - | - | - | - | - | -
| 311 654 | 21 702 | - | (134) | (58) | - | 333 164
Retail |  |  |  |  |  |  |
Very Low | 285 037 | 6 152 | - | (15) | (18) | - | 291 156
Low | 100 455 | 5 196 | - | (8) | (3) | - | 105 640
Lower–Intermediate | 202 106 | 55 175 | - | (61) | (103) | - | 257 117
Intermediate | 25 623 | 3 313 | - | (35) | (39) | - | 28 862
Upper–Intermediate | 6 668 | 4 925 | - | (28) | (246) | - | 11 319
High | 1 096 | 674 | - | (11) | (42) | - | 1 717
Default | - | - | 3 414 | - | - | (185) | 3 229
Unrated | 211 | 58 | - | - | - | - | 269
| 621 196 | 75 493 | 3 414 | (158) | (451) | (185) | 699 309
Public administration |  |  |  |  |  |  |
Very Low | 101 795 | 1 981 | - | (28) | - | - | 103 748
Low | 36 756 | 2 800 | - | (7) | - | - | 39 549
Lower–Intermediate | - | - | - | - | - | - | -
Intermediate | 8 587 | 110 | - | (3) | - | - | 8 694
Upper–Intermediate | 20 006 | 3 067 | - | (30) | (8) | - | 23 035
High | - | 22 | - | - | - | - | 22
Default | - | - | - | - | - | - | -
Unrated | 47 025 | 20 | - | (178) | - | - | 46 867
| 214 169 | 8 000 | - | (246) | (8) | - | 221 915
Total due from customers | 4 930 084 | 651 143 | 23 713 | (3 642) | (6 010) | (10 337) | 5 584 951
Total financial assets at AC | 5 150 440 | 651 148 | 23 713 | (3 650) | (6 010) | (10 337) | 5 805 304

Consolidated Financial Statements

2024 | Gross amount | Impairment losses | Net amount
€ ’000 | Stage 1 | Stage 2 | Stage 3 | Stage 1 | Stage 2 | Stage 3 |
Financial assets at AC |  |  |  |  |  |  |
Due from banks |  |  |  |  |  |  |
Very Low | 85 685 | - | - | (3) | - | - | 85 682
Low | 182 323 | - | - | - | - | - | 182 323
Lower–Intermediate | - | - | - | - | - | - | -
Intermediate | - | - | - | - | - | - | -
Upper–Intermediate | - | - | - | - | - | - | -
High | - | - | - | - | - | - | -
Default | - | - | 55 721 | - | - | (5 866) | 49 855
Unrated | 78 | - | - | - | - | - | 78
| 268 086 | - | 55 721 | (3) | - | (5 866) | 317 938
Due from customers |  |  |  |  |  |  |
Financial corporations |  |  |  |  |  |  |
Very Low | 994 490 | - | - | (114) | - | - | 994 376
Low | 254 535 | - | - | (93) | - | - | 254 442
Lower–Intermediate | 42 067 | 17 | - | (204) | - | - | 41 880
Intermediate | 27 262 | 69 | - | (70) | - | - | 27 261
Upper–Intermediate | 13 | - | - | - | - | - | 13
High | - | - | - | - | - | - | -
Default | - | - | 18 | - | - | (7) | 11
Unrated | 1 165 | - | - | - | - | - | 1 165
| 1 319 532 | 86 | 18 | (481) | - | (7) | 1 319 148
Non-financial corporations |  |  |  |  |  |  |
Very Low | 1 407 649 | 127 956 | - | (619) | (174) | - | 1 534 812
Low | 1 660 321 | 522 | - | (621) | - | - | 1 660 222
Lower–Intermediate | 1 289 182 | 352 038 | - | (3 387) | (2 047) | - | 1 635 786
Intermediate | 304 415 | 135 601 | - | (1 402) | (1 998) | - | 436 616
Upper–Intermediate | 215 367 | 398 789 | - | (3 460) | (19 339) | - | 591 357
High | 793 | 90 141 | - | (14) | (16 560) | - | 74 360
Very high | - | - | - | - | - | - | -
Default | - | - | 121 130 | - | - | (56 784) | 64 346
Unrated | 1 767 | 27 | - | - | - | - | 1 794
| 4 879 494 | 1 105 074 | 121 130 | (9 503) | (40 118) | (56 784) | 5 999 293
Non-financial corporations – |  |  |  |  |  |  |
specialised lending |  |  |  |  |  |  |
Strong | 156 818 | 2 509 | - | (786) | (100) | - | 158 441
Good | 452 152 | 19 662 | - | (4 081) | (667) | - | 467 066
Satisfactory | 69 646 | 27 504 | - | (2 148) | (2 253) | - | 92 749
Weak | 6 973 | 40 838 | - | (679) | (9 657) | - | 37 475
Default | - | - | 25 817 | - | - | (12 567) | 13 250
Unrated | - | - | - | - | - | - | -
| 685 589 | 90 513 | 25 817 | (7 694) | (12 677) | (12 567) | 768 981
Retail |  |  |  |  |  |  |
Very Low | 6 529 601 | 61 336 | - | (887) | (1 323) | - | 6 588 727
Low | 1 573 227 | 33 355 | - | (413) | (744) | - | 1 605 425
Lower–Intermediate | 2 151 716 | 190 993 | - | (3 513) | (5 000) | - | 2 334 196
Intermediate | 237 602 | 164 779 | - | (2 298) | (10 603) | - | 389 480
Upper–Intermediate | 92 607 | 159 434 | - | (2 662) | (14 875) | - | 234 504
High | 14 391 | 121 386 | - | (1 399) | (26 536) | - | 107 842
Default | - | - | 219 975 | - | - | (128 696) | 91 279
Unrated | 36 932 | 558 | - | (8) | - | - | 37 482
| 10 636 076 | 731 841 | 219 975 | (11 180) | (59 081) | (128 696) | 11 388 935

(Table continues on the next page.)
89
Consolidated Financial Statements
(Table continues on the next page)
90

2024 | Gross amount | Impairment losses/Provisions | Net amount
€ ’000 | Stage 1 | Stage 2 | Stage 3 | Stage 1 | Stage 2 | Stage 3 |
Financial assets at AC |  |  |  |  |  |  |
Due from customers |  |  |  |  |  |  |
Public administration |  |  |  |  |  |  |
Very Low | 36 606 | 2 196 | - | (18) | (2) | - | 38 782
Low | 30 551 | 2 611 | - | (14) | (9) | - | 33 139
Lower–Intermediate | - | - | - | - | - | - | -
Intermediate | 8 015 | 2 248 | - | (6) | (9) | - | 10 248
Upper–Intermediate | 83 525 | 9 872 | - | (231) | (401) | - | 92 765
High | 245 | 901 | - | (9) | (77) | - | 1 060
Default | - | - | - | - | - | - | -
Unrated | 804 135 | 147 | - | (673) | (8) | - | 803 601
| 963 077 | 17 975 | - | (951) | (506) | - | 979 595
Total due from customers | 18 483 768 | 1 945 489 | 366 940 | (29 809) | (112 382) | (198 054) | 20 455 952
Total financial assets at AC | 18 751 854 | 1 945 489 | 422 661 | (29 812) | (112 382) | (203 920) | 20 773 890
Financial assets at FVOCI |  |  |  |  |  |  |
– debt securities |  |  |  |  |  |  |
Unrated | 1 489 641 | - | - | (212) | - | - | 1 489 429
Loan commitments |  |  |  |  |  |  |
and financial guarantees |  |  |  |  |  |  |
Due from banks |  |  |  |  |  |  |
Very Low | 11 954 | - | - | (1) | - | - | 11 953
Low | - | - | - | - | - | - | -
Lower–Intermediate | 209 532 | - | - | (5) | - | - | 209 527
Intermediate | 1 129 | - | - | - | - | - | 1 129
Upper–Intermediate | - | - | - | - | - | - | -
High | - | - | - | - | - | - | -
Default | - | - | - | - | - | - | -
Unrated | 1 612 | 10 | - | - | - | - | 1 622
| 224 227 | 10 | - | (6) | - | - | 224 231
Due from customers |  |  |  |  |  |  |
Financial corporations |  |  |  |  |  |  |
Very Low | 64 545 | 24 391 | - | (2) | (27) | - | 88 907
Low | 39 875 | - | - | 1 | - | - | 39 876
Lower–Intermediate | 8 728 | 1 | - | (2) | - | - | 8 727
Intermediate | 24 269 | 5 | - | (11) | - | - | 24 263
Upper–Intermediate | - | - | - | - | - | - | -
High | - | - | - | - | - | - | -
Default | - | - | - | - | - | - | -
Unrated | - | - | - | - | - | - | -
| 137 417 | 24 397 | - | (14) | (27) | - | 161 773
Non-financial corporations |  |  |  |  |  |  |
Very Low | 1 517 600 | 296 533 | - | (174) | (2 664) | - | 1 811 295
Low | 1 344 403 | 56 344 | - | (220) | (35) | - | 1 400 492
Lower–Intermediate | 585 227 | 170 673 | - | (573) | (3 236) | - | 752 091
Intermediate | 156 934 | 108 164 | - | (462) | (2 002) | - | 262 634
Upper–Intermediate | 33 330 | 102 399 | - | (249) | (5 844) | - | 129 636
High | 9 | 7 492 | - | - | (216) | - | 7 285
Very high | - | - | - | - | - | - | -
Default | - | - | 14 251 | - | - | (4 327) | 9 924
Unrated | 2 046 | 400 | - | (1) | - | - | 2 445
| 3 639 549 | 742 005 | 14 251 | (1 679) | (13 997) | (4 327) | 4 375 802

Consolidated Financial Statements
91

2024 | Gross amount | Provisions | Net amount
€ ’000 | Stage 1 | Stage 2 | Stage 3 | Stage 1 | Stage 2 | Stage 3 |
Loan commitments |  |  |  |  |  |  |
and financial guarantees |  |  |  |  |  |  |
Due from customers |  |  |  |  |  |  |
Non-financial corporations – |  |  |  |  |  |  |
specialised lending |  |  |  |  |  |  |
Strong | 25 493 | 12 | - | (92) | - | - | 25 413
Good | 123 886 | 23 609 | - | (904) | (375) | - | 146 216
Satisfactory | 4 100 | 2 091 | - | (107) | (116) | - | 5 968
Weak | - | - | - | - | - | - | -
Default | - | - | - | - | - | - | -
Unrated | - | - | - | - | - | - | -
| 153 479 | 25 712 | - | (1 103) | (491) | - | 177 597
Retail |  |  |  |  |  |  |
Very Low | 220 363 | 6 805 | - | (21) | (69) | - | 227 078
Low | 76 139 | 3 345 | - | (13) | (21) | - | 79 450
Lower–Intermediate | 184 930 | 52 962 | - | (105) | (244) | - | 237 543
Intermediate | 29 969 | 3 504 | - | (119) | (186) | - | 33 168
Upper–Intermediate | 6 392 | 4 946 | - | (84) | (439) | - | 10 815
High | 1 893 | 504 | - | (78) | (74) | - | 2 245
Default | - | - | 3 283 | - | - | (12) | 3 271
Unrated | 238 | - | - | (7) | - | - | 231
| 519 924 | 72 066 | 3 283 | (427) | (1 033) | (12) | 593 801
Public administration |  |  |  |  |  |  |
Very Low | 5 162 | 20 048 | - | - | - | - | 25 210
Low | 32 625 | - | - | (6) | - | - | 32 619
Lower–Intermediate | - | - | - | - | - | - | -
Intermediate | 2 373 | - | - | (1) | - | - | 2 372
Upper–Intermediate | 3 629 | 129 | - | (9) | - | - | 3 749
High | - | 20 | - | - | - | - | 20
Default | - | - | - | - | - | - | -
Unrated | 62 346 | - | - | (37) | - | - | 62 309
| 106 135 | 20 197 | - | (53) | - | - | 126 279
Total due from customers | 4 556 504 | 884 377 | 17 534 | (3 276) | (15 548) | (4 339) | 5 435 252
Total financial assets at AC | 4 780 731 | 884 387 | 17 534 | (3 282) | (15 548) | (4 339) | 5 659 483

For some portfolios, information from external credit reference agencies is also used. The credit quality for ﬁnancial
assets at amortized cost: due from banks is in the rating scale from Aa1 to Ba3 (31 December 2024: Aaa to B1). Two
banking counterparties did not have an external credit rating assigned as of the reporting date.
The following table sets out the credit quality of FVOCI debt securities. The analysis is based on Moody‘s ratings.

€ ’000 | 2025 | 2024
Financial assets at FVOCI – debt securities |  |
Aaa | 222 151 | 562 291
Aa1 | 34 298 | 8 065
Aa2 | - | 31 446
Aa3 | 346 667 | 20 938
A3 | 530 939 | 106 826
Baa1 | 5 233 | 5 272
Baa2 | 300 979 | 108 445
Baa3 | - | 646 358
Gross amount | 1 440 267 | 1 489 641
Impairment losses | (270) | (212)
Net amount | 1 439 997 | 1 489 429

During the preparation of the consolidated ﬁnancial statements for 2025, the V
U
B Group identiﬁed
that the
presentation of the credit quality of debt securities measured at FVOCI for 2024 was based on data corresponding
to individual
-
level inputs. Consequently, the comparative information for 2024 was restated for the rating classes
A3, Baa1 and Baa2.
Consolidated Financial Statements
92
4.1.10.
Sensitivity analysis of impairment losses
In the tables below the VUB Group shows the sensitivity of ECL calculation to a decrease or increase of PD parameter
by 10%:

| Basic |  |  |  |  |  |
| scenario | Decrease PD by 10% | Increase PD by 10%
| Impairment |  |  |  |  |  |
2025 | losses (note | Impairment | Absolute | Relative | Impairment | Absolute | Relative
€ ’000 | 11.1, 11.2) | losses | change | change | losses | change | change
Financial assets at AC |  |  |  |  |  |  |
Due from banks | 6 711 | 6 711 | - | - | 6 711 | - | -
Due from customers |  |  |  |  |  |  |
Financial corporations |  |  |  |  |  |  |
Loans | 3 013 | 3 083 | 70 | 2.32% | 2 943 | (70) | (2.32)%
Overdrafts | 2 | 3 | 1 | 50.00% | 2 | - | -
Factoring | 5 | 5 | - | - | 5 | - | -
Debt securities | 123 | 136 | 13 | 10.57% | 111 | (12) | (9.76)%
| 3 143 | 3 227 | 84 | 2.67% | 3 061 | (82) | (2.61)%
Non-financial corporations |  |  |  |  |  |  |
Loans | 96 290 | 101 678 | 5 388 | 5.60% | 90 903 | (5 387) | (5.59)%
Mortgages | 216 | 218 | 2 | 0.93% | 213 | (3) | (1.39)%
Overdrafts | 40 602 | 41 682 | 1 080 | 2.66% | 39 522 | (1 080) | (2.66)%
Credit cards | 362 | 375 | 13 | 3.59% | 349 | (13) | (3.59)%
Factoring | 1 431 | 1 525 | 94 | 6.57% | 1 338 | (93) | (6.50)%
Debt securities | 843 | 927 | 84 | 9.96% | 759 | (84) | (9.96)%
Other | 7 320 | 7 610 | 290 | 3.96% | 7 032 | (288) | (3.93)%
| 147 064 | 154 015 | 6 951 | 4.73% | 140 116 | (6 948) | (4.72)%
Retail |  |  |  |  |  |  |
Loans | 136 083 | 139 017 | 2 934 | 2.16% | 133 149 | (2 934) | (2.16)%
Mortgages | 65 064 | 67 754 | 2 690 | 4.13% | 62 374 | (2 690) | (4.13)%
Overdrafts | 4 139 | 4 213 | 74 | 1.79% | 4 065 | (74) | (1.79)%
Credit cards | 1 927 | 2 011 | 84 | 4.36% | 1 844 | (83) | (4.31)%
Other | 534 | 542 | 8 | 1.50% | 526 | (8) | (1.50)%
| 207 747 | 213 537 | 5 790 | 2.79% | 201 958 | (5 789) | (2.79)%
Public administration |  |  |  |  |  |  |
Loans | 1 498 | 1 648 | 150 | 10.01% | 1 349 | (149) | (9.95)%
Overdrafts | 3 | 3 | - | - | 3 | - | -
Debt securities | 263 | 290 | 27 | 10.27% | 237 | (26) | (9.89)%
Other | 1 | 1 | - | - | - | (1) | (100.00)%
| 1 765 | 1 942 | 177 | 10.03% | 1 589 | (176) | (9.97)%
Total due from customers | 359 719 | 372 721 | 13 002 | 3.61% | 346 724 | (12 995) | (3.61)%
Total financial assets at AC | 366 430 | 379 432 | 13 002 | 3.55% | 353 435 | (12 995) | (3.55)%
Financial assets at FVOCI – |  |  |  |  |  |  |
debt securities | 270 | 297 | 27 | 10.00% | 243 | (27) | (10.00)%

Consolidated Financial Statements
93

| Basic |  |  |  |  |  |
| scenario | Decrease PD by 10% | Increase PD by 10%
| Impairment |  |  |  |  |  |
2024 | losses (note | Impairment | Absolute | Relative | Impairment | Absolute | Relative
€ ’000 | 11.1, 11.2) | losses | change | change | losses | change | change
Financial assets at AC |  |  |  |  |  |  |
Due from banks | 5 869 | 5 869 | - | - | 5 870 | 1 | 0.02%
Due from customers |  |  |  |  |  |  |
Financial corporations |  |  |  |  |  |  |
Loans | 392 | 354 | (38) | (9.69)% | 431 | 39 | 9.95%
Overdrafts | - | - | - | - | - | - | -
Factoring | - | - | - | - | - | - | -
Debt securities | 96 | 86 | (10) | (10.42)% | 105 | 9 | 9.38%
| 488 | 440 | (48) | (20.11)% | 536 | 48 | 9.84%
Non-financial corporations |  |  |  |  |  |  |
Loans | 102 961 | 96 732 | (6 229) | (6.05)% | 109 189 | 6 228 | 6.05%
Mortgages | 203 | 199 | (4) | (1.97)% | 207 | 4 | 1.97%
Overdrafts | 28 645 | 28 196 | (449) | (1.57)% | 29 095 | 450 | 1.57%
Credit cards | 198 | 191 | (7) | (3.54)% | 204 | 6 | 3.03%
Factoring | 1 315 | 1 205 | (110) | (8.37)% | 1 426 | 111 | 8.44%
Debt securities | 165 | 149 | (16) | (9.70)% | 182 | 17 | 10.30%
Other | 5 856 | 5 672 | (184) | (3.14)% | 6 039 | 183 | 3.13%
| 139 343 | 132 344 | (6 999) | (5.02)% | 146 342 | 6 999 | 5.02%
Retail |  |  |  |  |  |  |
Loans | 118 807 | 115 193 | (3 614) | (3.04)% | 122 421 | 3 614 | 3.04%
Mortgages | 73 185 | 69 905 | (3 280) | (4.48)% | 76 464 | 3 279 | 4.48%
Overdrafts | 4 279 | 4 223 | (56) | (1.31)% | 4 334 | 55 | 1.29%
Credit cards | 2 065 | 2 001 | (64) | (3.10)% | 2 129 | 64 | 3.10%
Other | 621 | 608 | (13) | (2.09)% | 634 | 13 | 2.09%
| 198 957 | 191 930 | (7 027) | (3.53)% | 205 982 | 7 025 | 3.53%
Public administration |  |  |  |  |  |  |
Loans | 1 351 | 1 216 | (135) | (9.99)% | 1 486 | 135 | 9.99%
Overdrafts | 2 | 2 | - | - | 2 | - | -
Debt securities | 94 | 84 | (10) | (10.64)% | 104 | 10 | 10.64%
Other | 10 | 9 | (1) | (10.00)% | 11 | 1 | 10.00%
| 1 457 | 1 311 | (146) | (10.02)% | 1 603 | 146 | 10.02%
Total due from customers | 340 245 | 326 025 | (14 220) | (4.18)% | 354 463 | 14 218 | 4.18%
Total financial assets at AC | 346 114 | 331 894 | (14 220) | (4.11)% | 360 333 | 14 219 | 4.11%
Financial assets at FVOCI – |  |  |  |  |  |  |
debt securities | 212 | 191 | (21) | (9.91)% | 233 | 21 | 9.91%

Consolidated Financial Statements
94
4.1.11.
Impact of the possible scenarios on the impairment losses and provisions
The behavior of the macroeconomic model is described by two possible scenarios simulating a worsening of
the macroeconomic situation. The scenarios resulted in the increase of expected loss. The simulation was run on
the VUB Group level covering the whole Retail segment – mortgages, consumer loans, credit cards, overdrafts,
car
purchase ﬁnancing and former CFH products (Quatro, Slovenská požičovňa, HRL).
For the purposes of the simulation, the VUB Group formulates three scenarios:
–
BASE – the scenario without stressing macroeconomic inputs. The predictions of the macroeconomic variables
are inputted into the macroeconomic model without any adjustments. Please note that the provisioning values
for December 2025 are not aligned with the ﬁgures used in
BASE scenario, as managerial overlay amounts –
ordinarily included in the year-end totals – were removed solely for the purpose of this analysis;
–
STRESS 10% – the predictions of the macroeconomic variables entering the macroeconomic model are stressed
by 10%;
–
STRESS 30% – the predictions of the macroeconomic variables entering the macroeconomic model are stressed
by 30%.
The expected loss for BASE scenario is at the level of EUR 175 925 ths and the proportion of assets in Stage 2 is at
the level of 6.07%. If the predictions of the macroeconomic variables entering the macroeconomic model are
stressed by 10%, the expected loss would increase to EUR 175 953 ths and the proportion of assets in Stage 2
would stay at the level of 6.07% (negligible increase is not visible due to rounding). A more severe scenario (STRESS
30%) would increase the expected loss to EUR 176 055 ths and the proportion of assets in Stage 2 would increase
to 6.08%.
Scenarios and their impact:

| 2025 | 2024
€ ’000 | BASE | STRESS 10 % | STRESS 30 % | BASE | STRESS 10 % | STRESS 30 %
Gross exposure |  |  |  |  |  |
Retail | 12 429 757 | 12 429 757 | 12 429 757 | 11 778 469 | 11 778 469 | 11 778 469
Expected loss |  |  |  |  |  |
Retail | 175 925 | 175 953 | 176 055 | 178 008 | 178 592 | 180 089
Proportion of assets in Stage 2 |  |  |  |  |  |
(in terms of gross exposure) |  |  |  |  |  |
Retail | 6.07% | 6.07% | 6.08% | 5.67% | 5.71% | 5.89%

4.1.12.
Credit risk of ﬁnancial
derivatives
Credit exposure (or the replacement cost) of derivative ﬁnancial instruments represents the VUB
Group’s credit
exposure from contracts with a positive fair value, that is, it indicates the estimated maximum potential losses in the
event that counterparties fail to perform their obligations. It is usually a small proportion of the notional amounts of
the contracts. The credit exposure of each contract is indicated by the credit equivalent calculated pursuant to the
generally applicable methodology using the current exposure method and involves the market value of the contract
(only if positive, otherwise a zero value is taken into account) and a portion of the nominal value, which indicates
the potential change in market value over the term of the contract. The credit equivalent is established depending
on the type of contract and its maturity.
The VUB Group assesses the credit risk of all ﬁnancial instruments on a daily
basis.
With regard to IFRS 13 (
which contains a clariﬁcation in reference to non
-performance risk in determining the fair
value of over-the-counter derivatives), the VUB Group uses the bilateral Credit Value Adjustment model (‘bCVA’). It
takes into account the effects of changes in counterparty credit ratings as well as the changes in own credit rating.
The bCVA has two addends, calculated by considering the possibility that both counterparties go bankrupt, known
as the Credit Value Adjustment (‘CVA’) and Debit Value Adjustment (‘DVA’):
–
The CVA (negative) takes into account scenarios where the counterparty fails before the VUB Group which has
a positive exposure to the counterparty. In these scenarios, the VUB Group suffers a loss equal to the cost of
replacing/closing the derivative contract,
–
The DVA (positive) takes into account scenarios where the VUB Group fails before the counterparty and has a
negative exposure to the counterparty. In these scenarios, the VUB Group achieves a gain
equal to the cost of
replacing/closing the derivative contract.
Consolidated Financial Statements
95
The bCVA depends on the exposure, probability of default and the loss given default of the counterparties. The VUB
Group is selective in its choice of counterparties and sets limits for transactions with customers. The VUB Group
takes its own and its counterparties’ credit risk into consideration to the extent as it expects from other market
participants.
4.2.
Market risk
Market risk refers to the
potential impact of ﬂuctuations
in market prices—such as interest rates, stock prices, and
exchange rates—on the VUB Group's returns
or the value of its ﬁnancial instruments. The objective of market risk
management is to manage and control market risk exposures within acceptable parameters, while optimizing the
return on risk.
4.2.1.
Management of market risk
The VUB Group separates its exposures to market risk between trading (‘trading book’) and non-trading portfolios
(‘banking book’). Trading portfolios are held by the Trading sub-department and Sales sub-department and include
positions arising from market-making and proprietary position taking. All foreign exchange risk within the VUB Group
is transferred each day to the Trading sub-department and forms part of the trading portfolio for risk management
purposes. The non-trading portfolios are managed by the sub-department Asset Liability Management (‘ALM‘), and
include all positions which are not intended for trading.
Trading portfolios includes derivative
ﬁnancial
instruments used for both trading and hedging and debt securities
classiﬁed
as
ﬁnancial
assets held for trading. Financial instruments with non-trading purpose are part of the banking
book.
Overall authority for market risk is vested in ALCO. The Risk Management Department is responsible for the
development of detailed risk management policies and for their implementation and day-to-day risk monitoring and
reporting.
In the normal course of business, the VUB Group enters into derivative ﬁnancial instrument transactions
to hedge its
liquidity, foreign exchange and interest rate risks. The VUB Group also enters into proprietary
derivative ﬁnancial
transactions for the purpose of generating proﬁts from short
-
term ﬂuctuations in market prices. The VUB Group
operates a system of market risk and counterparty limits, which are designed to restrict exposure to movements in
market prices and counterparty concentrations. The VUB Group also monitors adherence to these limits on a daily
basis.
4.2.2.
Exposure to market risk – trading portfolios
The principal tool used to measure and control market risk exposures within the VUB Group’s trading portfolio is
Value at Risk (‘VaR’). A derivation of VaR is the stress VaR (‘sVaR’) which represents maximal VaR of a selected one-
year period generating the highest value of VaR during a period of at least the last ten years. The VaR of a trading
portfolio represents the estimated loss expected over a given holding period due to adverse market movements,
calculated with a predetermined
conﬁdence level.
The VaR model used by the VUB Group is based upon a 99%
conﬁdence level and assumes a one
-day holding period.
The VaR and sVaR models used are based on historical simulations. Taking into account market data from the previous
year and in case of sVaR a one-year scenario from at least the last ten years of history and observed relationships
between different markets and prices, the models generate a wide range of plausible future scenarios for market
price movements evaluated in the model. The VaR model was approved by the NBS as a basis for the calculation of
the capital charge for market risk of the trading book.
The VUB Group uses VaR limits for total market risk in the trading book, foreign exchange risk and interest rate risk.
The overall structure of VaR and sVaR limits is subject to review and approval by ALCO and Intesa Sanpaolo. VaR is
measured on a daily basis. Daily reports of utilisation of VaR and sVaR limits are submitted to the trading unit, the
head of the Division Risk Management and the head of the Treasury and ALM Department. Regular summaries are
submitted to Intesa Sanpaolo and ALCO.
Consolidated Financial Statements
96
A summary of the VaR and sVaR position of the VUB Group’s trading portfolios:

| 2025 | 2024
€ ‘000 | Balance | Avg | Max | Min | Balance | Avg | Max | Min
Foreign currency risk | 36 | 36 | 98 | 8 | 56 | 58 | 140 | 13
Interest rate risk | 70 | 166 | 358 | 70 | 113 | 200 | 419 | 61
Total VaR | 75 | 172 | 385 | 70 | 114 | 222 | 458 | 64
Total sVaR | 1 053 | 1 394 | 2 292 | 956 | 1 240 | 1 259 | 1 698 | 236

4.2.3.
Exposure to interest rate risk in the banking book
Interest rate risk comprises of the risk that the value of a ﬁnancial instrument will ﬂuctuate due to changes in market
interest rates and the risk that the maturities of interest-earning assets differ from the maturities of interest-bearing
liabilities used to fund those assets. The period for which the interest
rate is ﬁxed
for
a ﬁnancial instrument therefore
indicates the extent to which it is exposed to interest rate risk.
The main risk to which non-
trading portfolios are exposed is the risk of loss from ﬂuctuations in the future cash
ﬂows
and
fair values of ﬁnancial instruments due to a change in market interest rates. Interest rate risk
in the banking
book is managed mainly through the monitoring of interest rate gaps. Financial instruments are mapped to repricing
time buckets either by maturity for
ﬁxed
-rate instruments, or by next repricing date for
ﬂoating
rate instruments.
Assets and liabilities that do not have a contractual maturity date are mapped according to internal models based on
behavioural assumptions.
The Risk Management Department is responsible for monitoring and reporting of interest rate gaps at least on monthly
basis. Interest rate risk in the banking book is measured using the shift sensitivity of fair value (change in present value)
and in terms of net interest income sensitivity. These metrics are utilized for baseline, internal stress and regulatory
scenarios.
Baseline scenarios for the shift sensitivity of fair value are defined as the parallel and instantaneous shift of +/-100 basis
points of the yield curve and four non-parallel shifts of the yield curve. Internal stress scenarios measure the shift sensitivity
of fair value through the parallel and instantaneous shift of +/-200 basis points. Six regulatory scenarios include parallel
up, parallel down, steepening, flattening, short rates up ad short rates down scenarios. For the net interest income
sensitivity, the baseline scenario is represented by parallel and instantaneous +/-50 basis points shock in the yield curve,
in a period of the following 12 months. Internal stress scenarios include +/-100, +/-200 basis points shocks and six
regulatory scenarios, mentioned above, are applied as well.
Overall interest rate risk positions in the banking book are managed by the Treasury and ALM Department, which uses
different on-balance and off-balance sheet instruments to manage the positions arising from the banking book activities.
Models applied for the interest rate risk in the banking book
calculation
Each ﬁnancial instrument is allocated to the time bucket based on its contractual or behavioural repricing date
.
Contractual
This category includes instruments for which the VUB Group knows exactly when the maturity or next repricing takes
place. This approach is applied mainly to purchased and issued securities, received loans and term deposits.
Behavioural
These are items for which it is not exactly known when the maturity or next repricing will take place (e.g. current
accounts). There are also items where the maturity or repricing period is known but it can be assumed that they will
behave differently (e.g. prepayments can occur for mortgages and consumer loans). In this case, it is necessary to
make certain assumptions to reﬂect the behaviour
al characteristics of such items. The assumptions are based on the
detailed analysis of the VUB Group’s historical time series data and statistical models.
Consolidated Financial Statements
97
At 31 December 2025
, the interest margin sensitivity of the banking book on proﬁt or loss in a one
-year time frame,
in the event of a 100 basis points rise in interest rates, was EUR 27 456 thousand (31 December 2024:
EUR 30 334 thousand).
At 31 December 2025
, the interest margin sensitivity of the banking book on proﬁt or loss in a one
-year time frame,
in the event of a 100 basis points decline in interest rates, was EUR 31 877 thousand (31 December 2024:
EUR 35 027 thousand).
At 31 December 2025, the interest rate risk generated by the banking book, measured through shift sensitivity
analysis of plus 100 basis points, reached the value of EUR 34 795 thousand (31 December 2024:
EUR 24 942 thousand).
At 31 December 2025, the interest rate risk generated by the banking book, measured through shift sensitivity
analysis of minus 100 basis points, reached the value of EUR
32 171
thousand (31 December 2024: EUR 22 505
thousand).
At 31 December 2025, the sensitivity of the FVOCI reserve in equity related to the non-hedged part of the portfolio
to 100 basis points rise in interest rates was EUR 322 thousand (31 December 2024: EUR 331 thousand).
4.2.4.
Currency denominations of assets and liabilities
Foreign exchange rate risk comprises the risk that the value of ﬁnancial assets and ﬁnancial liabilities will ﬂuctuate
due to changes in foreign exchange rates. It is the policy of the VUB Group to manage its exposure to ﬂuctuations
in exchange rates through regular monitoring and reporting of open foreign exchange positions and the application
of position exposure in single currencies and overall position limit.
4.3.
Liquidity risk
Liquidity risk is deﬁned as the risk that the VUB Group
will not be able to meet its payment obligations due to its
inability to obtain funds on the market (funding liquidity risk) or liquidate its assets (market liquidity risk). Normally,
the VUB Group can
cover cash outﬂows with cash inﬂows, high
-quality liquid assets and its ability to obtain credit.
The Liquidity Risk Management Policy adopted by the VUB Group outlines the tasks and responsibilities of the various
corporate functions, as well as the control and management processes to ensure a prudent governance of liquidity
risk, preventing crisis situations. It also includes assumptions, measurement metrics and limits related to liquidity risk.
The internal liquidity risk control and management system is based on the following principles.
–
The existence of an operating structure that works within set limits and early warning thresholds and of a control
structure that is independent from the operating structure.
–
A prudential approach in
cash inﬂow and outﬂow projections for all the balance sheet and off
-balance sheet
items, especially those without a contractual maturity.
–
Impact assessment of different
scenarios, including stress testing scenarios, on cash inﬂows and outﬂows over
time and on the adequacy of the liquidity reserve.
–
Constant availability of adequate liquidity reserves in relation to the chosen liquidity risk tolerance threshold.
The VUB Group regularly performs stress testing to evaluate the impact of adverse events on its liquidity position and
on the adequacy of liquidity reserves. The unencumbered high-quality liquid assets are maintained at levels to support
the liquidity position even in case of extraordinary events. The VUB Group can also obtain short-term funding from
the Parent Company or interbank market to maintain its liquidity position.
The Treasury and ALM Department is responsible for ensuring adherence to the Liquidity Risk Management Policy in
terms of liquidity risk management whereas the Risk Management Department is responsible for reporting and
monitoring of liquidity risk indicators. The Liquidity Risk Management Policy consists of three main areas – Short-
Term Liquidity Risk Management, Structural Liquidity Risk Management and Contingency Liquidity Plan that are
essential components of the Internal Liquidity Adequacy Assessment Process.
The Short-Term Liquidity Risk Management includes a set of parameters, limits and thresholds that enable the
measurement, both under normal and stressedmarket conditions, of liquidity risk exposure over the short-term horizon.
The main regulatory indicator in this area is the Liquidity Coverage Ratio that enables to monitor that the VUB Group
maintains an adequate stock of unencumbered high-quality liquid assets to cover its short-term
net cash outﬂows
under stressed conditions lasting 30 calendar days.
Consolidated Financial Statements
98
The Structural Liquidity Risk Management of the VUB Group incorporates a set of measures and limits designed to
control and manage the risks deriving from the mismatch of the medium to long-term maturities of the assets and
liabilities. The main regulatory indicator used in this area is the Net Stable Funding Ratio (NSFR) that represents the
ratio of the available stable funding to the required stable funding.
The goal of the Contingency Liquidity Plan is to protect the VUB Group’s liquidity position, verifying compliance on
an ongoing basis with the risk tolerance, through the identiﬁcation and monitoring of the early warning signals and
the deﬁnition of stra
tegies and intervention tools to be implemented in situations of liquidity stress.
The liquidity position of the VUB Group is presented by the Risk Management Department during the ALCO meetings
on monthly basis.
The table below shows an analysis of assets and liabilities (discounted cash ﬂow basis) according to when they are
expected to be recovered or settled:

| 2025 | 2024
| Less than | Over |  | Less than | Over |
€ ’000 | 12 months | 12 months | Total | 12 months | 12 months | Total
Assets |  |  |  |  |  |
Cash and cash equivalents | 2 149 318 | - | 2 149 318 | 2 272 663 | - | 2 272 663
Financial assets at FVTPL | 34 652 | 131 137 | 165 789 | 16 134 | 175 581 | 191 715
Derivatives – Hedge accounting | 3 407 | 85 631 | 89 038 | 1 583 | 73 983 | 75 566
Financial assets at FVOCI | 46 648 | 1 393 636 | 1 440 284 | 124 097 | 1 365 557 | 1 489 654
Financial assets at AC |  |  |  |  |  |
Due from banks | 340 | 212 735 | 213 075 | 263 986 | 53 952 | 317 938
Due from customers | 3 856 883 | 17 970 439 | 21 827 322 | 3 871 559 | 16 584 393 | 20 455 952
Fair value changes of the hedged items |  |  |  |  |  |
in portfolio hedge of IRR | - | 1 262 | 1 262 | - | 775 | 775
Investments in joint ventures and associates | - | 1 507 | 1 507 | - | 1 197 | 1 197
Property and equipment | - | 111 147 | 111 147 | - | 119 156 | 119 156
Intangible assets | - | 171 311 | 171 311 | - | 173 749 | 173 749
Goodwill | - | 29 305 | 29 305 | - | 29 305 | 29 305
Current income tax assets | 5 155 | - | 5 155 | - | - | -
Deferred income tax assets | - | 61 396 | 61 396 | - | 68 406 | 68 406
Other assets | 54 272 | - | 54 272 | 58 241 | - | 58 241
| 6 150 675 | 20 169 506 | 26 320 181 | 6 608 263 | 18 646 054 | 25 254 317
Liabilities |  |  |  |  |  |
Financial liabilities at FVTPL | (6 737) | (44 296) | (51 033) | (13 239) | (56 702) | (69 941)
Derivatives – Hedge accounting | (15 305) | (85 038) | (100 343) | (14 782) | (158 500) | (173 282)
Financial liabilities measured at AC |  |  |  |  |  |
Due to banks | (46 101) | (1 108 107) | (1 154 208) | (58 709) | (772 659) | (831 368)
Due to customers | (2 150 178) | (15 917 243) | (18 067 421) | (2 205 892) | (14 940 546) | (17 146 438)
Lease liabilities | (6 478) | (15 604) | (22 082) | (6 137) | (15 019) | (21 156)
Subordinated debt | (200 386) | (100 000) | (300 386) | (401) | (300 000) | (300 401)
Debt securities in issue | (1 036 776) | (2 970 446) | (4 007 222) | (751 420) | (3 452 563) | (4 203 983)
Fair value changes of the hedged items |  |  |  |  |  |
in portfolio hedge of IRR | - | 5 770 | 5 770 | - | 8 193 | 8 193
Current income tax liabilities | - | - | - | (44 016) | - | (44 016)
Provisions | - | (27 482) | (27 482) | - | (30 309) | (30 309)
Other liabilities | (166 894) | - | (166 894) | (172 696) | (4 413) | (177 109)
| (3 628 855) | (20 262 446) | (23 891 301) | (3 267 292) | (19 722 518) | (22 989 810)
Net position | 2 521 820 | (92 940) | 2 428 880 | 3 340 971 | (1 076 464) | 2 264 507

Consolidated Financial Statements
99
The remaining maturities of assets and liabilities based on contractual undiscounted cash-
ﬂows were as follows:

2025 | Up to 3 | 3 months |  |  |  |
€ ’000 | months | to 1 year | 1 to 5 years | Over 5 years | Not specified | Total
Financial assets |  |  |  |  |  |
Cash and cash equivalents | 2 149 318 | - | - | - | 2 | 2 149 320
Financial assets at FVTPL |  |  |  |  |  |
(excl. Trading derivatives) | 80 | 30 000 | 82 204 | - | - | 112 284
Financial assets at FVOCI | 4 429 | 28 942 | 888 759 | 532 542 | 287 | 1 454 959
Financial assets at AC |  |  |  |  |  |
Due from banks | - | - | - | 190 230 | - | 190 230
Due from customers | 2 404 721 | 1 390 776 | 6 140 882 | 9 410 191 | 83 602 | 19 430 172
| 4 558 548 | 1 449 718 | 7 111 845 | 10 132 963 | 83 891 | 23 336 965
Financial liabilities |  |  |  |  |  |
Financial liabilities at AC |  |  |  |  |  |
Due to banks | (24 246) | (350) | (302 271) | (750 000) | - | (1 076 867)
Due to customers | (16 739 000) | (1 286 073) | (166 852) | (25 143) | (169) | (18 217 237)
Lease liabilities | (1 231) | (5 314) | (14 634) | (2 125) | - | (23 304)
Subordinated debt | (364) | (200 000) | - | (50 000) | - | (250 364)
Debt securities in issue | (467 965) | (525 132) | (1 995 279) | (1 058 419) | - | (4 046 795)
| (17 232 806) | (2 016 869) | (2 479 036) | (1 885 687) | (169) | (23 614 567)
Net position of financial instruments* | (12 674 258) | (567 151) | 4 632 809 | 8 247 276 | 83 722 | (277 602)
Cash inflows from derivatives | 405 695 | 123 244 | 77 770 | - | - | 606 709
Cash outflows from derivatives | (405 942) | (123 026) | (78 163) | - | - | (607 131)
Net position from derivatives | (247) | 218 | (393) | - | - | (422)
Net position from loan commitments |  |  |  |  |  |
and financial guarantees | (5 830 124) | - | - | - | - | (5 830 124)

* The high negative liquidity gap in the ﬁrst bucket is caused by a huge volume of deposits on demand (without contractual m
aturity) which are
presented under ‘Due to customers’. For the purpose of internal liquidity management monitoring, the behavioural
proﬁle of on
-demand deposits
is taken into account based on a statistical model using internal historical data. Such deposits are then placed into later buckets (see the previous
table) according to when they are expected to be settled.
Consolidated Financial Statements
100

2024 | Up to 3 | 3 months |  |  |  |
€ ’000 | months | to 1 year | 1 to 5 years | Over 5 years | Not specified | Total
Financial assets |  |  |  |  |  |
Cash and cash equivalents | 2 272 663 | - | - | - | - | 2 272 663
Financial assets at FVTPL |  |  |  |  |  |
(excl. Trading derivatives) | 6 947 | - | 106 670 | 22 190 | 3 378 | 139 185
Financial assets at FVOCI | 17 090 | 132 608 | 733 058 | 789 853 | 225 | 1 672 834
Financial assets at AC |  |  |  |  |  |
Due from banks | 215 896 | 50 301 | - | 49 030 | - | 315 227
Due from customers | 2 423 381 | 2 035 649 | 8 088 227 | 11 882 565 | 75 583 | 24 505 405
| 4 935 977 | 2 218 558 | 8 927 955 | 12 743 638 | 79 186 | 28 905 314
Financial liabilities |  |  |  |  |  |
Financial liabilities at AC |  |  |  |  |  |
Due to banks | (61 952) | (11 826) | (572 376) | (222 887) | - | (869 041)
Due to customers | (15 818 025) | (1 316 576) | (181 923) | (16 305) | (327) | (17 333 156)
Lease liabilities | (1 772) | (4 409) | (13 707) | (2 167) | - | (22 055)
Subordinated debt | (4 267) | (13 843) | (220 674) | (53 403) | - | (292 187)
Debt securities in issue | 11 972 | (786 459) | (3 076 264) | (720 173) | - | (4 570 924)
| (15 874 044) | (2 133 113) | (4 064 944) | (1 014 935) | (327) | (23 087 363)
Net position of financial |  |  |  |  |  |
instruments* | (10 938 067) | 85 445 | 4 863 011 | 11 728 703 | 78 859 | 5 817 951
Cash inflows from derivatives | 400 008 | 158 379 | 127 891 | - | - | 686 278
Cash outflows from derivatives | (401 170) | (157 327) | (127 584) | - | - | (686 081)
Net position from |  |  |  |  |  |
derivatives | (1 162) | 1 052 | 307 | - | - | 197
Net position from loan commitments |  |  |  |  |  |
and financial guarantees | (5 682 652) | - | - | - | - | (5 682 652)

* The high negative liquidity gap in the ﬁrst bucket is caused by a huge volume of deposits on demand (without contractual m
aturity) which are
presented under ‘Due to customers’. For the purpose of internal liquidity management monitoring,
the behavioural proﬁle of on
-demand deposits
is taken into account based on a statistical model using internal historical data. Such deposits are then placed into later buckets (see the previous
table) according to when they are expected to be settled.
4.4.
Operational risk
Operational risk is the risk of loss resulting from inadequate or failed internal processes, people and systems or from
external events. Operational risk includes legal risk and compliance risk, model risk, information and communication
technology risk and
ﬁnancial reporting risk; strategic and reputational
risks are not included. Operational risk can
arise from legal and regulatory requirements, non-compliance with generally accepted standards of corporate
behaviour and from all of the VUB Group’s operations.
4.4.1.
Operational risk management strategies and processes
The VUB Group, in coordination with Intesa Sanpaolo,
deﬁned
the overall operational risk management framework
by setting up a VUB Group policy and organisational process for measuring, managing and controlling operational
risk.
The control of operational risk was attributed to the Operational Risk Committee, which
identiﬁes
risk management
policies. The Supervisory and Management Boards of the VUB Group ensure the functionality, ef
ﬁciency and
effectiveness of the risk management and controls system.
Consolidated Financial Statements
101
The Operational Risk Committee (composed of the heads of the areas of the governance centre (Chief Executive
Officer,
Deputy Chief Executive Ofﬁcer) and of the business areas more involved in operational risk management
(voting members: CRO, CFO, COO, Head of Compliance and AML Department; permanent invitees without voting
rights
:
Head of Corporate & SME Division, Head of Retail Division, Head of Risk Management Department, Head of
Legal Department, Head of Human Resources & Organization Department, Head of Information Security sub-
department) is tasked with periodically reviewing the VUB Group’s
overall operational risk proﬁle, authorising any
corrective actions, coordinating and monitoring the effectiveness of the main mitigation activities and approving the
operational risk transfer strategies. The VUB Group, in coordination with its parent company, uses a traditional tool
for transferring operational risk through insurance contracts (bank insurance), with the main objective being to
mitigate the impact of unexpected operational losses arising from the risks covered by this insurance.
4.4.2.
Organisational structure of the associated risk management function
For some time, the VUB Group has had a centralised function within the Risk Management Division for the
management of the VUB Group’s operational risks. This function is responsible, in coordination with the Parent
Company,
for the deﬁnition, implementation and monitoring of the methodological and organisational
framework,
as well as for the measurement of the risk
proﬁle,
the
veriﬁcation
of mitigation effectiveness and reporting to senior
Management. In compliance with current requirements, the individual organisational units participate in the process
and each of them is responsible for the identiﬁcation, assessment, management and mitigation of its o
perational
risks. Speciﬁc ofﬁces and departments have been identiﬁed within these organisational units to be responsible for
Operational Risk Management. These functions are responsible for the collection and structured census of
information relating to operational events, scenario analyses and evaluation of the level of risk associated with the
business environment, including information and communication technology risk. The Risk Management Division
carries out second level monitoring of these activities.
4.4.3.
Scope of application and characteristics of the risk measurement and reporting system
Based on the implementation of Basel IV (‘CRR 3‘) effective from 1 January 2025, VUB Group began using a new
standardized approach to operational risk, known as the Business Indicator Component (BIC) approach, to calculate
its own funds requirements for operational risk (‘Standardized approach based on the Business Indicator Component
BIC‘). At the same time, all previously used approaches, including internal models, have been eliminated.
Operational risks are monitored using an integrated reporting system that provides management with the
information necessary to manage and/or mitigate operational risk. In addition to the management system required
by regulatory requirements, the VU
B Group has an operational risk management system in place, which is certiﬁed
annually as part of a self-assessment process. The results of this process are submitted to the Operational Risk
Committee for annual veriﬁcation.
5.
Estimated fair value of ﬁnancial assets and ﬁnancial liabilities
See accounting policy in note 3.4.7.
The VUB Group applies the following fair value hierarchy, which categorizes the inputs to valuation techniques used
to measure fair value into three levels:
Level 1:inputs represented by quoted prices (unadjusted) in active markets for identical assets or liabilities accessible
by the VUB Group as at the measurement date;
Level 2:inputs other than quoted prices included in Level 1 that are directly or indirectly observable for the assets or
liabilities to be measured; and
Level 3:inputs unobservable for the asset or liability.
The highest priority is given to effective market quotes (level 1) for the valuation of assets and liabilities or for similar
assets and liabilities measured using valuation techniques based on market-observable parameters other than
ﬁnancial instruments quotes (level 2) and the lowe
st priority to unobservable inputs (level 3). Following this hierarchy,
where available, fair value estimates made by the VUB Group are based
on quoted market prices. However, no
readily available market prices exist for a sign
iﬁcant portion of
the VUB Group’s
ﬁnancial instruments. In circumstances
where the quoted market prices are not readily available, fair value is estimated using discounted cash ﬂow models
or other pricing models as appropriate.
Consolidated Financial Statements
102
Under level 2, the principal valuation technique used by the VUB Group for debt instruments involves the method of
discounting future cash ﬂows. The calculation takes into account the time value of money
(risk free rate of interest)
and the credit risk expressed in the form of credit spreads applied to the bonds’ yield and representing the risk
premium the investor claims against a risk-free investment. In the case of derivative
ﬁnancial
instruments, the VUB
Group uses standard fair value calculation models based on the principal net present value using the yield curve to
discount all future cash
ﬂows
from derivatives for all relevant currencies. The principal input parameters used by the
models comprise interest rate curves, volatility curves, spot and forward prices and the correlation between
underlying assets. Changes in underlying assumptions, including discount rates and estimated fu
ture cash ﬂows,
affect the estimates
signiﬁcantly
. The VUB Group also considers its own and counterparty’s credit risk.
The valuation technique deﬁned for a ﬁnancial instrument is adopted over time and is modiﬁed only following
signiﬁcant changes in market conditions or the subjective conditions related to the issuer of the ﬁnancial instrument.
The VUB Group monitors t
he occurrence of these changes and accordingly reassesses the classiﬁcation into the fair
value hierarchy. For determining the timing of the transfers between the levels, the VUB Group uses the end of the
reporting period as the day when the transfer is deemed to have occurred.
In estimating the fair value of the VUB Group’s ﬁnancial instruments, the following methods and assumptions were
used:
Cash and cash equivalents
The carrying values of cash and cash equivalents are deemed to approximate their fair value.
Due from banks
The fair value of due from banks balances with maturities more than one year is estimated using discounted cash
ﬂow analyses, based upon the risk
-
free interest rate curve. For maturities up to one year and not signiﬁcant balances,
the carrying amounts of amounts due from banks approximate their fair value.
Due from customers
The fair value of loans and advances to customers is estimated using discounted cash ﬂow analyses, based on the
risk-
free interest rate curve and risk reﬂecting
creditworthiness of the counterparty. Impairment losses are taken into
consideration when calculating fair values.
Purchased debt securities
The carrying values of cash and cash equivalents are deemed to approximate their fair value.
Due to banks
The carrying amounts of due to banks approximates their fair value. The fair value of due to banks is estimated by
discounting their future expected cash ﬂows using
relevant discount interest rate curve.
Debt securities in issue
The fair value of debt securities issued by the VUB Group is based on quoted market prices. Where no market prices
are available, the fair value was calculated by discounting future cash
ﬂows
using the risk-free interest rate curve
adjusted by credit spreads reﬂecting the credit quality of VUB as the
issuer.
Consolidated Financial Statements
103

|  | Carrying amount | Fair value
|  |  |  | Total |  |  |  |
2025 |  | At amortised |  | carrying |  |  |  | Total
€ ’000 | Note | cost | At fair value | amount | Level 1 | Level 2 | Level 3 | fair value
Financial assets |  |  |  |  |  |  |  |
Cash and cash equivalents | 7 | 2 149 318 | - | 2 149 318 | - | 2 149 165 | - | 2 149 165
Financial assets at FVTPL | 8 | - | 165 789 | 165 789 | 114 169 | 51 620 | - | 165 789
Derivatives – Hedge |  |  |  |  |  |  |  |
accounting | 9 | - | 89 038 | 89 038 | - | 89 038 | - | 89 038
Financial assets at FVOCI | 10 | - | 1 440 284 | 1 440 284 | 1 419 148 | 21 136 | - | 1 440 284
Financial assets at AC | 11 |  |  |  |  |  |  |
Due from banks |  | 213 075 | - | 213 075 | - | 212 249 | - | 212 249
Due from customers |  | 21 827 322 | - | 21 827 322 | 1 677 807 | 764 371 | 21 246 996 | 23 689 174
|  | 24 189 715 | 1 695 111 | 25 884 826 | 3 211 124 | 3 287 579 | 21 246 996 | 27 745 699
Financial liabilities |  |  |  |  |  |  |  |
Financial liabilities at FVTPL | 8 | - | 51 033 | 51 033 | - | 51 033 | - | 51 033
Derivatives – Hedge |  |  |  |  |  |  |  |
accounting | 9 | - | 100 343 | 100 343 | - | 100 343 | - | 100 343
Financial liabilities at AC | 11 |  |  |  |  |  |  |
Due to banks |  | 1 154 208 | - | 1 154 208 | - | 1 159 692 | - | 1 159 692
Due to customers |  | 18 067 421 | - | 18 067 421 | - | 18 062 535 | - | 18 062 535
Lease liabilities |  | 22 082 | - | 22 082 | - | 22 082 | - | 22 082
Subordinated debt |  | 300 386 | - | 300 386 | - | 310 655 | - | 310 655
Debt securities in issue |  | 4 007 222 | - | 4 007 222 | - | 4 074 558 | - | 4 074 558
|  | 23 551 319 | 151 376 | 23 702 695 | - | 23 780 898 | - | 23 780 898

|  | Carrying amount | Fair value
|  |  |  | Total |  |  |  |
2024 |  | At amortised |  | carrying |  |  |  | Total
€ ’000 | Note | cost | At fair value | amount | Level 1 | Level 2 | Level 3 | fair value
Financial assets |  |  |  |  |  |  |  |
Cash and cash equivalents | 7 | 2 272 663 | - | 2 272 663 | - | 2 272 379 | - | 2 272 379
Financial assets at FVTPL | 8 | - | 191 715 | 191 715 | 122 784 | 68 931 | - | 191 715
Derivatives – Hedge |  |  |  |  |  |  |  |
accounting | 9 | - | 75 566 | 75 566 | - | 75 566 | - | 75 566
Financial assets at FVOCI | 10 | - | 1 489 654 | 1 489 654 | 1 476 561 | 13 093 | - | 1 489 654
Financial assets at AC | 11 |  |  |  |  |  |  |
Due from banks |  | 317 938 | - | 317 938 | - | 317 198 | - | 317 198
Due from customers |  | 20 455 952 | - | 20 455 952 | 777 210 | 618 820 | 20 823 300 | 22 219 330
|  | 23 046 553 | 1 756 935 | 24 803 488 | 2 376 555 | 3 365 987 | 20 823 300 | 26 565 842
Financial liabilities |  |  |  |  |  |  |  |
Financial liabilities at FVTPL | 8 | - | 69 941 | 69 941 | - | 69 941 | - | 69 941
Derivatives – Hedge |  |  |  |  |  |  |  |
accounting | 9 | - | 173 282 | 173 282 | - | 173 282 | - | 173 282
Financial liabilities at AC | 11 |  |  |  |  |  |  |
Due to banks |  | 831 368 | - | 831 368 | - | 825 127 | - | 825 127
Due to customers |  | 17 146 438 | - | 17 146 438 | - | 17 138 502 | - | 17 138 502
Lease liabilities |  | 21 156 | - | 21 156 | - | 21 156 | - | 21 156
Subordinated debt |  | 300 401 | - | 300 401 | - | 323 560 | - | 323 560
Debt securities in issue |  | 4 203 983 | - | 4 203 983 | - | 4 244 278 | - | 4 244 278
|  | 22 503 346 | 243 223 | 22 746 569 | - | 22 795 846 | - | 22 795 846

There were no
transfers of ﬁnancial instruments among the levels
during 2025 and 2024.
Consolidated Financial Statements
104
6.
Segment reporting
The VUB Group reports ﬁnancial and descriptive information about its operating segments in the ﬁnancial
statements. An operating segment is a component of the VUB Group that engages in business activities from which
it may earn revenues and incur expenses (including revenues and expenses relating to transactions with other
components of the VUB Group), whose operating results are regularly reviewed by the VUB Group’s management to
make decisions about resources to be allocated to the segment and to assess its performance, and for which separate
ﬁnancial information is
available.
The VUB Group operates in three operating segments: Retail Banking, Corporate Banking and Central Treasury. Each
segment is exposed to different risks and differs in the nature of its services, business processes and types of
customers for its products and services.
For all segments the VUB Group reports a measure of segment assets along with liabilities and income and expense
items, a reconciliation of total reportable segment revenues, total
proﬁt
or loss, total assets, liabilities and other
amounts disclosed for reportable segments to corresponding amounts in the VUB Group’s
ﬁnancial statements.
Most of the transactions of the VUB Group are related to the Slovak market. However, the group operates also on
the Czech market via a foreign subsidiary in Prague performing activities especially in corporate banking and Central
Treasury.
Operating segments pay and receive interest to and from the Central Treasury on an arm’s length basis in order to
reﬂect the costs of funding.
Retail Banking includes loans, deposits and other transactions and balances with households, sole traders and small
business segment.
Corporate Banking comprises SME, the Corporate Customer Desk (‘CCD’), Municipalities and Public Sector Entities.
SME includes complex loan structures, deposits and other transactions and balances with SME (company revenue
up to EUR 50 million; if revenue information is not available, bank account turnover is used). The CCD includes
complex loan structures, deposits and other transactions and balances with large corporate customers (company
revenue over EUR 50 million).
Central Treasury ensures the VUB Group’s funding, the issuance of debt securities as well as transactions related to
the trading book.
The VUB Group reported in the column Other a Central Governance Centre that manages the VUB Group’s premises,
equity investments and own equity funds as well as Risk Management that operates the workout loan portfolio.
Unclassiﬁed items are also reported within this
column.
Consolidated Financial Statements
105

|  |  |  | Total |  |
2025 | Retail | Corporate | Central | reportable |  |
€ ’000 | banking | banking | Treasury | segments | Other | Total
External revenue |  |  |  |  |  |
Interest and similar income | 475 387 | 321 513 | 136 290 | 933 190 | 6 086 | 939 276
Interest and similar expense | (56 447) | (120 687) | (155 942) | (333 076) | (17 489) | (350 565)
Inter-segment revenue | (111 151) | (45 945) | 108 500 | (48 596) | 48 596 | -
Net interest income | 307 789 | 154 881 | 88 848 | 551 518 | 37 193 | 588 711
Net fee and commission income (note 25) | 161 382 | 45 131 | 1 266 | 207 779 | 9 406 | 217 185
Net trading result | 6 165 | 7 949 | 10 633 | 24 747 | (5 205) | 19 542
Other operating income | 59 | 2 887 | (1 205) | 1 741 | 1 811 | 3 552
Other operating expense | (12 308) | (3 577) | - | (15 885) | (7 831) | (23 716)
Salaries and employee benefit | (65 768) | (14 968) | (898) | (81 634) | (82 602) | (164 236)
Other administrative expenses* | - | - | - | - | (96 264) | (96 264)
Amortisation | (4 425) | (335) | (14) | (4 774) | (22 360) | (27 134)
Depreciation | (1 869) | (976) | 8 | (2 837) | (9 471) | (12 308)
Profit before provisions, impairment and tax | 391 025 | 190 992 | 98 638 | 680 655 | (175 323) | 505 332
Net modification gain/(loss) | (20 000) | - | - | (20 000) | 56 | (19 944)
Provisions* | - | - | - | - | 55 | 55
Impairment losses | (46 275) | (14 645) | (901) | (61 821) | 5 217 | (56 604)
Net gain /(loss) arising from the derecognition of |  |  |  |  |  |
financial assets at amortised cost | 1 348 | 5 898 | - | 7 246 | (1) | 7 245
Profit before tax | 326 098 | 182 245 | 97 737 | 606 080 | (169 996) | 436 084
Segment assets | 12 362 355 | 7 891 597 | 5 370 643 | 25 624 595 | 695 586 | 26 320 181
Segment liabilities | 11 242 709 | 7 276 603 | 4 964 661 | 23 483 973 | 407 328 | 23 891 301

* The VUB Group does not allocate these items to the individual segments.

|  |  |  | Total |  |
2024 | Retail | Corporate | Central | reportable |  |
€ ’000 | banking | banking | Treasury | segments | Other | Total
External revenue |  |  |  |  |  |
Interest and similar income | 390 344 | 378 509 | 246 316 | 1 015 169 | 571 | 1 015 740
Interest and similar expense | (60 261) | (182 470) | (177 182) | (419 913) | (21 940) | (441 853)
Inter-segment revenue | 30 257 | (25 826) | (78 790) | (74 359) | 74 359 | -
Net interest income | 360 340 | 170 213 | (9 656) | 520 897 | 52 990 | 573 887
Net fee and commission income (note 25) | 137 520 | 40 566 | 966 | 179 052 | 10 342 | 189 394
Net trading result | 6 233 | 7 987 | 3 411 | 17 631 | (700) | 16 931
Other operating income | 83 | 4 049 | (1 185) | 2 947 | 2 183 | 5 130
Other operating expense | (10 334) | (3 310) | 19 | (13 625) | (7 993) | (21 618)
Salaries and employee benefit | (63 224) | (13 585) | (850) | (77 659) | (84 388) | (162 047)
Other administrative expenses* | - | 380 | 218 | 598 | (93 027) | (92 429)
Amortisation | (9 492) | (1 114) | (10) | (10 616) | (22 785) | (33 401)
Depreciation | (2 172) | (1 071) | 5 | (3 238) | (9 678) | (12 916)
Profit before provisions, impairment and tax | 418 954 | 204 115 | (7 082) | 615 987 | (153 056) | 462 931
Net modification gain/(loss) | - | - | - | - | 158 | 158
Provisions* | - | - | - | - | (67) | (67)
Impairment losses | (21 351) | (15 579) | (700) | (37 630) | 806 | (36 824)
Net gain/(loss) arising from the derecognition of |  |  |  |  |  |
financial assets at amortised cost | 692 | (661) | - | 31 | (52) | (21)
Profit before tax | 398 295 | 187 875 | (7 782) | 578 388 | (152 211) | 426 177
Segment assets | 11 777 391 | 8 031 608 | 4 754 377 | 24 563 376 | 690 940 | 25 254 316
Segment liabilities | 10 740 460 | 7 423 716 | 4 346 117 | 22 510 293 | 479 517 | 22 989 810

* The VUB Group does not allocate these items to the individual segments.
Consolidated Financial Statements
106
7.
Cash and cash equivalents
Cash and cash equivalents comprise the following balances:

€ ’000 | 2025 | 2024
Cash in hand | 287 607 | 257 321
Balances at central banks |  |
Compulsory minimum reserves | 163 204 | 154 506
Term deposits | 831 407 | 841 791
Loans and advances | 825 233 | 990 078
Impairment losses | (8) | (10)
| 1 819 836 | 1 986 365
Due from other banks |  |
Current accounts | 41 875 | 28 977
Total cash and cash equivalents | 2 149 318 | 2 272 663

8.
Financial assets and ﬁnancial liabilities at fair value through proﬁt or loss

€ ’000 | 2025 | 2024
Financial assets held for trading |  |
Trading derivatives | 50 612 | 66 101
Government debt securities of European Union countries | 113 636 | 122 204
| 164 248 | 188 305
Non-trading financial assets at fair value through profit or loss |  |
Equity instruments | 1 541 | 3 410
Financial liabilities held for trading |  |
Trading derivatives | 51 033 | 69 941

Equity instruments
classiﬁed as ‘Non
-
trading ﬁnancial assets at fair value through proﬁt or loss‘
comprise shares of
Intesa Sanpaolo S.p.A. in the amount of EUR 533 thousand (31 December 2024: EUR 580 thousand) and form part
of the Group’s incentive plan introduced by the Parent Company in line with the applicable EU capital remuneration
rules (CRD V and, from 2026, CRD VI). The VUB Group did not elect the option to present these instruments at
‘Financial assets at fair value through other comprehensive income‘.

| 2025 | 2024
€ ’000 | Assets | Liabilities | Assets | Liabilities
Trading derivatives – Fair values |  |  |  |
Interest rate instruments |  |  |  |
Forwards and swaps | 45 417 | 45 285 | 55 656 | 59 461
Options | 52 | 50 | 127 | 118
| 45 469 | 45 335 | 55 783 | 59 579
Foreign currency instruments |  |  |  |
Forwards and swaps | 3 763 | 4 318 | 9 271 | 9 298
Options | 571 | 574 | 1 044 | 1 061
| 4 334 | 4 892 | 10 315 | 10 359
Equity and commodity instruments |  |  |  |
Equity options | 456 | 459 | - | -
Commodity forwards and swaps | 353 | 347 | 3 | 3
| 809 | 806 | 3 | 3
Total trading derivatives – fair values | 50 612 | 51 033 | 66 101 | 69 941

Consolidated Financial Statements
107

| 2025 | 2024
€ ’000 | Assets | Liabilities | Assets | Liabilities
Trading derivatives – Notional values |  |  |  |
Interest rate instruments |  |  |  |
Forwards and swaps | 2 020 453 | 2 020 453 | 3 580 043 | 3 580 043
Options | 292 080 | 292 080 | 209 281 | 209 281
| 2 312 533 | 2 312 533 | 3 789 324 | 3 789 324
Foreign currency instruments |  |  |  |
Forwards and swaps | 468 485 | 469 191 | 589 378 | 588 697
Options | 80 634 | 80 634 | 67 543 | 67 543
| 549 119 | 549 825 | 656 921 | 656 240
Equity and commodity instruments |  |  |  |
Equity options | 718 | 718 | - | -
Commodity forwards and swaps | 3 840 | 3 840 | 296 | 296
| 4 558 | 4 558 | 296 | 296
Total trading derivatives – notional values | 2 866 210 | 2 866 916 | 4 446 541 | 4 445 860

9.
Derivatives – Hedge accounting

| 2025 | 2024
€ ’000 | Assets | Liabilities | Assets | Liabilities
Cash flow hedges of interest rate risk | - | 557 | - | 216
Fair value hedges of interest rate, foreign currency and |  |  |  |
inflation risk | 89 038 | 99 786 | 75 566 | 173 066
| 89 038 | 100 343 | 75 566 | 173 282

9.1.
Cash ﬂow hedge related to foreign currency risk
At 31 December 2025 the VUB Group used three currency forwards to hedge the currency risk of an expected future
transaction when transferring the economic result of branch Prague in the amount of
CZK
527 439 thousand
(31 December 2024:
CZK
541 886 thousand). The maturity of this hedging instrument is 14 January 2026. Due to
the nature of the business, hedging inefﬁciency is not expected.

| Assets | Liabilities | Assets | Liabilities |  |
|  |  |  |  | Change in |
|  |  |  |  | fair value |
|  |  |  |  | used for |
|  |  |  |  | calculating | Ineffective-
|  |  |  |  | hedge | ness
2025 |  |  | Notional | Notional | ineffective- | recognised in
€ ’000 | Fair value | Fair value | value | value | ness | profit or loss
Micro hedges |  |  |  |  |  |
Foreign currency instruments |  |  |  |  |  |
Forwards and swaps |  |  |  |  |  |
Cash flow hedge in foreign currency | - | 557 | 21 200 | 21 762 | (594) | -

| Assets | Liabilities | Assets | Liabilities |  |
|  |  |  |  | Change in |
|  |  |  |  | fair value |
|  |  |  |  | used for |
|  |  |  |  | calculating | Ineffective-
|  |  |  |  | hedge | ness
2024 |  |  | Notional | Notional | ineffective- | recognised in
€ ’000 | Fair value | Fair value | value | value | ness | profit or loss
Micro hedges |  |  |  |  |  |
Foreign currency instruments |  |  |  |  |  |
Forwards and swaps |  |  |  |  |  |
Cash flow hedge in foreign currency | - | 216 | 21 300 | 21 516 | - | -

Consolidated Financial Statements
108
9.2.
Fair value hedges of interest rate, foreign currency and inﬂation risk as of date of preparation of the ﬁnancial
statements

| Assets | Liabilities | Assets | Liabilities |  |
|  |  |  |  | Change in |
|  |  |  |  | fair value |
|  |  |  |  | used for |
|  |  |  |  | calculating | Ineffective-
|  |  |  |  | hedge | ness
2025 |  |  | Notional | Notional | ineffective- | recognised in
€ ’000 | Fair value | Fair value | value | value | ness | profit or loss
Micro hedges |  |  |  |  |  |
Interest rate instruments |  |  |  |  |  |
Forwards and swaps |  |  |  |  |  |
Hedge of debt securities at FVOCI | 40 899 | 34 247 | 1 596 011 | 1 596 011 | (2 133) | -
Hedge of corporate loans | - | 2 006 | 143 707 | 143 707 | (3 363) | 34
Hedge of loans received from other banks | - | 1 203 | 50 000 | 50 000 | 1 252 | 16
Hedge of covered bonds | 10 791 | 15 984 | 3 718 094 | 3 718 094 | (3 301) | -
Hedge of debt securities at AC | 20 656 | 6 428 | 1 681 670 | 1 681 670 | 43 800 | -
Foreign currency instruments |  |  |  |  |  |
Forwards and swaps |  |  |  |  |  |
Hedge of corporate loans | 7 998 | - | 166 070 | 157 277 | (1 056) | -
Hedge of debt securities at AC | 7 801 | 9 781 | 438 384 | 436 974 | 1 431 | -
Macro hedges |  |  |  |  |  |
Interest rate instruments |  |  |  |  |  |
Forwards and swaps |  |  |  |  |  |
Hedge of mortgage loans | 880 | 29 102 | 2 083 000 | 2 083 000 | 13 228 | 329
Hedge of current accounts | 13 | 1 035 | 111 000 | 111 000 | 1 098 | (98)

| Assets | Liabilities | Assets | Liabilities |  |
|  |  |  |  | Change in |
|  |  |  |  | fair value |
|  |  |  |  | used for |
|  |  |  |  | calculating | Ineffective-
|  |  |  |  | hedge | ness
2024 |  |  | Notional | Notional | ineffective- | recognised in
€ ’000 | Fair value | Fair value | value | value | ness | profit or loss
Micro hedges |  |  |  |  |  |
Interest rate instruments |  |  |  |  |  |
Forwards and swaps |  |  |  |  |  |
Hedge of debt securities at FVOCI | 49 745 | 37 729 | 1 645 800 | 1 645 800 | (29 418) | -
Hedge of corporate loans | 5 008 | 2 051 | 303 604 | 303 604 | (5 631) | 4
Hedge of loans received from other banks | - | 2 587 | 50 000 | 50 000 | 1 661 | 15
Hedge of covered bonds | 20 493 | 49 944 | 3 594 900 | 3 594 900 | 36 874 | -
Hedge of debt securities at AC | 320 | 21 561 | 787 600 | 787 600 | (13 154) | 1
Foreign currency instruments |  |  |  |  |  |
Forwards and swaps |  |  |  |  |  |
Hedge of corporate loans | - | 9 379 | 166 248 | 176 765 | (1 362) | -
Hedge of debt securities at AC | - | 15 391 | 297 248 | 308 215 | (629) | (7)
Macro hedges |  |  |  |  |  |
Interest rate instruments |  |  |  |  |  |
Forwards and swaps |  |  |  |  |  |
Hedge of mortgage loans | - | 32 004 | 964 000 | 964 000 | (21 475) | (427)
Hedge of current accounts | - | 2 420 | 112 500 | 112 500 | 3 189 | (2)

Consolidated Financial Statements
109
The amounts relating to items designated as hedged items were as follows:

|  |  | Accumulated | Change in fair | Fair value
|  |  | amount of fair | value | adjustment
|  |  | value | used for | after
|  |  | adjustments | calculating | termination of
2025 |  | Carrying | included in | hedge | hedging
€ ’000 | Line item in SOFP | amount | carrying amount | ineffectiveness | relationship
Micro hedges |  |  |  |  |
| Financial assets at FVOCI |  |  |  |
Debt securities at FVOCI |  | 1 336 364 | - | 2 133 | 144
| Financial assets at AC |  |  |  |
Loans and advances |  |  |  |  |
from other banks | Due from banks | - | - | - | -
Corporate loans | Due from customers | 309 778 | 2 | 4 453 | (240)
Debt securities at AC | Due from customers | 2 194 013 | (23 716) | (45 231) | -
| Financial liabilities at AC |  |  |  |
Loans received |  |  |  |  |
from other banks | Due to banks | 50 000 | (887) | 1 236 | -
Covered bonds* | Debt securities in issue | 3 696 372 | (16 796) | (3 301) | (47 887)
Macro hedges |  |  |  |  |
| Financial assets at AC |  |  |  |
Mortgage loans | Due from customers | 2 083 000 | 4 504 | (12 899) | (3 242)
| Financial liabilities at AC |  |  |  |
Current accounts | Due to customers | 111 000 | (1 387) | 1 196 | (4 383)

* Interest rate risk hedging of covered bonds is sometimes closed before the original maturity of the interest rate swap. This is due to the fact
that the interest rate risk position of the VUB Group changed in a way that
required more ﬁxed
-rate liabilities. S
ince the originally ﬁxed
-rate
covered bonds were in the past swapped into ﬂoat
ing rate, these swaps were early terminated in order to achieve the required interest risk
position of the VUB Group.

|  |  | Accumulated | Change in fair | Fair value
|  |  | amount of fair | value | adjustment
|  |  | value | used for | after
|  |  | adjustments | calculating | termination of
2024 |  | Carrying | included in | hedge | hedging
€ ’000 | Line item in SOFP | amount | carrying amount | ineffectiveness | relationship
Micro hedges |  |  |  |  |
| Financial assets at FVOCI |  |  |  |
Debt securities at FVOCI |  | 1 351 153 | - | 29 418 | 155
| Financial assets at AC |  |  |  |
Loans and advances |  |  |  |  |
from other banks | Due from banks | - | - | - | 71
Corporate loans | Due from customers | 480 369 | (10 787) | 6 997 | (287)
Debt securities at AC | Due from customers | 1 095 369 | 21 837 | 13 777 | -
| Financial liabilities at AC |  |  |  |
Loans received |  |  |  |  |
from other banks | Due to banks | 50 000 | (2 123) | 1 646 | -
Covered bonds* | Debt securities in issue | 3 364 009 | (75 660) | 36 874 | -
Macro hedges |  |  |  |  |
| Financial assets at AC |  |  |  |
Mortgage loans | Due from customers | 964 000 | 17 944 | 21 048 | (17 169)
| Financial liabilities at AC |  |  |  |
Current accounts | Due to customers | 112 500 | (2 582) | 3 191 | (5 611)

* Interest rate risk hedging of covered bonds is sometimes closed before the original maturity of the interest rate swap. This is due to the fact
that the interest rate risk position of the VUB Group changed in a way, which required more
ﬁxed
-rate liabilities. S
ince the originally ﬁxed
-rate
covered bonds were in the past swapped into ﬂoat
ing rate, these swaps were early terminated in order to achieve the required interest risk
position of the VUB Group.
Consolidated Financial Statements
110
Maturity of notional values of hedging instruments designated as fair value hedges and their average interest rates:

| 2025 | 2024
| Less |  | More | Less |  | More
€ ’000 | than 1 year | 1 to 5 years | than 5 years | than 1 year | 1 to 5 years | than 5 years
Interest rate instruments |  |  |  |  |  |
Forwards and swaps |  |  |  |  |  |
Hedge of debt securities at FVOCI | 20 630 | 1 059 681 | 515 700 | 8 000 | 647 500 | 734 300
| 3.29% | 1.62% | 2.29% | (0.47)% | 0.79% | 1.82%
Hedge of corporate loans | 47 448 | 96 259 | - | 71 471 | 232 133 | -
| 3.66% | 3.16% | - | 3.71% | 2.61% | -
Hedge of debt securities at AC | 31 770 | 50 000 | 1 599 900 | - | 50 000 | 737 600
| 0.98% | 2.16% | 2.61% | - | 2.16% | 2.67%
Hedge of mortgage loans | - | 2 083 000 | - | - | 964 000 | -
| - | 2.59% | - | - | 2.71% | -
Hedge of loans received from other banks | 50 000 | - | - | - | 50 000 | -
| (0.26)% | - | - | - | (0.26)% | -
Hedge of current accounts | 49 500 | 31 500 | 30 000 | 27 000 | 85 500 | -
| 0.64% | 0.72% | 2.32% | 0.56% | 0.68% | -
Hedge of covered bonds | 1 600 000 | 1 065 000 | 1 053 094 | 2 160 000 | 600 000 | 634 900
| 0.87% | 1.41% | 1.89% | 2.98% | (0.28)% | 1.06%
Foreign currency instruments |  |  |  |  |  |
Forwards and swaps |  |  |  |  |  |
Hedge of corporate loans | - | 166 070 | - | 95 140 | 81 625 | -
| - | 3.85% | - | 0.00% | 0.00% | -
Hedge of debt securities at AC | 76 456 | 361 928 | - | 44 211 | 264 005 | -
| 5.60% | 4.78% | - | 2.63% | 0.00% | -

10.
Financial assets at fair value through other comprehensive income

€ ’000 | 2025 | 2024
Government debt securities of European Union countries | 1 304 164 | 1 086 730
of which Italian government debt securities | 164 140 | 101 279
Bank debt securities | 135 833 | 402 699
Equity instruments |  |
Intesa Sanpaolo S.p.A. | 109 | 72
S.W.I.F.T. | 178 | 153
Total equity instruments | 287 | 225
Total financial assets at fair value through other comprehensive income | 1 440 284 | 1 489 654

At 31 December 2025, the debt securities in the total nominal amount of EUR 60 000 thousand were pledged by
the VUB Group to secure collateralized transactions (31 December 2024: EUR 592 100 thousand). These debt
securities were pledged in favour of the ECB within the pool of assets which can be immediately used as collateral
for received funds needed for liquidity management purposes.
Consolidated Financial Statements
111
11.
Financial assets and ﬁnancial liabilities at
amortized cost
11.1.
Due from banks

€ ’000 | Note | 2025 | 2024
Term deposits |  |  |
with contractual maturity over 90 days |  |  |
to other banks |  | - | 5 500
Loans and advances |  |  |
with contractual maturity over 90 days |  |  |
to central banks |  | 86 | 78
to other banks |  | 37 289 | 108 092
|  | 37 375 | 108 170
Cash collateral |  | 182 411 | 210 137
Impairment losses | 21 | (6 711) | (5 869)
|  | 213 075 | 317 938

11.2.
Due from customers

| 2025 | 2024
|  | Impairment |  |  | Impairment |
| Gross | losses | Carrying | Gross | losses | Carrying
€ ’000 | amount | (note 21) | amount | amount | (note 21) | amount
Financial corporations |  |  |  |  |  |
Loans | 923 539 | (3 013) | 920 526 | 924 770 | (392) | 924 378
Overdrafts | 46 | (2) | 44 | 55 | - | 55
Credit cards | 24 | - | 24 | 18 | - | 18
Factoring | 10 082 | (5) | 10 077 | - | - | -
Debt securities | 207 695 | (123) | 207 572 | 393 568 | (96) | 393 472
Other | - | - | - | 1 165 | - | 1 165
Leasing | 31 | - | 31 | 60 | - | 60
| 1 141 417 | (3 143) | 1 138 274 | 1 319 636 | (488) | 1 319 148
Non-financial corporations |  |  |  |  |  |
Loans | 5 138 484 | (96 290) | 5 042 194 | 5 436 735 | (102 961) | 5 333 774
Mortgages | 5 397 | (216) | 5 181 | 7 645 | (203) | 7 442
Overdrafts | 939 015 | (40 602) | 898 413 | 898 495 | (28 645) | 869 850
Credit cards | 5 551 | (362) | 5 189 | 2 385 | (198) | 2 187
Factoring | 127 890 | (1 431) | 126 459 | 129 888 | (1 315) | 128 573
Debt securities | 558 984 | (843) | 558 141 | 229 856 | (165) | 229 691
Other | - | - | - | - | - | -
Leasing | 149 932 | (7 320) | 142 612 | 202 613 | (5 856) | 196 757
| 6 925 253 | (147 064) | 6 778 189 | 6 907 617 | (139 343) | 6 768 274
Retail |  |  |  |  |  |
Loans | 1 552 489 | (136 083) | 1 416 406 | 1 507 892 | (118 807) | 1 389 085
Mortgages | 10 399 712 | (65 064) | 10 334 648 | 9 898 719 | (73 185) | 9 825 534
Overdrafts | 74 596 | (4 139) | 70 457 | 75 747 | (4 279) | 71 468
Credit cards | 94 477 | (1 927) | 92 550 | 94 722 | (2 065) | 92 657
Factoring | 1 | - | 1 | 47 | - | 47
Leasing | 6 506 | (534) | 5 972 | 10 765 | (621) | 10 144
| 12 127 781 | (207 747) | 11 920 034 | 11 587 892 | (198 957) | 11 388 935
Public administration |  |  |  |  |  |
Loans | 342 269 | (1 498) | 340 771 | 197 656 | (1 351) | 196 305
Overdrafts | 2 501 | (3) | 2 498 | 1 085 | (2) | 1 083
Credit cards | 33 | - | 33 | 26 | - | 26
Debt securities | 1 646 957 | (263) | 1 646 694 | 781 068 | (94) | 780 974
Leasing | 830 | (1) | 829 | 1 217 | (10) | 1 207
| 1 992 590 | (1 765) | 1 990 825 | 981 052 | (1 457) | 979 595
Total due from customers | 22 187 041 | (359 719) | 21 827 322 | 20 796 197 | (340 245) | 20 455 952

Consolidated Financial Statements
112
At 31 December 2025, the 20 largest corporate customers represented a total balance of EUR 1 473 838 thousand
(31 December 2024: EUR 1 535 973 thousand), respectively 6.75% (31 December 2024: 7.51%) of the total loan
portfolio.
At 31 December 2025, the debt securities in the total nominal amount of EUR 598 900 thousand were pledged by
the VUB Group to secure collateralized transactions (31 December 2024: EUR 169 300 thousand). These debt
securities were pledged in favour of the ECB within the pool of assets which can be immediately used as collateral
for received funds needed for liquidity management purposes.
The following table sets out a maturity analysis of lease receivables, showing the undiscounted lease payments to
be received after the reporting date.

€ ’000 | 2025 | 2024
Up to one year | 65 020 | 82 575
One to two years | 44 022 | 59 231
Two to three years | 28 885 | 41 127
Three to four years | 16 211 | 25 266
Four to five years | 8 358 | 13 211
Over five years | 6 839 | 10 601
| 169 335 | 232 011
Unearned future finance income on finance leases | (12 067) | (17 356)
Impairment losses | (7 855) | (6 487)
| 149 413 | 208 168

11.3.
Due to banks

€ ’000 | 2025 | 2024
Due to central banks |  |
Current accounts | 812 | 874
Due to other banks |  |
Current accounts | 15 963 | 51 764
Term deposits | 6 627 | 6 941
Loans received from other banks | 1 107 896 | 773 234
Revaluation of fair value hedged loans received | (887) | (2 123)
Cash collateral received | 23 772 | 660
Other deposits | 25 | 18
| 1 153 396 | 830 494
Total due to banks | 1 154 208 | 831 368

‘Loans received from other banks‘ are classi
ﬁed
in full as long
-
term, with contractual maturities
exceeding ﬁve
years.
One loan, with a nominal value of EUR 50 000 thousand, is due in 2026.
The breakdown of ‘Loans received from other banks’ according to the counterparty is presented below:

€ ’000 | 2025 | 2024
Intesa Sanpaolo S. p. A. | 951 083 | 651 199
European Investment Bank | 156 813 | 121 080
European Bank for Reconstruction and Development | - | 955
| 1 107 896 | 773 234

Consolidated Financial Statements
113
11.4.
Due to customers

€ ’000 | 2025 | 2024
Current accounts | 10 696 108 | 10 171 765
Term deposits | 6 545 698 | 6 144 503
Government and municipal deposits | 639 721 | 626 051
Savings accounts | 80 481 | 95 038
Other deposits | 105 413 | 109 081
| 18 067 421 | 17 146 438

11.5.
Subordinated debt
The balance of the subordinated debt as of 31 December 2025 consisted of two loans from INTESA SANPAOLO SPA
with a total nominal value of EUR 100 000 thousand with maturities in 2033 and 2032 and interest rates of 5.298%
and 5.542% (31 December 2024: 6.289% and 5.995%) and one loan from Intesa Sanpaolo Holding International
in the nominal value of EUR 200 000 thousand with maturity in 2026 and an interest rate of 5.320% (31 December
2024: 6.124%).
In accordance with the loan agreement, the loan may be used as an unsecured liability to pay the VUB Group's debts
and may not be repaid before all claims of the VUB Group's unsubordinated creditors have been paid.
11.6.
Debt securities in issue

€ ’000 | 2025 | 2024
Covered bonds | 1 274 833 | 915 634
Covered bonds subject to fair value hedges | 2 797 073 | 3 364 009
| 4 071 906 | 4 279 643
Revaluation of fair value hedged covered bonds | (16 796) | (26 877)
Unamortized part of revaluation related to terminated |  |
fair value hedges | (47 888) | (48 783)
| 4 007 222 | 4 203 983

The repayment of covered bonds is funded by the mortgage loans denominated in EUR provided to customers of
the VUB Group (note 11.2.) and debt securities in FVOCI portfolio (note 10).
11.7.
Changes in ﬁnancial liabilities
The disclosure of changes arising from cash ﬂows and non
-
cash changes in liabilities arising from ﬁnancing activities:

| Loans received |  |  |
| from other banks |  |  |
2025 | (including |  | Subordinated |
€ ’000 | revaluation | Lease liabilities | debt | Covered bonds
1 January | 771 111 | 21 156 | 300 401 | 4 203 983
Cash flow |  |  |  |
Proceeds | 595 000 | - | - | 500 000
Repayments | (260 200) | (6 590) | - | (716 597)
Non-cash changes |  |  |  |
Accruals | 2 334 | - | (15) | 30 812
Revaluation | (1 236) | - | - | (10 976)
Other | - | 7 516 | - | -
31 December | 1 107 009 | 22 082 | 300 386 | 4 007 222

Consolidated Financial Statements
114

| Loans received |  |  |
| from other banks |  |  |
2024 | (including |  | Subordinated |
€ ’000 | revaluation | Lease liabilities | debt | Covered bonds
1 January | 780 595 | 18 307 | 300 487 | 4 436 314
Cash flow |  |  |  |
Proceeds | 100 000 | - | - | 500 000
Repayments | (107 304) | (8 641) | - | (788 000)
Non-cash changes |  |  |  |
Accruals | 57 | - | (86) | 10 054
Revaluation | (1 646) | - | - | 45 615
Other | - | 11 490 | - | -
31 December | 771 111 | 21 156 | 300 401 | 4 203 983

12.
Fair value changes of the hedged items in portfolio hedge of interest rate risk

€ ’000 | 2025 | 2024
Financial assets at AC |  |
Due from customers |  |
Retail |  |
Mortgages | 1 262 | 775
Financial liabilities at AC |  |
Due to customers | (5 770) | (8 193)

13.
Investments in joint ventures and associates

2025 |  |  |  | Carrying
€ ’000 | Share | Cost | Revaluation | amount
Monilogi | 33.00% | 2 549 | (1 162) | 1 387
SBCB | 33.33% | 3 | 117 | 120
|  | 2 552 | (1 045) | 1 507

2024 |  |  |  | Carrying
€ ’000 | Share | Cost | Revaluation | amount
Monilogi | 33.00% | 2 549 | (1 459) | 1 090
SBCB | 33.33% | 3 | 104 | 107
|  | 2 552 | (1 355) | 1 197

Monilogi is the joint venture of the VUB Group for which equity method of consolidation is used and is incorporated
in the Slovak Republic. SBCB is the associate of the VUB Group for which equity method of consolidation is used
and is incorporated in the Slovak Republic.
14.
Property and equipment and non-
current assets classiﬁed as held for sale

2025 | Owned and | Owned and | Right-of-use |
€ ’000 | used | leased | assets | Total
Buildings and land | 68 569 | - | 17 683 | 86 252
Equipment | 4 856 | 2 705 | - | 7 561
Other tangibles | 1 594 | 2 319 | 4 055 | 7 968
Assets under construction | 9 366 | - | - | 9 366
| 84 385 | 5 024 | 21 738 | 111 147

2024 | Owned and | Owned and | Right-of-use |
€ ’000 | used | leased | assets | Total
Buildings and land | 71 535 | - | 18 690 | 90 225
Equipment | 4 538 | 910 | - | 5 448
Other tangibles | 1 171 | 5 113 | 2 149 | 8 433
Assets under construction | 15 050 | - | - | 15 050
| 92 294 | 6 023 | 20 839 | 119 156

Consolidated Financial Statements
115

2025 | Buildings |  | Other | Assets under |
€ ’000 | and land | Equipment | tangibles | construction | Total
Revaluation |  |  |  |  |
At 1 January | 124 237 | 33 126 | 33 531 | 15 050 | 205 944
Transfer to other assets | (9 039) | - | - | - | (9 039)
Additions | 9 173 | 15 | 4 497 | 7 366 | 21 051
Disposals | (10 298) | (3 380) | (7 922) | - | (21 600)
Transfers | 8 160 | 4 078 | 812 | (13 050) | -
Exchange differences | 44 | 4 | 1 | - | 49
At 31 December | 122 277 | 33 843 | 30 919 | 9 366 | 196 405
Accumulated depreciation |  |  |  |  |
At 1 January | (33 997) | (27 678) | (24 877) | - | (86 552)
Transfer to other assets | 3 607 | - | - | - | 3 607
Depreciation for the year | (8 273) | (1 950) | (2 085) | - | (12 308)
Disposals | 2 659 | 3 350 | 4 168 | - | 10 177
Exchange differences | (21) | (4) | (1) | - | (26)
At 31 December | (36 025) | (26 282) | (22 795) | - | (85 102)
Impairment losses (note 21) |  |  |  |  |
At 1 January | (15) | - | (221) | - | (236)
Creation | - | - | (26) | - | (26)
Release | 15 | - | 91 | - | 106
At 31 December | - | - | (156) | - | (156)
Carrying amount |  |  |  |  |
At 1 January | 90 225 | 5 448 | 8 433 | 15 050 | 119 156
At 31 December | 86 252 | 7 561 | 7 968 | 9 366 | 111 147

2024 | Buildings |  | Other | Assets under |
€ ’000 | and land | Equipment | tangibles | construction | Total
Revaluation |  |  |  |  |
At 1 January | 117 088 | 34 202 | 38 507 | 14 239 | 204 036
Transfer to other assets | - | - | - | - | -
Additions | 9 687 | 48 | 759 | 5 701 | 16 195
Disposals | (4 011) | (2 306) | (5 788) | (2 161) | (14 266)
Transfers | 1 492 | 1 184 | 53 | (2 729) | -
Exchange differences | (19) | (2) | - | - | (21)
At 31 December | 124 237 | 33 126 | 33 531 | 15 050 | 205 944
Accumulated depreciation |  |  |  |  |
At 1 January | (26 473) | (28 572) | (26 573) | - | (81 618)
Transfer to other assets | - | - | - | - | -
Depreciation for the year | (9 236) | (1 412) | (2 268) | - | (12 916)
Disposals | 1 707 | 2 304 | 3 964 | - | 7 975
Exchange differences | 5 | 2 | - | - | 7
At 31 December | (33 997) | (27 678) | (24 877) | - | (86 552)
Impairment losses (note 21) |  |  |  |  |
At 1 January | (94) | - | (239) | - | (333)
Creation | - | - | (6) | - | (6)
Release | 79 | - | 24 | - | 103
At 31 December | (15) | - | (221) | - | (236)
Carrying amount |  |  |  |  |
At 1 January | 90 521 | 5 630 | 11 695 | 14 239 | 122 085
At 31 December | 90 225 | 5 448 | 8 433 | 15 050 | 119 156

Consolidated Financial Statements
116
Of which owned and leased property and equipment:

2025 |  | Other | Assets under |
€ ’000 | Equipment | tangibles | construction | Total
Cost |  |  |  |
At 1 January | 1 226 | 11 226 | - | 12 452
Additions | - | - | 2 328 | 2 328
Disposals | (233) | (5 362) | - | (5 595)
Transfers | 2 328 | - | (2 328) | -
At 31 December | 3 321 | 5 864 | - | 9 185
Accumulated depreciation |  |  |  |
At 1 January | (316) | (5 892) | - | (6 208)
Depreciation for the year | (531) | (672) | - | (1 203)
Disposals | 231 | 3 175 | - | 3 406
At 31 December | (616) | (3 389) | - | (4 005)
Impairment losses |  |  |  |
At 1 January | - | (221) | - | (221)
Creation | - | (26) | - | (26)
Release | - | 91 | - | 91
At 31 December | - | (156) | - | (156)
Carrying amount |  |  |  |
At 1 January | 910 | 5 113 | - | 6 023
At 31 December | 2 705 | 2 319 | - | 5 024

2024 |  | Other | Assets under |
€ ’000 | Equipment | tangibles | construction | Total
Cost |  |  |  |
At 1 January | 421 | 15 392 | 2 982 | 18 795
Additions | - | - | - | -
Disposals | (16) | (4 166) | (2 161) | (6 343)
Transfers | 821 | - | (821) | -
At 31 December | 1 226 | 11 226 | - | 12 452
Accumulated depreciation |  |  |  |
At 1 January | (140) | (6 937) | - | (7 077)
Depreciation for the year | (191) | (1 322) | - | (1 513)
Disposals | 15 | 2 367 | - | 2 382
At 31 December | (316) | (5 892) | - | (6 208)
Impairment losses |  |  |  |
At 1 January | - | (239) | - | (239)
Creation | - | (6) | - | (6)
Release | - | 24 | - | 24
At 31 December | - | (221) | - | (221)
Carrying amount |  |  |  |
At 1 January | 281 | 8 216 | 2 982 | 11 479
At 31 December | 910 | 5 113 | - | 6 023

Consolidated Financial Statements
117
Of which right-of-use assets:

| 2025 | 2024
| Buildings | Other |  | Buildings | Other |
€ ’000 | and land | tangibles | Total | and land | tangibles | Total
Cost |  |  |  |  |  |
At 1 January | 47 212 | 3 872 | 51 084 | 39 783 | 3 344 | 43 127
Additions | 9 173 | 4 408 | 13 581 | 9 687 | 712 | 10 399
Disposals | (6 591) | (1 437) | (8 028) | (2 239) | (184) | (2 423)
Exchange differences | 44 | 1 | 45 | (19) | - | (19)
At 31 December | 49 838 | 6 844 | 56 682 | 47 212 | 3 872 | 51 084
Accumulated depreciation |  |  |  |  |  |
At 1 January | (28 522) | (1 723) | (30 245) | (23 804) | (1 314) | (25 118)
Depreciation for the year | (6 251) | (951) | (7 202) | (6 289) | (577) | (6 866)
Disposals | 2 639 | (114) | 2 525 | 1 566 | 168 | 1 734
Exchange differences | (21) | (1) | (22) | 5 | - | 5
At 31 December | (32 155) | (2 789) | (34 944) | (28 522) | (1 723) | (30 245)
Carrying amount |  |  |  |  |  |
At 1 January | 18 690 | 2 149 | 20 839 | 15 979 | 2 030 | 18 009
At 31 December | 17 683 | 4 055 | 21 738 | 18 690 | 2 149 | 20 839

In 2025 the VUB Group reviewed the carrying amount of its property and equipment. An impairment test was carried
out to determine the recoverable amount. As a result of the impairment test the VUB Group recognized release of
impairment loss in the amount of EUR 80 thousand (31 December 2024: release of impairment loss in amount of
EUR 97 thousand).
If ‘Buildings and land’ were measured using the cost model, the carrying amounts would be, as follows:

€ ’000 | 2025 | 2024
Cost | 101 679 | 96 829
Accumulated depreciation | (55 266) | (53 032)
Impairment losses | (15) | (15)
| 46 398 | 43 782

At 31 December 2025, the gross book value of fully depreciated tangible assets that are still used by the VUB Group
amounted to EUR 47 207 thousand (31 December 2024: EUR 49 536 thousand).
The VUB Group’s insurance program covers all standard risks to tangible and intangible assets (theft, robbery, natural
hazards, vandalism and other damages).
Consolidated Financial Statements
118
15.
Intangible assets

|  | Other |  |
2025 |  | intangible | Assets under |
€ ’000 | Software | assets | development | Total
Cost |  |  |  |
At 1 January | 385 821 | 90 513 | 30 435 | 506 769
Additions | 197 | - | 19 280 | 19 477
Transfers | 13 392 | - | (13 392) | -
Exchange differences | 37 | 1 | - | 38
At 31 December | 399 447 | 90 514 | 36 323 | 526 284
Accumulated amortisation |  |  |  |
At 1 January | (311 311) | (16 492) | - | (327 803)
Depreciation for the year | (24 080) | (3 054) | - | (27 134)
Exchange differences | (35) | (1) | - | (36)
At 31 December | (335 426) | (19 547) | - | (354 973)
Impairment losses (note 21) |  |  |  |
At 1 January | - | (5 217) | - | (5 217)
Release | - | 5 217 | - | 5 217
At 31 December | - | - | - | -
Carrying amount |  |  |  |
At 1 January | 74 510 | 68 804 | 30 435 | 173 749
At 31 December | 64 021 | 70 967 | 36 323 | 171 311

|  | Other |  |
2024 |  | intangible | Assets under |
€ ’000 | Software | assets | development | Total
Cost |  |  |  |
At 1 January | 358 603 | 90 515 | 34 035 | 483 153
Additions | 75 | - | 23 561 | 23 636
Transfers | 27 161 | - | (27 161) | -
Exchange differences | (18) | (2) | - | (20)
At 31 December | 385 821 | 90 513 | 30 435 | 506 769
Accumulated amortisation |  |  |  |
At 1 January | (280 592) | (13 828) | - | (294 420)
Depreciation for the year | (30 736) | (2 665) | - | (33 401)
Exchange differences | 17 | 1 | - | 18
At 31 December | (311 311) | (16 492) | - | (327 803)
Impairment losses (note 21) |  |  |  |
At 1 January | - | (5 217) | - | (5 217)
Release | - | - | - | -
At 31 December | - | (5 217) | - | (5 217)
Carrying amount |  |  |  |
At 1 January | 78 011 | 71 470 | 34 035 | 183 516
At 31 December | 74 510 | 68 804 | 30 435 | 173 749

The acquisition of assets mainly includes the development of new software applications and the costs of technical
evaluation of software that have not yet been put into use.
At 31 December 2025, the gross book value of fully amortized intangible assets that are still used by the VUB Group
amounted to EUR 215 542 thousand (31 December 2024: EUR 204 822 thousand).
Consolidated Financial Statements
119
16.
Goodwill

€ ’000 | 2025 | 2024
Retail Banking | 18 871 | 18 871
Corporate Banking | 10 434 | 10 434
| 29 305 | 29 305

The
VUB Group has identiﬁed three cash
-generating units – Retail Banking, Corporate Banking and Central Treasury,
which also represent operating segments used in ‘Segment reporting’ (note 6).
Goodwill allocated to Retail Banking in the amount of EUR 18 871 thousand arose in 2005 on the acquisition of
Consumer Finance Holding, a.s. and was merged into the Bank in 2018.
Goodwill allocated to Corporate Banking related to the VUB Leasing, a.s. and includes both goodwill related to
purchase of the majority (70%) shareholding in the amount of EUR 7 304 thousand in 2007 and goodwill arising
from the purchase of the remaining 30% shareholding in the amount of EUR 3 130 thousand in 2010. This goodwill
was merged into the Bank in 2022.
No impairment losses were created during 2025 and 2024.
17.
Deferred income tax assets and liabilities
Deferred income
taxes are calculated on
all temporary differences using
a
tax rate of
24%
(31 December 2024: 24%) as follows:

2025 |  |  |  | Exchange rate |
€ ’000 | 1 January | Profit/(loss) | Equity | differences | 31 December
Derivative financial instruments – |  |  |  |  |
CF Hedge | 52 | - | 82 | - | 134
Financial assets at FVOCI | 6 122 | - | (6 629) | - | (507)
Financial assets at AC |  |  |  |  |
Due from banks | 1 393 | 202 | - | - | 1 595
Due from customers | 64 735 | 4 967 | - | - | 69 702
Property and equipment | (14 579) | (1 845) | - | - | (16 424)
Intangible assets | (13 070) | (3 646) | - | - | (16 716)
Other assets | 7 | 1 784 | - | - | 1 791
Financial liabilities at AC |  |  |  |  |
Lease liabilities | 5 052 | 232 | - | - | 5 284
Provisions | 5 407 | (790) | - | - | 4 617
Other liabilities | 17 596 | (198) | - | - | 17 398
Other | (4 309) | (120) | (1 066) | 17 | (5 478)
| 68 406 | 586 | (7 613) | 17 | 61 396

2024 |  |  |  | Exchange rate |
€ ’000 | 1 January | Profit/(loss) | Equity | differences | 31 December
Derivative financial instruments – |  |  |  |  |
CF Hedge | 7 | - | 45 | - | 52
Financial assets at FVOCI | 5 138 | - | 984 | - | 6 122
Financial assets at AC |  |  |  |  |
Due from banks | 1 072 | 321 | - | - | 1 393
Due from customers | 63 173 | 1 562 | - | - | 64 735
Property and equipment | (12 206) | (1 718) | (655) | - | (14 579)
Intangible assets | (12 869) | (201) | - | - | (13 070)
Other assets | 7 | - | - | - | 7
Financial liabilities at AC |  |  |  |  |
Lease liabilities | 3 788 | 1 264 | - | - | 5 052
Provisions | 3 224 | 2 183 | - | - | 5 407
Other liabilities | 13 283 | 4 313 | - | - | 17 596
Other | (2 561) | (1 748) | - | - | (4 309)
| 62 056 | 5 976 | 374 | - | 68 406

Consolidated Financial Statements
120
18.
Other assets

€ ’000 | Note | 2025 | 2024
Operating receivables and advances |  | 27 400 | 34 991
Prepayments and accrued income |  | 19 802 | 19 354
Leashold improvement |  | 7 568 | -
Settlement of operations with financial instruments |  | 1 453 | 623
Other tax receivables |  | 1 148 | 6 156
Inventories |  | 427 | 521
Receivables from termination of leasing |  | 208 | 324
Other |  | 335 | 195
Impairment losses | 21 | (4 069) | (3 923)
|  | 54 272 | 58 241

19.
Provisions

€ ’000 | Note | 2025 | 2024
Loan commitments and financial guarantees | 21 | 19 997 | 23 169
Litigation | 23.2 | 6 885 | 6 940
Restructuring provision |  | 400 | -
Other provisions |  | 200 | 200
|  | 27 482 | 30 309

2025 |  |  | Net creation/ |  | Exchange |
€ ’000 | Note | 1 January | (release) | Use | difference | 31 December
Litigation | 23.2 | 6 940 | (53) | (2) | - | 6 885
Restructuring provision | 29 | - | 400 | - | - | 400
Other provisions |  | 200 | - | - | - | 200
|  | 7 140 | 347 | (2) | - | 7 485

2024 |  |  | Net creation/ |  | Exchange |
€ ’000 | Note | 1 January | (release) | Use | difference | 31 December
Litigation | 23.2 | 6 872 | 85 | (18) | 1 | 6 940
Restructuring provision | 29 | - | - | - | - | -
Other provisions |  | 200 | - | - | - | 200
|  | 7 072 | 85 | (18) | 1 | 7 140

20.
Other liabilities

€ ’000 | 2025 | 2024
Various creditors | 53 298 | 63 456
NCI options schemes | 42 569 | 40 408
Settlement with employees | 38 137 | 36 701
VAT payable and other tax payables | 6 491 | 5 759
Severance and Jubilee benefits | 4 862 | 4 413
Accruals and deferred income | 4 039 | 7 377
Settlement of operations with financial instruments | 2 492 | 2 490
Investment certificates | 455 | 466
Share remuneration scheme | 533 | 580
Other | 14 018 | 15 459
| 166 894 | 177 109

At 31 December 2025 and 31 December 2024 there were no overdue balances in ‘Other liabilities’.
Consolidated Financial Statements
121
The movements in social fund liability presented within ‘Settlement with employees’ were as follows:

2025 |  | Creation |  |
€ ’000 | 1 January | (note 29) | Use | 31 December
Social fund | 827 | 2 747 | (2 739) | 835

2024 |  | Creation |  |
€ ’000 | 1 January | (note 29) | Use | 31 December
Social fund | 797 | 3 219 | (3 189) | 827

21.
Movements in impairment losses and provisions for loan commitments and
ﬁnancial guarantees

|  |  |  | Assets |  |  |
2025 |  |  | Net creation/ | Written off/ | Exchange |  |
€ ’000 | Note | 1 January | release | sold | difference | Other | 31 December
Financial assets at FVOCI |  | 212 | 106 | (48) | - | - | 270
Financial assets at AC | 11 |  |  |  |  |  |
Due from banks |  | 5 869 | 839 | - | 3 | - | 6 711
Due from customers |  | 340 245 | 65 630 | (44 893) | (1 263) | - | 359 719
Impairment losses |  |  |  |  |  |  |
according to IFRS 9 |  | 346 326 | 66 575 | (44 941) | (1 260) | - | 366 700
Loan commitments |  |  |  |  |  |  |
and financial guarantees | 19 | 23 169 | (4 641) | - | 1 469 | - | 19 997
Impairment losses and provisions |  |  |  |  |  |  |
according to IFRS 9 |  | 369 495 | 61 934 | (44 941) | 209 | - | 386 697
Property and equipment and non– |  |  |  |  |  |  |
current assets classified as held for |  |  |  |  |  |  |
sale | 14 | 5 453 | (5 282) | (15) | - | - | 156
Other assets | 18 | - | - | - | - | - | -
Total impairment losses and |  |  |  |  |  |  |
provisions for loan commitments |  |  |  |  |  |  |
and financial guarantees |  | 374 948 | 56 652 | (44 956) | 209 | - | 386 853

|  |  |  | Assets |  |  |
2024 |  |  | Net creation/ | Written off/ | Exchange |  |
€ ’000 | Note | 1 January | release | sold | difference | Other | 31 December
Financial assets at FVOCI |  | 232 | (20) | - | - | - | 212
Financial assets at AC | 11 |  |  |  |  |  |
Due from banks |  | 5 109 | 761 | - | (1) | - | 5 869
Due from customers |  | 372 309 | 31 961 | (62 145) | (1 880) | - | 340 245
Impairment losses |  |  |  |  |  |  |
according to IFRS 9 |  | 377 650 | 32 702 | (62 145) | (1 881) | - | 346 326
Loan commitments |  |  |  |  |  |  |
and financial guarantees | 19 | 16 888 | 4 883 | - | 1 398 | - | 23 169
Impairment losses and provisions |  |  |  |  |  |  |
according to IFRS 9 |  | 394 538 | 37 585 | (62 145) | (483) | - | 369 495
Property and equipment and non– |  |  |  |  |  |  |
current assets classified as held for |  |  |  |  |  |  |
sale | 14 | 5 550 | (97) | - | - | - | 5 453
Other assets | 18 | 4 142 | (664) | (57) | 502 | - | 3 923
Total impairment losses and |  |  |  |  |  |  |
provisions for loan commitments |  |  |  |  |  |  |
and financial guarantees |  | 404 230 | 36 824 | (62 202) | 19 | - | 378 871

Consolidated Financial Statements
122
22.
Equity

€ ’000 | 2025 | 2024
Share capital – authorised, issued and fully paid |  |
80 additional ordinary shares of EUR 1 million, not traded | 80 000 | 80 000
89 ordinary shares of EUR 3 319 391.89 each, not traded | 295 426 | 295 426
4 078 108 ordinary shares of EUR 33.20 each, not traded | 135 393 | 135 393
| 510 819 | 510 819
Share premium | 13 719 | 13 719
Reserves | 127 428 | 107 308
Other capital funds | 8 464 | 8 464
Retained earnings (excluding net profit for the year) | 1 498 329 | 1 370 640
| 2 158 759 | 2 010 950

The registered share capital of VUB, a.s. amounts to EUR 510 819 063.81 and was created by the contribution of
the founder designated in the deed of foundation as of the day of its establishment.
In accordance with the law and statutes of the VUB Group, the VUB Group is obliged to contribute at least 10% of
its annual net proﬁt to the ‘Legal reserve fund’ until it reaches 20% of the share capital. Usage of the ‘Legal reserve
fund’ is restricted by the law and the fund can be used for the coverage of the losses of the VUB Group.

€ ’000 | 2025 | 2024
Net profit for the year attributable to shareholders | 270 121 | 253 557

22.1.
Regulatory capital management
The primary objectives of the VUB Group’s capital management are to ensure that the VUB Group complies with
externally imposed capital requirements and that the VUB Group maintains strong credit ratings and healthy capital
ratios in order to support its business and to maximise shareholders’ value.
The VUB Group manages its capital structure and adjusts it in the light of changes in economic conditions and the
risk characteristics of its activities. In order to maintain or adjust the capital structure, the VUB Group may adjust the
amount of dividend payment to shareholders, return capital to shareholders, issue capital securities or other capital
instruments, classiﬁed as Additional Tier 1, or Tier
2. No changes have been made in the objectives, policies and
processes since the previous year.
The VUB Group’s regulatory capital position was determined based on the rules for capital adequacy calculation set
by the CRR Regulation:

€ ’000 | 2025 | 2024
Tier 1 capital |  |
Share capital | 510 819 | 510 819
Share premium | 13 719 | 13 719
Retained earnings* | 1 498 329 | 1 370 640
Profit or loss eligible | 82 118 | 127 594
Legal reserve fund | 102 454 | 102 454
Other capital funds | 8 464 | 8 464
Accumulated other comprehensive income | 24 974 | 4 854
(-) Value adjustments due to the requirements for prudent valuation | (143) | (264)
Less goodwill and intangible assets | (158 905) | (164 491)
(-) Insufficient coverage for non-performing exposures | (4 597) | (2 454)
| 2 077 232 | 1 971 335
Tier 2 capital |  |
IRB excess of provisions over expected losses eligible | 44 507 | 42 850
Subordinated debt | 139 094 | 179 305
| 183 600 | 222 155
Total regulatory capital | 2 260 832 | 2 193 490

* Excluding net proﬁt for the period, proﬁt in approval and other capital funds
:

€ ’000 | 2025 | 2024
Retained earnings | 1 768 450 | 1 624 197
Net profit for the year | (270 121) | (253 557)
| 1 498 329 | 1 370 640

Consolidated Financial Statements
123

| 2025 | 2024
€ ’000 |  | Required |  | Required
Tier 1 capital | 2 077 232 | 825 114 | 1 971 335 | 893 211
Tier 2 capital | 183 600 | 183 600 | 222 154 | 222 154
Total regulatory capital | 2 260 832 | 825 114 | 2 193 489 | 893 211
Total Risk Weighted Assets | 10 313 923 | 10 313 923 | 11 165 139 | 11 165 139
CET 1 capital ratio | 20.14% | 12.09% | 17.66% | 12.09%
Total capital ratio | 21.92% | 16.25% | 19.65% | 16.25%

Regulatory capital consists of Tier 1 capital, which comprises share capital, share premium, retained earnings,
accumulated other comprehensive income, foreign currency translation and reserves. The deducted amounts in Tier
1 capital are: goodwill, intangible assets
, prudential ﬁlters
,
insufﬁcient coverage for non
-performing exposures and
IRB shortfall, if negative. The other component of regulatory capital is Tier 2 capital, which includes subordinated
long-term debt and IRB excess of provisions over expected losses.
Own Funds, risk-weighted assets and the capital ratios as of 31 December
2025 were calculated in accordance with the
harmonised rules and regulations for banks and investment companies contained in Directive (EU) 2019/878 (‘CRD V’)
and in the CRR Regulation of 31 May 2024 (EU) 2024/1623, which transpose the banking supervision standards defined
by the Basel Committee (the Basel 3 Framework) to European Union laws.
Following the Supervisory Review and Evaluation Process (‘SREP’), the ECB annually makes a ﬁnal decision on the
capital requirement that the Bank must comply with on sub-consolidated and individual level. Starting from 1 January
2025
, the overall capital requirement the Bank has to meet in terms of Common Equity Tier 1 ratio is 11.09%. This
is the result:
–
The SREP requirement comprising a minimum Pillar 1 capital requirement of 4.5% and an additional Pillar 2
capital requirement of 0,84%, made up entirely of Common Equity Tier 1;
–
Additional requirements, made up entirely of Common Equity Tier 1, relating to a Capital Conservation Buffer
of 2.5%, an Other Systemically Important Institutions Buffer (‘O-SII Buffer’) of 1.75% and a Countercyclical
buffer (‘CCyB Buffer’) of 1.5%.
CRD V establishes the obligation for the designated national authorities to activate an operational framework for
the deﬁnition of the ratio of the countercyclical capital buffer (‘CCyB’). The ratio is subject to review on a quarterly
basis. Based on the analysis of the reference indicators, the National Bank of Slovakia decided to set the
countercyclical buffer (relating to the exposures towards Slovak counterparties).
Countercyclical buffer, which has been increased after COVID-19 pandemic period back to 1.5%, valid from 1
August 2023 back, remains effective. P2R composition based on CRD V rules is set to 75% Tier 1, out of which 75%
should represent CET 1 (56.25% of P2R). These changes represent from 1 August 2023 capital requirement (without
Pillar 2 Capital Guidance) for CET 1 of 11.09% and capital requirement for Tier 1 of 12.88%.
The Overall Capital Requirement was at VUB Group level, as of 31 December
2025 s
et at 16.
25
% and consists of:
–
Capital requirement for Pillar 1 (8%),
–
Capital requirement for Pillar 2 (P2R 1.5% and Pillar 2 Capital Guidance 1%),
–
Capital requirement for a combined buffer (5.75%), consisting of Capital Conservation Buffer of 2.5%, Other
Systemically Important Institutions Buffer of 1.75% and a Countercyclical Buffer 1.5%.
ECB set the P2G to 1% since 1.1.2024, with no change in 2025, and therefore the Overall Capital Requirement in
force is 16,25% (13.88% for Tier 1 capital ratio and 12.09% for CET1 capital ratio, including the Pillar 2 Guidance).
Since November 2014, the VUB Group has been under the supervision of the European Central Bank.
Internally, within its Risk Appetite framework, the VUB Group has set internal limits for both OCR and CET1, managing
the regulatory capital requirements additionally with an internal management buffer.
Consolidated Financial Statements
124
The prudential treatment of software assets
The VUB Group has adopted prudential approach to software assets based on the Final Report ‘Draft Regulatory
Technical Standards on the prudential approach to software assets under Article 36 of Regulation (EU) 575/2013
(CRR)
‘, EBA/RTS/2020/07, regarding updated version of the Capital Requirements Regulation 2019/876 and Directive
2019/878 (CRR II/CRD V) published in June 2019 concerning the modiﬁed version of article 36(1)b (CRR II) with
regard to own funds requirements for institutions. The VUB Group has adopted the prudential amortization approach
to software assets for the calculation of CET1 at individual and consolidated level starting from December 2020
based on EBA/RTS/2020/07 methodology, which is in line with ISP Group Approach. The prudential amortization
allows the banks not to deduct from CET1 software assets that are prudentially valued (i.e. when the value of software
assets is not negatively affected by status of resolution, insolvency or liquidation). The residual portion of the carrying
amount of software is risk-weighted (100%), in accordance with the current CRR provisions. This approach has also
been established by Commission delegated Regulation (EU) 2020/2176 of 12 November 2020 amending Delegated
Regulation (EU) 241/2014 as regards the deduction of software assets from Common Equity Tier 1 items.
22.1.1.
Implementation of Basel IV
Basel IV implementation relevant for VUB is executed via update of EU Capital Requirements Regulation (‘CRR 3’).
The key changes in CRR 3 include:
–
Credit Risk: Introduction of a new standardized approach for credit risk (SA-CR), which includes changes to the
treatment of almost all exposures classes, with biggest changes probably for the exposures secured by
immovable property. Also, IRB approach includes some changes (notably decrease in the senior debt LGD).
–
Market Risk: A revised market risk framework to better capture the risks associated with trading activities.
–
Operational Risk: Implementation of a new standardized approach for operational risk, known as the Business
Indicator Component (BIC) approach, and removal of all internal models.
–
Credit Valuation Adjustment (CVA) Risk: Redeﬁnition of the CVA risk charge to better reﬂect the risk of
counterparty credit risk.
–
Output Floor: Introduction of an output ﬂoor to ensure that banks’ risk
-weighted assets (RWAs) calculated using
internal models do not fall below a certain percentage of RWAs calculated using standardized approaches.
–
Environmental, Social, and Governance (ESG) Risks: Integration of ESG risks into the regulatory framework,
requiring banks to manage and disclose their ESG risks.
–
Disclosures: Enhanced disclosure requirements to improve transparency and market discipline.
CRR 3 was published in the Ofﬁcial Journal of the European Union on
19 June 2024, and entered into force 20 days
later. The majority of the CRR 3 rules became applicable from 1 January 2025. However, Market Risk framework
changes are postponed by two years by the Commission Delegated Regulation 2025/1496, to be applicable from 1
January 2027.
23.
Off-balance sheet items
23.1.
Issued guarantees and commitments and undrawn credit facilities

€ ’000 | 2025 | 2024
Issued guarantees | 1 184 736 | 1 152 905
Commitments and undrawn credit facilities | 4 640 565 | 4 529 747
of which revocable | 1 399 123 | 1 441 389
| 5 825 301 | 5 682 652

Issued guarantees represent irrevocable assurances that the VUB Group will make payments in the event that a
borrower cannot meet its obligations to third parties. These assurances carry the same credit risk as loans and
therefore the VUB Group recognises provisions for these instruments (note 19).
The primary purpose of commitments to extend credit is to ensure that funds are available to the customer as
required. Commitments and undrawn credit facilities represent undrawn portions of commitments, credit facilities
and approved overdraft loans.
Consolidated Financial Statements
125
23.2.
Legal proceedings
In the normal course of business, the VUB Group is subject to a variety of legal actions. The VUB Group conducted
a review of legal proceedings outstanding against it as of 31 December 2025. Pursuant to this review, management
has recorded total provisions of EUR 6 885 thousand (31 December 2024: EUR 6 940 thousand) in respect of such
legal proceedings (note 19). The VUB Group will continue to defend its position in respect of each of these legal
proceedings.
In addition to the legal proceedings covered by provisions, there are contingent liabilities arising from legal
proceedings in the total amount of EUR 26 800 thousand, as at 31 December 2025 (31 December 2024: EUR 29 717
thousand). This amount represents existing legal proceedings against the
VUB Group
that will most probably not
result in any payments due by the VUB Group.
23.3.
Operating leasing
The following table sets out a maturity analysis of lease receivables, showing the undiscounted lease payments to
be received after the reporting date.

€ ’000 | 2025 | 2024
Up to one year | 265 | 977
One to two years | 158 | 213
Two to three years | 4 | 32
| 427 | 1 222

23.4.
Tax Legislation
Given that several areas of Slovak tax legislation permit more than one interpretation, there is a possibility that the
tax authorities may take a different view on certain transactions carried out within the VUB Group and determine a
tax treatment that differs from the approach applied by the Group.
The tax authorities have not audited the tax periods 2020 to 2024; therefore, there is a risk that additional tax
liabilities may be assessed.
The management of the VUB Group is not aware of any facts or circumstances that would give rise
to signiﬁcant
future costs. Tax periods that have not yet been subject to a tax audit may be reviewed retrospectively, up to and
including the year 2020.
Consolidated Financial Statements
126
24.
Net interest income

€ ’000 | 2025 | 2024
Interest and similar income |  |
Financial assets at FVTPL | 4 388 | 3 335
Financial assets at FVOCI | 37 234 | 31 451
Financial assets at AC |  |
Due from banks | 55 554 | 116 874
Due from customers | 840 940 | 782 325
Derivatives – Hedge accounting | 1 160 | 81 755
| 939 276 | 1 015 740
Interest and similar expense |  |
Financial liabilities at AC |  |
Due to banks | (41 102) | (44 986)
Due to customers and Subordinated debt | (191 301) | (257 296)
Lease liabilities | (417) | (286)
Debt securities in issue | (85 650) | (74 874)
Derivatives – Hedge accounting | (32 070) | (64 368)
Interest expense on assets | (25) | (43)
| (350 565) | (441 853)
Total net interest income | 588 711 | 573 887

€ ’000 | 2025 | 2024
Interest and similar income |  |
Total interest income calculated using the effective interest method | 927 622 | 1 011 972
Other interest income – interest income on finance leases | 7 266 | 433
Other interest income – interest income on financial assets at FVTPL | 4 388 | 3 335
| 939 276 | 1 015 740

€ ’000 | 2025 | 2024
Net interest and similar income |  |
Financial assets at FVOCI | 37 234 | 31 451
Financial assets at AC | 889 203 | 898 723
| 926 437 | 930 174
Financial liabilities at AC | (318 053) | (377 156)

Interest income on impaired loans and advances to customers for 2025 amounted to EUR 20 159 thousand
(2024: EUR 16 990 thousand).
Consolidated Financial Statements
127
25.
Net fee and commission income

2025 |  | Corporate |  |  |
€ ’000 | Retail Banking | Banking | Central Treasury | Other | Total
Fee and commission income |  |  |  |  |
Indirect deposits | 39 109 | 36 | - | 14 337 | 53 482
Current accounts | 47 985 | 3 420 | - | 11 | 51 416
Cards | 42 480 | 1 167 | - | 53 | 43 700
Insurance | 25 843 | 649 | - | 1 | 26 493
Payments and cash management | 13 692 | 12 266 | - | 1 | 25 959
Loans | 13 393 | 9 282 | - | 38 | 22 713
Trade finance | 25 | 7 035 | 1 775 | 17 | 8 852
Structured finance | - | 5 601 | - | - | 5 601
Factoring | 49 | 2 190 | - | - | 2 239
Other | 520 | 6 257 | 1 978 | - | 8 755
| 183 096 | 47 903 | 3 753 | 14 458 | 249 210
Fee and commission expense |  |  |  |  |
Cards | (18 352) | (35) | - | - | (18 387)
Payments and cash management | (2 567) | (9 188) | - | - | (11 755)
Current accounts | - | - | (585) | (604) | (1 189)
Insurance | (661) | - | - | - | (661)
Factoring | (6) | (576) | - | - | (582)
Trade finance | - | - | - | (193) | (193)
Loans | (51) | - | - | (49) | (100)
Structured finance | - | - | - | - | -
Other | (77) | 114 | (1 902) | (4 206) | (6 071)
| (21 714) | (9 685) | (2 487) | (5 052) | (38 938)
Net fee and commission income |  |  |  |  |
under IFRS 15 | 161 382 | 38 218 | 1 266 | 9 406 | 210 272
Income from guarantees under IFRS 9 | - | 6 913 | - | - | 6 913
Total net fee and commission income | 161 382 | 45 131 | 1 266 | 9 406 | 217 185

2024 |  | Corporate |  |  |
€ ’000 | Retail Banking | Banking | Central Treasury | Other | Total
Fee and commission income |  |  |  |  |
Indirect deposits | 33 902 | 32 | - | - | 33 934
Current accounts | 43 777 | 3 361 | - | 11 | 47 149
Cards | 42 357 | 1 012 | - | 40 | 43 409
Insurance | 18 737 | 547 | - | 13 218 | 32 502
Payments and cash management | 16 066 | 13 123 | - | 1 | 29 190
Loans | 7 260 | 9 324 | - | (16) | 16 568
Trade finance | 20 | 7 081 | 1 578 | - | 8 679
Structured finance | - | 1 934 | - | - | 1 934
Factoring | - | 2 018 | - | - | 2 018
Other | 499 | 6 078 | 1 262 | - | 7 839
| 162 618 | 44 510 | 2 840 | 13 254 | 223 222
Fee and commission expense |  |  |  |  |
Cards | (20 714) | (106) | - | - | (20 820)
Payments and cash management | (2 684) | (9 113) | - | - | (11 797)
Current accounts | - | - | (600) | (670) | (1 270)
Insurance | (570) | - | - | (1 011) | (1 581)
Factoring | - | (475) | - | - | (475)
Trade finance | - | (168) | - | - | (168)
Loans | (74) | (19) | - | - | (93)
Structured finance | - | (19) | - | - | (19)
Other | (1 056) | (914) | (1 274) | (1 231) | (4 475)
| (25 098) | (10 814) | (1 874) | (2 912) | (40 698)
Net fee and commission income |  |  |  |  |
under IFRS 15 | 137 520 | 33 696 | 966 | 10 342 | 182 524
Income from guarantees under IFRS 9 | - | 6 870 | - | - | 6 870
Total net fee and commission income | 137 520 | 40 566 | 966 | 10 342 | 189 394

Consolidated Financial Statements
128
26.
Net trading result

€ ’000 | 2025 | 2024
Cross currency swaps | 29 935 | (13 750)
Customer foreign exchange margins | 10 154 | 10 238
Interest rate derivatives | 1 535 | 1 704
Financial assets held for trading – debt securities | 1 044 | 1 720
Non-trading financial assets measured at FVTPL | 392 | 780
Net result from hedging transactions | 281 | (416)
Dividends from equity shares held in FVTPL | 43 | 69
Dividends from equity shares measured at FVOCI | 32 | 19
Other derivatives | 24 | 1
Equity derivatives | (1) | -
Financial assets measured at FVOCI | (4 606) | (364)
Foreign currency derivatives and transactions | (19 291) | 16 930
| 19 542 | 16 931

27.
Other operating income

€ ’000 | 2025 | 2024
Income from operating leasing | 1 372 | 2 242
Net profit from sale of fixed assets | 492 | 926
Financial revenues | 396 | 226
Services | 1 | 7
Other | 1 291 | 1 729
| 3 552 | 5 130

28.
Other operating expenses

€ ’000 | 2025 | 2024
Costs of product support – credit cards | (3 377) | (2 607)
Contribution to the Deposit Protection Fund | (1 725) | (1 614)
Depreciation of leasehold improvements | (1 172) | -
Court fees and expenses and out-of-court settlements | (488) | (496)
Net release of impairment losses to other assets | (310) | -
Other damages | (162) | (623)
Other | (16 482) | (16 278)
| (23 716) | (21 618)

29.
Salaries and employee beneﬁts

€ ’000 | Note | 2025 | 2024
Remuneration |  | (113 711) | (114 539)
Social security costs |  | (46 929) | (44 289)
Social fund |  | (2 747) | (3 219)
Severance and Jubilee benefits |  | (449) | -
Termination benefit | 19 | (400) | -
|  | (164 236) | (162 047)

The VUB Group does not maintain any pension arrangements separate from the pension system established by law
that would require mandatory contributions of a certain percentage of gross salaries to the state-owned social
insurance and privately owned pension funds. These contributions are recognized in the period when salaries are
earned by employees. No further liabilities are arising to the VUB Group from the payment of pensions to employees
in the future.
Consolidated Financial Statements
129
30.
Other administrative expenses

€ ’000 | 2025 | 2024
Third parties' services | (25 345) | (24 849)
Information technologies systems maintenance | (17 878) | (17 118)
Advertising and sponsorship | (6 733) | (6 764)
Archives and documents | (5 010) | (4 888)
Maintenance and repairs | (4 813) | (4 889)
Transport | (4 746) | (4 207)
Rental of buildings and related expenses | (3 962) | (4 086)
Indirect personnel costs and compensation | (3 281) | (3 966)
Energy costs | (3 005) | (3 471)
Electronic data processing system leasing | (2 988) | (2 713)
Value added tax and other taxes | (2 752) | (627)
Telephone and telecommunication costs | (2 543) | (2 395)
Forms and office supplies | (2 440) | (2 504)
Cleaning of premises | (1 481) | (1 435)
Consultations and other fees* | (1 182) | (851)
Security | (1 095) | (1 226)
Cost of legal services | (1 094) | (575)
Other rentals | (1 019) | (1 126)
Postage costs | (892) | (504)
Insurance | (760) | (914)
Information and research | (222) | (234)
Other expenses | (5 137) | (4 786)
Reinvoicing | 2 114 | 1 699
| (96 264) | (92 429)

* ‘Consulting and other fees’
include remuneration for the statutory audit and ﬁnancial statements of
EUR 566 thousand (2024: EUR 394
thousand). The price also includes the fee for the audit of the annual group reporting, ancillary fees, the audit of the cons
olidated ﬁnancial
statements as well as the audit of the VUB Prague branch, VUB Operating Leasing and VUB Generali. Additionally, the remuneration for the audit
in sustainability reporting to EUR 118 thousand (2024: EUR 160 thousand), including ancillary fees. Other audit-related services and non-audit
services performed by the statutory auditor related to limited accounting review of interim
statutory ﬁnancial statements and report packages,
audit of prudential and business regulatory statements as required by Slovak legislation of the extended auditor's report for the National Bank of
Slovakia
, the recommended list in connection with the veriﬁcation of proﬁt at the end of 202
4 for the ECB, the recommended list in connection
with the issues of covered bonds and were amounted to EUR 174 thousand. (2024: EUR 261 thousand). All amounts shown here are without
VAT.
31.
Income tax expense and special levy

€ ’000 | Note | 2025 | 2024
Current income tax |  | (96 973) | (82 100)
Special levy on business in regulated sectors |  | (69 884) | (96 817)
Deferred income tax | 17 | 586 | 5 976
|  | (166 271) | (172 941)

Consolidated Financial Statements
130
The effective tax rate differs from the statutory tax rate in 2025 and in 2024. The reconciliation of the VUB Group’s
proﬁt before tax with the actual corporate income tax is as follows:

€ ’000 | 2025 | 2024
Profit before tax | 436 392 | 426 498
Theoretical tax calculated at the tax rate 24% | (103 644) | (89 565)
Tax impact |  |
Non-taxable income | (128) | 3 406
Impact of the special 16% CIT rate on government bond income | 6 120 | -
Tax non-deductible expenses | (4 550) | (2 907)
Impairment allowances and provisions, net | 1 356 | 8 278
Additional tax of prior years | 1 292 | (815)
Creation of allowances for uncertain realization of deferred tax receivables | 3 167 | 5 479
Income tax expense | (166 271) | (172 941)
of which Special levy on business in regulated sectors | (69 884) | (96 817)
Effective tax for the year | 38.10% | 40.55%
without Special levy on business in regulated sectors | 26.30% | 23.09%

32.
Related parties
Related parties are those counterparties that represent:
–
Key management personnel (
‘
KMP
’), i.e., members of the Management Board of VUB, who have the authority
and responsibility for planning, directing, and controlling the activities of the VUB Group, including close family
members;
–
Joint ventures that are under the joint control of the VUB Group, i.e., Monilogi;
–
Associates in which the VUB Group has signiﬁcant inﬂuence
, and which are neither subsidiaries nor joint
ventures, i.e., SBCB;
–
ISP, i.e., the parent company of VUB, which holds a 100% share in the equity of VUB;
–
ISP Group companies, i.e., companies that are controlled by ISP directly or indirectly, ISP has signiﬁcant or
substantial inﬂuence over them, or they are under joint control (excluding entities under the control or signiﬁcant
inﬂuence of the VUB Group,
which are reported separately).
In considering each possible related party relationship, attention is directed to the substance of the relationship, and
not merely the legal form. The stated transactions have been made under arms-length commercial and banking
conditions.
In 2025
, the remuneration and other beneﬁts provided to members of the
Management Board were
EUR 2 881 thousand (2024: EUR 2 864 thousand) and to members of the Supervisory Board EUR 82 thousand (2024:
EUR 83 thousand).
Consolidated Financial Statements
131
As at 31 December 2025, the outstanding balances with related parties comprised:

2025 |  |  | Intesa | ISP Group |
€ ’000 | KMP | Associates | Sanpaolo | companies | Total
Assets |  |  |  |  |
Cash and cash equivalents | - | - | 24 569 | 673 | 25 242
Financial assets at FVTPL |  |  |  |  |
Financial assets held for trading | - | - | 42 409 | 27 | 42 436
Non-trading financial assets at FVTPL | - | - | 533 | - | 533
Derivatives – Hedge accounting | - | - | 70 358 | - | 70 358
Financial assets at FVOCI | - | - | 15 835 | - | 15 835
Financial assets at AC |  |  |  |  |
Due from banks | - | - | 170 331 | - | 170 331
Due from customers | 1 588 | - | - | 86 673 | 88 261
Other assets | - | - | 49 | 5 119 | 5 168
| 1 588 | - | 324 084 | 92 492 | 418 164
Liabilities |  |  |  |  |
Financial liabilities at FVTPL |  |  |  |  |
Financial liabilities held for trading | - | - | 43 869 | - | 43 869
Derivatives – Hedge accounting | - | - | 75 619 | - | 75 619
Financial liabilities at AC |  |  |  |  |
Due to banks | - | - | 982 091 | 1 845 | 983 936
Due to customers | 987 | 91 | - | 3 626 | 4 704
Subordinated debt | - | - | 100 090 | 200 296 | 300 386
Provisions | - | - | 7 | - | 7
Other liabilities | 533 | - | 2 959 | 924 | 4 416
| 1 520 | 91 | 1 204 635 | 206 691 | 1 412 937

As at 31 December 2024, the outstanding balances with related parties comprised:

2024 |  |  | Intesa | ISP Group |
€ ’000 | KMP | Associates | Sanpaolo | companies | Total
Assets |  |  |  |  |
Cash and cash equivalents | - | - | 23 431 | 534 | 23 965
Financial assets at FVTPL |  |  |  |  |
Financial assets held for trading | - | - | 47 651 | - | 47 651
Non-trading financial assets at FVTPL | - | - | 580 | - | 580
Derivatives – Hedge accounting | - | - | 75 566 | - | 75 566
Financial assets at FVOCI | - | - | 72 | - | 72
Financial assets at AC |  |  |  |  |
Due from banks | - | - | 188 045 | - | 188 045
Due from customers | 2 322 | - | - | 86 670 | 88 992
Other assets | - | - | 97 | 7 316 | 7 413
| 2 322 | - | 335 442 | 94 520 | 432 284
Liabilities |  |  |  |  |
Financial liabilities at FVTPL |  |  |  |  |
Financial liabilities held for trading | - | - | 59 452 | 8 | 59 460
Derivatives – Hedge accounting | - | - | 148 296 | - | 148 296
Financial liabilities at AC |  |  |  |  |
Due to banks | - | - | 698 492 | 1 710 | 700 202
Due to customers | 1 164 | 90 | - | 6 354 | 7 608
Subordinated debt | - | - | 100 095 | 200 306 | 300 401
Provisions | - | - | 5 | - | 5
Other liabilities | 580 | - | 2 871 | 60 | 3 511
| 1 744 | 90 | 1 009 211 | 208 438 | 1 219 483

Consolidated Financial Statements
132
As at 31 December 2025, the outstanding off-balance sheet balances with related parties comprised:

2025 |  |  | Intesa | ISP Group |
€ ’000 | KMP | Associates | Sanpaolo | companies | Total
Commitments and undrawn credit |  |  |  |  |
facilities | 242 | - | 185 422 | 8 | 185 672
Issued guarantees | - | - | 20 537 | 1 315 | 21 852
Received guarantees | - | - | 1 600 | 1 000 | 2 600
Derivative transactions (notional amount |  |  |  |  |
– receivable) | - | - | 11 142 968 | 10 549 | 11 153 517
Derivative transactions (notional amount |  |  |  |  |
– payable) | - | - | 11 142 222 | 10 514 | 11 152 736

As at 31 December 2024, the outstanding off-balance sheet balances with related parties comprised:

2024 |  |  | Intesa | ISP Group |
€ ’000 | KMP | Associates | Sanpaolo | companies | Total
Commitments and undrawn credit |  |  |  |  |
facilities | 47 | - | 178 089 | 8 | 178 144
Issued guarantees | - | - | 25 505 | 5 937 | 31 442
Received guarantees | - | - | 1 600 | 1 000 | 2 600
Derivative transactions (notional amount |  |  |  |  |
– receivable) | - | - | 10 976 570 | 17 370 | 10 993 940
Derivative transactions (notional amount |  |  |  |  |
– payable) | - | - | 10 976 409 | 17 375 | 10 993 784

For the year ended 31 December 2025, the outstanding balances with related parties comprised:

2025 |  |  | Intesa | ISP Group |
€ ’000 | KMP | Associates | Sanpaolo | companies | Total
Income and expense |  |  |  |  |
Interest and similar income | 43 | - | 4 885 | 3 080 | 8 008
Interest and similar expense | (18) | - | (37 818) | (11 268) | (49 104)
Fee and commission income | 1 | 2 | 636 | 33 001 | 33 640
Fee and commission expense | - | - | (140) | (9) | (149)
Net trading result | - | - | 41 538 | 1 217 | 42 755
Other operating income | - | - | 650 | 126 | 776
Other operating expenses | - | - | (60) | - | (60)
Other administrative expenses | - | - | (6 837) | (13 417) | (20 254)
Impairment losses | - | - | (5) | - | (5)
| 26 | 2 | 2 849 | 12 730 | 15 607

For the year ended 31 December 2024, the outstanding balances with related parties comprised:

2024 |  |  | Intesa | ISP Group |
€ ’000 | KMP | Associates | Sanpaolo | companies | Total
Income and expense |  |  |  |  |
Interest and similar income | 60 | - | 5 591 | 2 456 | 8 107
Interest and similar expense | (31) | - | (38 361) | (13 300) | (51 692)
Fee and commission income | 1 | 2 | 119 | 30 315 | 30 437
Fee and commission expense | - | - | (134) | (6) | (140)
Net trading result | - | - | (38 816) | (521) | (39 337)
Other operating income | - | - | 769 | 125 | 894
Other operating expenses | - | - | - | - | -
Other administrative expenses | - | - | (6 730) | (12 992) | (19 722)
Impairment losses | - | - | 1 | - | 1
| 30 | 2 | (77 561) | 6 077 | (71 452)

Consolidated Financial Statements
133
33.
Events after the end of the reporting period
From 31 December 2025
, up to the date when these ﬁnancial statements were
authorized for issue, there were no
further events identiﬁed that would require adjustments to or disclosure in these ﬁnancial statements.
These ﬁnancial statements were
authorized for issue by the Management Board on 3
0
March 2026
. These ﬁnancial
statements will be published and available at the registered ofﬁce of the Bank.
Jozef Kausich
Chairman of the Management Board
Darina Kmeťová
Member of the Management Board
134
Separate financial statements
Separate ﬁnancial statements prepared in accordance with International Financial Reporting Standards
(‘IFRS®’) as
adopted by the European Union (‘EU’) and Independent Auditors’ Report for the year ended 31 December 2025
135
Contents
Independent auditor´s report
....................................................................................................................
136
Separate statement of financial position as at 31 December 2025
................................................................
143
Separate statement of profit or loss and other comprehensive income for the year ended 31 December 2025... 144
Separate statement of changes in equity for the year ended 31 December 2025
............................................
146
Separate statement of cash flows for the year ended 31 December 2025
......................................................
147
1.
Basis of preparation
.......................................................................................................................
149
2.
Changes in accounting policies
........................................................................................................
152
3.
Material accounting policies
............................................................................................................
154
4.
Financial and operational risk management
......................................................................................
170
5.
Estimated fair value of financial assets and financial liabilities
..............................................................
203
6.
Segment reporting
.........................................................................................................................
205
7.
Cash and cash equivalents
..............................................................................................................
207
8.
Financial assets and financial liabilities at fair value through profit or loss
.............................................
207
9.
Derivatives – Hedge accounting
.......................................................................................................
208
10.
Financial assets at fair value through other comprehensive income
......................................................
212
11.
Financial assets and financial liabilities at amortized cost
....................................................................
213
12.
Fair value changes of the hedged items in portfolio hedge of interest rate risk
......................................
216
13.
Investments in subsidiaries, joint ventures and associates
....................................................................
216
14.
Property and equipment and non-current assets classified as held for sale
............................................
216
15.
Intangible assets
............................................................................................................................
219
16.
Goodwill
.......................................................................................................................................
220
17.
Deferred income tax assets and liabilities
..........................................................................................
220
18.
Other assets
..................................................................................................................................
221
19.
Provisions
......................................................................................................................................
221
20.
Other liabilities
..............................................................................................................................
221
21.
Movements in impairment losses and provisions for loan commitments and financial guarantees
............
222
22.
Equity
...........................................................................................................................................
223
23.
Off-balance sheet items
..................................................................................................................
225
24.
Net interest income
........................................................................................................................
227
25.
Net fee and commission income
......................................................................................................
228
26.
Net trading result
...........................................................................................................................
229
27.
Other operating income
.................................................................................................................
229
28.
Other operating expenses
...............................................................................................................
229
29.
Salaries and employee benefits
........................................................................................................
230
30.
Other administrative expenses
.........................................................................................................
230
31.
Income tax expense and special levy
................................................................................................
231
32.
Related parties
..............................................................................................................................
231
33.
Events after the end of the reporting period
.....................................................................................
234
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www.ey.com/sk
Independent Auditor’s Report
To the Shareholder, Supervisory Board, Board of Directors and to the Audit Committee
of Všeobecná
úverová banka, a.s.:
Report on the Audit of the Separate Financial Statements
Opinion
We have audited the separate financial statements of
Všeobecná úverová banka, a.s.
(”the
Bank
”),
which comprise the separate statement of financial position as at 31 December 2025, separate
statement of profit or loss and other comprehensive income, separate statement of changes in equity
and separate statement of cash flows for the year then ended, and notes to the separate financial
statements, including material accounting policy information and other explanatory information.
In our opinion, the accompanying separate financial statements of the Bank give a true and fair view of
the financial position of the Bank as at 31 December 2025, and of its financial performance and its cash
flows for the year then ended in accordance with IFRS accounting standards (International Financial
Reporting Standards) as adopted by the European union.
Basis for Opinion
We conducted our audit in accordance with International Standards on Auditing (ISA). Our
responsibilities under those standards are further described in the
Auditor’s Responsibilities for the Audit
of the Separate Financial Statements section of our report. We are independent of the Bank in
accordance with the International Ethics Standards Board for Accountants’ International Code of Ethics
for Professional Accountants (including International Independence Standards) as adopted by the
Slovak Chamber of Auditors (
“
Code of Ethics for Auditors
”
) within the scope applicable to audits of
financial statements of public interest entities, including the ethical requirements of the Regulation of the
European Parliament and of the Council (EU) No 537/2014 from 16 April 2014 on specific requirements,
as applicable to audits of the financial statements of public interest entities (
“
Regulation No 537/2014
”
)
and Act No. 423/2015 on Statutory Audit and on the amendments and supplements to the Act on
Accounting No. 431/2002, as amended (
“
Act on Statutory Audit
”
), that are relevant to audits of the
financial statements of public interest entities in the Slovak Republic. We have also fulfilled our other
ethical responsibilities in accordance with the Code of Ethics for Auditors, the ethical requirements of
the Regulation No 537/2014 and the Act on Statutory Audit. We believe that the audit evidence we have
obtained is sufficient and appropriate to provide a basis for our opinion.
Key audit matters
Key audit matters are those matters that, in our professional judgment, were of most significance in our
audit of the separate financial statements of the current period. These matters were addressed in the
context of our audit of the separate financial statements as a whole, and in forming our opinion thereon,
and we do not provide a separate opinion on these matters.
Impairment allowances for loans and advances to customers
Due from customers valued at amortized cost less
impairment as at 31 December 2025 amount to
EUR 21 828 029 thousand and represent a
significant portion of the Bank’s total assets. As
disclosed in Note 11.2 (Due from customers) to the
separate financial statements, it included the gross
book value of due from customers valued at
amortized cost of EUR 22 187 409 thousand and
impairment allowance of EUR 359 380 thousand.
Determining the amount and the moment of
recognizing impairment allowances for expected
credit losses requires significant judgments and
complex estimates of the management disclosed in
Note 4.1.2 (Impairment losses) to the separate
financial statements. For performing exposures and
non-performing exposures below EUR 500 thousand
individually, it comprises assumptions built into
statistical credit loss models, such as assessment of
significant increase in credit risk, definition of default,
incorporation
of
forward-looking
information,
calculation of the loss given default parameter and
the recovery rates. For exposures above EUR 500
thousand
individually,
the
Bank
performs
an
individual assessment based on the detailed review
and analysis of the borrower’s situation and for non
-
performing
exposures,
the
judgments
include
identification of loss events other than overdue
payments and estimation of timing and amount of
expected cash flows from repayments and realization
of collaterals.
The individual basis for calculating expected credit
losses
(“
ECL
”),
based
on
probability
-weighted
scenarios, is then used for individually assessed
exposures in Stage 3. Portfolio ECL calculation is
used for all other instances.
Due to the significance of loans and advances in
relation to the total assets and significance of the
management’s judgments and estimates and their
complexity regarding the expected credit losses
described
above,
we
evaluated
impairment
allowances for loans and advances as a key audit
matter.
As part of our audit procedures, we documented our
understanding of the Bank’s credit risk management
policies. We obtained an understanding, evaluated
the design and tested the operating effectiveness of
the internal controls over the approval, recording and
monitoring of the loans, identification of loss events
and
impairment
triggers and
the
process of
calculating impairment allowances for due from
customers.
We reconciled a register of due from customers with
accounting records to assess completeness of the
recognition of due from customers, which creates the
basis for the calculation of impairment allowances for
expected credit losses.
We involved credit risk specialists to assist us with
assessment
of
the
impairment
allowances
methodology, methods, results of the Bank’s tests of
credit risk parameters (so called “back
-
testing”),
credit rating models and credit risk parameter
models, their assumptions and implementation in the
system in accordance with the IFRS 9 requirements.
We evaluated post-model adjustments for expected
credit losses (so called “overlays”) that were recorded
to
address
the
back-testing
results
and
management’s expectations of additional credit
losses in the retail and corporate segment in the light
of economic volatility.
On a selected sample, we analyzed loan exposures
assessed individually by the Bank. For selected
performing exposures, we analyzed the economic
and financial situation of borrowers and fulfillment of
the
terms
of
loan
agreements
to
evaluate
appropriateness
of
the
classification
into
risk
categories, so-called
“
staging
”
. In case of selected
non-performing
exposures,
we
assessed
the
reasonableness of the expected cash flows from
repayments and recoverable amounts of collateral
based on available financial and market data and we
recalculated the individual impairment allowance.
We
performed
analytical
procedures
on
disaggregated data on the quarterly development of
the impairment allowance per portfolios, products and
stages related to the development of the structure
and characteristics of the credit portfolio including the
impairment allowances, reflecting the quality of the
loan portfolio in the light of the impairment allowances
for expected credit losses for loans to customers
aimed at identifying portfolios of loans to customers
with understated impairment provisions.
We involved specialists in the field of IT systems to
assist us with the testing of effectiveness of the
control mechanisms of IT systems, in which the Bank
calculates the credit risk parameters and the
impairment allowances for expected credit losses.
We also assessed the disclosures in Note 4.1.2
(Impairment losses) and Note 11.2 (Due from
customers) regarding expected credit losses for due
from customers included in the separate financial
statements in terms of their completeness and
compliance
with
IFRS
accounting
standards
(International Financial Reporting Standards) as
adopted by the European union.
Responsibilities of Management and Those Charged with Governance for the Separate Financial
Statements
Management is responsible for the preparation and fair presentation of the separate financial statements
in accordance with IFRS accounting standards (International Financial Reporting Standards) as adopted
by the European union, and for such internal control as management determines is necessary to enable
the preparation of separate financial statements that are free from material misstatement, whether due
to fraud or error.
In preparing the separate financial statements, management is responsible for assessing the Bank
’s
ability to continue as a going concern, disclosing, as applicable, matters related to going concern and
using the going concern basis of accounting unless management either intends to liquidate the Bank or
to cease operations, or has no realistic alternative but to do so.
Those charged with governance are responsible for overseeing the Bank
’s financial reporting process.
Auditor’s Responsibilities for the Audit of the Separate Financial Statements
Our objectives are to obtain reasonable assurance about whether the separate financial statements as
a whole are free from material misstatement, whether due to fraud or error, and to issue an auditor’s
report that includes our opinion. Reasonable assurance is a high level of assurance, but is not a
guarantee that an audit conducted in accordance with International Standards on Auditing will always
detect a material misstatement when it exists. Misstatements can arise from fraud or error and are
considered material if, individually or in the aggregate, they could reasonably be expected to influence
the economic decisions of users taken on the basis of these separate financial statements.
As part of an audit in accordance with International Standards on Auditing, we exercise professional
judgment and maintain professional scepticism throughout the audit. We also:
•
Identify and assess the risks of material misstatement of the separate financial statements,
whether due to fraud or error, design and perform audit procedures responsive to those risks,
and obtain audit evidence that is sufficient and appropriate to provide a basis for our opinion.
The risk of not detecting a material misstatement resulting from fraud is higher than for one
resulting from error, as fraud may involve collusion, forgery, intentional omissions,
misrepresentations, or the override of internal control.
•
Obtain an understanding of internal control relevant to the audit in order to design audit
procedures that are appropriate in the circumstances, but not for the purpose of expressing an
opinion on the effectiveness of the Bank
’s internal control.
•
Evaluate the appropriateness of accounting policies used and the reasonableness of accounting
estimates and related disclosures made by management.
•
Conclude on the appropriateness of management’s use of the going concern basis of
accounting and, based on the audit evidence obtained, whether a material uncertainty exists
related to events or conditions that may cast significant doubt on the Bank
’s ability to continue
as a going concern. If we conclude that a material uncertainty exists, we are required to draw
attention in our auditor’s report to the related disclosures in the
separate financial statements
or, if such disclosures are inadequate, to modify our opinion. Our conclusions are based on the
audit evidence obtained up to the date of our auditor’s report. However, future events or
conditions may cause the Bank to cease to continue as a going concern.
•
Evaluate the overall presentation, structure and content of the separate financial statements
including the presented information as well as whether the separate financial statements
capture the underlying transactions and events in a manner that leads to their fair presentation.
We communicate with those charged with governance regarding, among other matters, the planned
scope and timing of the audit and significant audit findings, including any significant deficiencies in
internal control that we identify during our audit.
We also provide those charged with governance with a statement that we have complied with relevant
ethical requirements regarding independence, and to communicate with them all relationships and other
matters that may reasonably be thought to bear on our independence, and where applicable, actions
taken to eliminate threats or safeguards applied.
From the matters communicated with those charged with governance, we determine those matters that
were of most significance in the audit of the separate financial statements of the current period and are
therefore the key audit matters.
We describe these matters in our auditor’s report unless law or regulation precludes public disclosure
about the matter or when, in extremely rare circumstances, we determine that a matter should not be
communicated in our report because the adverse consequences of doing so would reasonably be
expected to outweigh the public interest benefits of such communication.
Report on Other Legal and Regulatory Requirements
Report on Information Disclosed in the Consolidated Annual Report
Management is responsible for the information disclosed in the consolidated annual report, prepared
based on requirements of the Act on Accounting No 431/2002 Coll., as amended by later legislation
(“the Act on Accounting”)
. Our opinion on the separate financial statements expressed above does not
apply to other information contained in the consolidated annual report.
In connection with audit of the separate financial statements it is our responsibility to understand the
information disclosed in the consolidated annual report and to consider whether such information is not
materially inconsistent with audited separate financial statements or our knowledge about the Bank and
its situation obtained in the audit of the separate financial statements, or otherwise appears to be
materially misstated.
We considered whether the Bank
’s
consolidated annual report (except for the requirements related to
sustainability reporting) contains information, disclosure of which is required by the Act on Accounting.
Based on procedures performed during the audit of separate financial statements, in our opinion:
-
Information disclosed in the consolidated annual report prepared for 2025 is consistent with the
separate financial statements for the relevant year,
-
The consolidated annual report (except for the requirements related to sustainability reporting)
contains information based on the Act on Accounting.
Additionally, based on our understanding of the Bank and its situation, obtained in the audit of the
separate financial statements, we are required to disclose whether material misstatements were
identified in the consolidated
annual report, which we received prior to the date of issue of this auditor’s
report. In this regard, there are no findings which we should disclose.
Independent assurance report on the compliance of the presentation of the Separate Financial
Statements with the requirements of the European Single Electronic Format (“ESEF”)
We have been engaged by the Bank to conduct a reasonable assurance engagement to verify the
compliance of the presentation of the separate financial statements of the Bank for the year ended 31
December 2025
included in the Annual Financial Report (“the Presentation of the
Separate Financial
Statements”) with the requirements
of the Commission Delegated Regulation (EU) 2019/815 of 17
December 2018 supplementing Directive 2004/109/EC of the European Parliament and of the Council
with regard to regulatory technical standards on the specification of a single electronic reporting format
(“the ESEF Regulation”).
Description of subject matter and applicable criteria
The Presentation of the Separate Financial Statements has been applied by the management to comply
with the requirements of the ESEF Regulation. The applicable requirements regarding the Presentation
of the Separate Financial Statements are contained in the ESEF Regulation.
The requirements described in the preceding paragraph with respect to the Presentation of the Separate
Financial Statements constitute, in our view, appropriate criteria to form a reasonable assurance
conclusion.
Responsibility of the management and those charged with governance
The management is responsible for the Presentation of the Separate Financial Statements that complies
with the requirements of the ESEF Regulation.
This responsibility includes:
•
preparation of the separate financial statements in XHTML format; and
•
designing, implementing and maintaining internal controls relevant for the preparation of the
Presentation of the Separate Financial Statements which is free from material non-compliance
with the requirements of the ESEF Regulation.
Those charged with governance are responsible for overseeing the Bank
’s financial reporting process,
which also includes the preparation of the separate financial statements that also comply with the
requirements of the ESEF Regulation.
Auditor’s responsibility
Our responsibility is to express a reasonable assurance conclusion whether the Presentation of the
Separate Financial Statements complies, in all material respects, with the requirements of the ESEF
Regulation.
We conducted our reasonable assurance engagement in accordance with the International Standard on
Assurance Engagements 3000 (Revised), Assurance Engagements Other than Audits and Reviews of
Historical Financial Information,
(“the ISAE 3000(R)”), issued by the International Auditing and
Assurance Standards Board (“the IAASB”). This standard requires that we comply
with ethical
requirements, plan and perform procedures to obtain reasonable assurance whether the Presentation
of the Separate Financial Statements complies, in all material respects, with the requirements of the
ESEF Regulation.
The nature, timing, and extent of procedures performed depend on the auditor’s judgment. Reasonable
assurance is a high level of assurance, but it does not guarantee that the service performed in
accordance with ISAE 3000(R) always detects material non-compliance.
Auditor’s quality control and independence requirements
We apply the provisions of International Standard on Quality Management (ISQM) 1 (issued by the
IAASB) and, accordingly, maintain a comprehensive system of quality control, including documented
policies and procedures regarding compliance with ethical requirements, professional standards and
applicable legal and regulatory requirements.
We comply with independence and other ethical requirements of the International Code of Ethics for
Professional Accountants (including International Independence Standards) issued by the International
Ethics Standards Board for Accountants, which is founded on fundamental principles of integrity,
objectivity, professional competence and due care, confidentiality and professional behaviour.
Summary of the work performed
Our planned and performed procedures were aimed at obtaining reasonable assurance that the
Presentation of the Separate Financial Statements complies, in all material respects, with the
requirements of the ESEF Regulation. Our procedures included in particular:
•
obtaining an understanding of the internal control system and processes relevant to the
application of the electronic reporting format of the separate financial statements, including the
preparation of the XHTML format; and
•
verification whether the XHTML format was properly applied.
We believe that the evidence we have obtained is sufficient and appropriate to provide a basis for our
conclusion.
Conclusion
In our opinion, based on the procedures performed, the Presentation of the Separate Financial
Statements complies, in all material respects, with the requirements of the ESEF Regulation.
Other requirements on content of auditor’s report in compliance with Regulation (EU) No. 537/2014 of
the European Parliament and of the Council of 16 April 2014 on specific requirements regarding
statutory audit of public-interest entities
Appointment and approval of Auditor
We were appointed as the statutory auditor by statutory body of the Bank on 24 April 2025 based on
our approval by the General Meeting of Shareholder of the Bank on 18 March 2024.
Total uninterrupted
engagement period, including previous renewals (extension of the period for which we were originally
appointed) and reappointments for the statutory auditor
,
has lasted for 5years.
Consistence with Additional Report to the Audit Committee
Our audit opinion expressed herein is consistent with the additional report to the audit committee of the
Bank, which we issued on 23 February 2026.
Non-audit Services
No prohibited non-audit services referred to in Article 5(1) of Regulation (EU) No. 537/2014 of the
European Parliament and of the Council of 16 April 2014 on specific requirements regarding statutory
audit of public-interest entities were provided and we remain independent from the Bank in conducting
the audit.
In addition to statutory audit services and services disclosed in the consolidated annual report and in
the separate financial statements, no other services were provided by us to the Bank and its controlled
undertakings.
26 February 2026,
except for the section of our report “Independent assurance report on the compliance
of the presentation of the Separate Financial Statements with the requirements of the European Single
Electronic Format (“ESEF”)”, for which the date of our
report is 8 April 2026.
Bratislava, Slovak Republic
Ernst & Young Slovakia, spol. s r.o.
SKAU Licence No. 257
Ing. Dalimil Draganovský, statutory auditor
SKAU Licence No. 893
Separate Financial Statements
143
Separate
statement of ﬁnancial position as
at 31 December 2025
€ ‘000
Note
2025
2024
Assets
Cash and cash equivalents
7
2 144 599
2 272 661
Financial assets at fair value through profit or loss
8
Financial assets held for trading
164 248
188 305
Non-trading financial assets at fair value through profit or loss
1 541
3 410
Derivatives – Hedge accounting
9
89 038
75 566
Financial assets at fair value
through other comprehensive income
10
1 419 326
1 476 714
of which pledged as collateral
53 807
548 012
Financial assets at amortized cost
11
Due from banks
213 075
312 438
Due from customers
21 828 029
20 458 105
of which pledged as collateral
612 239
178 495
Fair value changes of the hedged items
in portfolio hedge of interest rate risk
12
1 262
775
Investments in subsidiaries, joint ventures and associates
13
26 980
28 314
Property and equipment
14
105 988
113 844
Intangible assets
15
100 352
105 077
Goodwill
16
29 305
29 305
Current income tax assets
5 894
-
Deferred income tax assets
17
78 860
83 024
Other assets
18
44 798
49 192
26 253 295
25 196 730
Liabilities
Financial liabilities at fair value through profit or loss
8
Financial liabilities held for trading
54 233
78 343
Derivatives – Hedge accounting
9
100 343
173 282
Financial liabilities at amortized cost
11
Due to banks
1 154 208
831 368
Due to customers
18 067 452
17 146 472
Lease liabilities
22 147
22 046
Subordinated debt
300 386
300 401
Debt securities in issue
4 007 222
4 203 983
Fair value changes of the hedged items
in portfolio hedge of interest rate risk
12
(5 770)
(8 193)
Current income tax liabilities
-
43 773
Provisions
19
27 282
30 110
Other liabilities
20
123 635
135 874
23 851 138
22 957 459
Equity
Share capital
22
510 819
510 819
Share premium
13 719
13 719
Legal reserve fund
102 164
102 164
Other capital funds
8 464
8 464
Retained earnings
1 741 864
1 599 158
Equity reserves
25 127
4 947
2 402 157
2 239 271
26 253 295
25 196 730
The accompanying notes on pages 149 to 234
form an integral part of these ﬁnancial statements.
Separate Financial Statements
144
Separate statement of proﬁt or loss and
other comprehensive income for the year
ended 31 December 2025
€ ‘000
Note
2025
2024
Interest income calculated using the effective interest method
927 308
1 012 214
Other interest income
11 296
3 335
Interest and similar expense
(350 569)
(441 885)
Net interest income
24
588 035
573 664
Fee and commission income
241 646
216 686
Fee and commission expense
(37 778)
(39 688)
Net fee and commission income
25
203 868
176 998
Dividend income
-
3 318
Net trading result
26
24 747
17 631
Other operating income
27
1 847
2 134
Other operating expenses
28
(20 330)
(17 303)
Salaries and employee benefits
29
(162 362)
(160 072)
Other administrative expenses
30
(95 658)
(91 597)
Amortisation
15
(24 007)
(30 650)
Depreciation
14
(11 236)
(11 764)
Profit before provisions, impairment and tax
504 904
462 359
Net modification (loss)/gain
(19 944)
158
Provisions
19
55
(67)
Impairment losses and
provisions for loan commitments and financial guarantees
21
(63 088)
(39 701)
Net gain arising from the derecognition
of financial assets at amortised cost
7 248
53
Profit before tax
429 175
422 802
Income tax expense
31
(160 599)
(170 871)
NET PROFIT FOR THE YEAR
268 576
251 931
(Table continues on the next page)
Separate Financial Statements
145
Separate statement of proﬁt or loss and
other comprehensive income for the year
ended 31 December 2025
(continued)
€ ‘000
Note
2025
2024
Other comprehensive income for the year, after tax
Items that shall not be reclassified to profit or loss in the future
Change in value of financial assets at fair value
through other comprehensive income (equity instruments)
Revaluation gain/(loss) arising during the year
313
(67)
Reclassification adjustment
for profit on sale of FVOCI equities within equity
(95)
60
Total items that shall not be reclassified to profit or loss
in the future, before tax
218
(7)
Income tax relating to components
of other comprehensive income
(29)
(668)
Total items that shall not be reclassified to profit or loss
in the future, after tax
189
(675)
Items that may be reclassified to profit or loss in the future
Change in value of financial assets at fair value
through other comprehensive income (debt instruments)
Revaluation gain/(loss) arising during the year
21 253
(4 284)
Reclassification adjustment for profit on sale
of FVOCI bonds included in the profit or loss
6 124
3 843
Exchange difference on translation of foreign operations
587
850
Change in value of cash flow hedges
(342)
(182)
Total items that may be reclassified to profit or loss
in the future, before tax
27 622
227
Income tax relating to components
of other comprehensive income
(7 535)
1 119
Total items that
may be reclassified to profit or loss
in the future, after tax
20 087
1 346
Total other comprehensive income for the year, after tax
20 276
671
TOTAL COMPREHENSIVE INCOME FOR THE YEAR
288 852
252 602
In 2025, the presentation of other comprehensive income was revised. Items related to other comprehensive income
that were presented in separate notes in the previous year have been clearly integrated directly into the statement
‘
Separate statement of proﬁt or loss and other comprehensive income for the year ended 31 December 2025
’. This
change represents only a reclassiﬁcation of information and does not affect the reported amounts of total
comprehensive income or the comparability of the data.
The accompanying notes on pages 149 to 234
form an integral part of these ﬁnancial statements.
Separate Financial Statements
146
Separate statement of changes in equity for the year ended 31 December 2025
€ ‘000
Share
capital
Share
premium
Other
capital
funds
Legal
reserve
fund
Retained
earnings
Reva-
luation
surplus of
buildings
and land
Financial
assets
at FVOCI
Cash
flow
hedges
Translation
of foreign
operation
Total
1 January 2025
510 819
13 719
8 464
102 164
1 599 158
16 595
(11 392)
(164)
(92)
2 239 271
Total comprehensive income
for the year, after tax
-
-
-
-
268 576
-
19 949
(260)
587
288 852
Transfers
-
-
-
-
-
-
-
-
-
-
Losses on the sale of shares
at FVOCI
-
-
-
-
95
-
(95)
-
-
-
Gain on disposal of property
and equipment
-
-
-
-
1
(1)
-
-
-
-
Exchange difference
-
-
-
-
-
-
-
-
-
-
Transactions with owners,
recorded directly in equity
Dividends to shareholders
-
-
-
-
(125 966)
-
-
-
-
(125 966)
Reversal of dividends
distributed but not collected
-
-
-
-
-
-
-
-
-
-
31 December 2025
510 819
13 719
8 464
102 164
1 741 864
16 594
8 462
(424)
495
2 402 157
€ ‘000
Share
capital
Share
premium
Other
capital
funds
Legal
reserve
fund
Retained
earnings
Reva-
luation
surplus of
buildings
and land
Financial
assets
at FVOCI
Cash
flow
hedges
Translation
of foreign
operation
Total
At 1 January 2024
510 819
13 719
8 464
87 493
1 493 705
17 250
(12 065)
(27)
(942)
2 118 416
Total comprehensive income
for the year, after tax
-
-
-
-
251 931
(655)
613
(137)
850
252 602
Transfers
-
-
-
14 671
(14 671)
-
-
-
-
-
Losses on the sale of shares
at FVOCI
-
-
-
-
(60)
-
60
-
-
-
Gain on disposal of property
and equipment
-
-
-
-
-
-
-
-
-
-
Exchange difference
-
-
-
-
1
-
-
-
-
1
Transactions with owners,
recorded directly in equity
Dividends to shareholders
-
-
-
-
(132 097)
-
-
-
-
(132 097)
Reversal of dividends
distributed but not collected
-
-
-
-
349
-
-
-
-
349
At 31 December 2024
510 819
13 719
8 464
102 164
1 599 158
16 595
(11 392)
(164)
(92)
2 239 271
The accompanying notes on pages 149 to 234
form an integral part of these ﬁnancial statements.
Separate Financial Statements
147
Separate statement of cash ﬂows for the year ended 31 December 202
5
€ ‘000
Note
2025
2024
Cash flows from operating activities
Profit before tax
429 175
422 802
Adjustments for
Interest income
24
(938 604)
(1 015 549)
Interest expense
24
350 569
441 885
Dividend income
-
(3 318)
Gain from sale/revaluation of financial assets
at fair value through other comprehensive income
26
(9 788)
(28 422)
Gain on sale of intangible assets and property and equipment
27
(125)
(872)
Loss from revaluation of financial liabilities at amortized cost
26
12 212
45 478
Amortisation
15
24 007
30 650
Depreciation
14
11 236
11 764
Impairment losses and similar charges
21
79 754
72 927
Exchange difference on translation of foreign operations
327
851
Interest received
937 569
1 011 980
Interest paid
(353 092)
(429 485)
Tax paid
(206 102)
(180 225)
Decrease/(increase) in financial assets
at fair value through profit or loss
23 477
(127 649)
(Increase)/decrease in derivatives – hedge accounting (assets)
(13 472)
108 111
Financial assets at amortized cost
Decrease/(increase) in due from banks
96 544
(82 284)
Increase in due from customers
(1 450 335)
(2 061 122)
Increase in fair value changes of the hedged items
in portfolio hedge of interest rate risk (assets)
(487)
(58 180)
Decrease/(increase) in other assets
4 394
(17 413)
(Decrease)/increase in financial liabilities
at fair value through profit or loss
(24 110)
36 893
Decrease in derivatives – hedge accounting (liabilities)
(72 939)
(72 378)
Financial liabilities measured at amortized cost
Decrease in due to banks
(11 966)
(123 822)
Increase in due to customers
931 118
1 121 192
Increase in fair value changes of the hedged items
in portfolio hedge of interest rate risk (liabilities)
2 423
3 725
Increase in provisions
1 814
1 466
(Decrease)/increase in other liabilities
(12 239)
15 028
Net cash used in operating activities
(188 640)
(875 967)
Cash flows from investing activities
Purchase of financial assets at fair value
through other comprehensive income
(686 647)
(450 563)
Disposal of financial assets at fair value
through other comprehensive income
777 424
207 323
Repayments of financial assets at fair value
through other comprehensive income
-
52 400
Purchase of intangible assets and property and equipment
(15 524)
(28 856)
Disposal of intangible assets and property and equipment
504
2 103
Dividends received
-
3 318
Investment in Monilogi, s.r.o.
-
(162)
Investments in VUB Generali DSS, a. s.
-
(4 100)
Net cash from/(used in) investing activities
75 757
(218 537)
(Table continues on the next page)
Separate Financial Statements
148
Separate statement of cash ﬂows for the year en
ded 31 December 2025
(continued)
€ ‘000
Note
2025
2024
Cash flows from financing activities
Proceeds from issue of debt securities
500 000
500 000
Repayments of debt securities in issue
(716 597)
(788 000)
Proceeds from loans received from other banks
595 000
100 000
Repayments of loans received from other banks
(260 200)
(107 304)
Repayments of lease liabilities
(7 416)
(7 957)
Dividends paid
(125 966)
(132 097)
Net cash used in financing activities
(15 179)
(435 358)
Net change in cash and cash equivalents
(128 062)
(1 529 862)
Cash and cash equivalents at the beginning of the year
7
2 272 661
3 802 523
Cash and cash equivalents at 31 December
7
2 144 599
2 272 661
The accompanying notes on pages 149 to 234
form an integral part of these ﬁnancial statements.
Separate Financial Statements
149
1.
Basis of preparation
1.1.
Reporting entity - general information
Všeobecná úverová banka, a.s. (‘the Bank’ or ‘VUB’) provides retail and commercial banking services. The Bank is
domiciled in the Slovak Republic with its registered ofﬁce at Mlynské nivy 1, 829 90 Bratislava 25
, with the
identiﬁcation number (IČO) 313 20 155 and the tax identiﬁcation number (DIČ) 2020411811.
The Bank is part of the Intesa Sanpaolo Group (’ISP Group’), which is one of the leading banking groups in Europe
(103.1 billion euros market capitalization), with a signiﬁcant ESG commitment, including on climate, and a world
-
class position in social Impact. The ISP Group is a leader in Italy in all business areas (retail, corporate, wealth
management) and has a strategic international presence, including subsidiaries operating in commercial banking in
12 countries in Central and Eastern Europe and in the Middle East and North Africa regions, and an international
network of specialists supporting corporate customers in 24 countries, particularly in the Middle East and North
Africa and in those areas where Italian companies are most active.
The Bank’s ultimate parent company is Intesa Sanpaolo S.p.A. (‘ISP’ or ‘the Parent Company’), which is a joint-stock
company and which is incorporated and domiciled in Italy. The consolidated ﬁnancial statements of the company
are available at the address
of its registered ofﬁce at Piazza San Carlo 156, 10121 Torino, Italy.
At 31 December 2025, the Bank had a network of 163 points of sale (including Retail Branches, Corporate Branches
and Mortgage centres) located throughout Slovakia (31 December 2024: 165). The Bank also has one branch in the
Czech Republic (31 December 2024: 1).
At 31 December 2025, the members of the Management Board
are Jozef Kausich (Chairman),
Gabriele Pace, Andrej
Viceník, Martin Techman, Darina Kmeťová
and Branislav Kováčik
.
At 31 December 2025, the members of the Supervisory Board are Massimo Enrico Proverbio (Chairmain), Elena
Kohútiková (Vice
Chairwoman), Marco Fabris, Laura Asperti, Raymond Edmond Schadeck, Draginja Duric, Peter Gutten,
Dana Kondrótová
and
Andrea Fumačová
.
At 31 December 2025, the Bank had in total 3,187 employees (31 December 2024: 3,331). The average number of
employees of the Bank during the year ended 31 December 2025 was 3,256 (31 December 2024: 3,322).
1.2.
Basis of accounting
The separate ﬁnancial statements of the Bank (‘the ﬁnancial statements’) have been prepared in accordance with
International Financial Reporting Standards (‘IFRS’) issued by the International Accounting Standards Board (‘IASB’)
and with interpretations issued by the International Financial Reporting Interpretations Committee of the IASB
(‘IFRIC’) as approved by the European Union Commission in accordance with the Regulation of the European
Parliament and the Council of European Union and in accordance with the Act No. 431/2002.
The ﬁnancial statements have been prepared under the historical cost convention, as modiﬁed by the revaluation of
ﬁnancial assets and ﬁnancial liabilities at fair value though proﬁt or loss, ﬁnancial assets at fair value through other
comprehensive income, derivatives – hedge accounting, buildings and land in property and equipment under
revaluation model to fair value and in the case of the ﬁnancial assets or ﬁnancial liabilities designated as hedged
items in qualifying fair value hedge relationshi
ps modiﬁed by the changes in fair value attributable to the risk being
hedged.
The ﬁnancial statements were prepared using the going concern assumption that the Bank will continue in operation
for the foreseeable future.
1.3.
Functional and presentation currency
EUR is the functional and presentation currency of the Bank. T
he ﬁnancial statements are presented in thousands of
EUR (‘€’), unless indicated otherwise. Negative balances are presented in brackets.
Separate Financial Statements
150
1.4.
Use of judgements and estimates
In preparing the ﬁnancial statements, management has made judgements, estimates and assumptions that affect
the application of the Bank‘s accounting policies and the reported amounts of assets, liabilities, income and
expenses. Actual results may differ from these estimates.
Estimates and underlying assumptions are reviewed on an ongoing basis. Revisions to estimates are recognized
prospectively.
1.4.1.
Judgements
Information about judgements made in applying accounting policies that have the most signiﬁcant effects on the
amounts recognized
in the ﬁnancial statements is included in the following notes. The most signiﬁcant judgements
relate to the classiﬁcation of ﬁnancial instruments.
–
Classiﬁcation of ﬁnancial instruments: assessment of the business model within which the assets are held
and
assessment of whether the contractual terms of the
ﬁnancial
asset are solely payments of principal and interest
(‘SPPI’) on the principal amount outstanding (note 3.4.2)
–
Establishing the criteria for determining whether credit risk on the ﬁnancial asset has increased signiﬁcantly
since
initial recognition, determining methodology for incorporating forward-looking information into measurement
of expected credit loss (‘ECL’) and selection and approval of models used to measure ECL (note 4.1.2).
–
Valuation of lease liabilities (note 11.5) and right-of-use assets (note 14).
The application of International Financial Reporting Standard 16 Leases (‘IFRS 16’) requires the Bank to make
judgments that affect the valuation of the lease liabilities and the valuation of right-of-use assets. These include:
determining contracts in scope of IFRS 16, determining the contract term and determining the interest rate used for
discounting of future cash ﬂows.
The lease term determined by the Bank generally comprises non-cancellable period of lease contracts, periods
covered by an option to extend the lease if the Bank is reasonably certain to exercise that option and periods covered
by an option to terminate the lease if the Bank is reasonably certain not to exercise that option. The same term is
applied as economic useful life of right-of-use assets.
For contracts relating to branch and ofﬁce premises, the Bank has concluded that there are a number of scenarios
where the Bank might elect not to exercise the extension options. Therefore, the IFRS 16 criterion of being reasonably
certain to exercise the
extension options is not fulﬁled. The periods covered by a potential use of an option to extend
the lease were excluded from the lease term.
For leases of branch and ofﬁce premises with indeﬁnite term the Bank generally estimates the length of the contract
to be ﬁve years. The Bank monitors these assumptions, reviews the industry practice and the evolution of the
accounting interpretations i
n relation to the estimation of the lease terms among peer ﬁnancial entities and is
prepared to make adjustments, if necessary.
The present value of the lease payment is determined using the discount rate representing interest rate swap
applicable for the currency of the lease contract and for similar tenor, corrected by the average credit spread of
entities with rating similar to the Bank’s rating, observed at the time
the lease contract commences or is modiﬁed.
1.4.2.
Assumptions and estimation uncertainties
Estimates are used for, but not limited to: fair values of ﬁnancial instruments, fair value of buildings and land under
the revaluation model, impairment losses on due from banks and due from customers and impairment losses related
to ﬁnancial assets at
fair value through other comprehensive income, provisions for loan commitments and
ﬁnancial
guarantees, useful lives and residual values of tangible and intangible assets, impairment losses on tangible and
intangible assets, valuation of lease liabilities and right-of-
use assets, liabilities from employee beneﬁts, provisions
for legal claims and deferred tax assets.
Information about assumptions and estimation uncertainties that run
a signiﬁcant risk of resulting in a material
adjustment is included in the following notes.
Separate Financial Statements
151
–
Determination of the fair value of ﬁnancial instruments with signiﬁcant unobservable inputs (note 5)
. Where the
fair values of ﬁnancial assets and ﬁnancial liabilities recorded on the statement of ﬁnancial position cannot be
derived from active markets, they are determined using a variety of valuation techniques which include the use
of mathematical models. The inputs to these models are taken from observable markets where possible, but
where this is not feasible, a degree of judgement is required in establishing fair values. The judgements include
considerations of liquidity and model inputs such as correlation and volatility for longer dated ﬁnancial
instruments.
–
Impairment of ﬁnancial instruments: determining inputs into the
expected credit loss (ECL) measurement model,
including incorporation of forward-looking information (note 4.1.2).
The Bank reviews its loans and advances at each reporting date to assess whether any individually assessed
impairment loss should be recorded in the statement of proﬁt or loss. In particular,
management judgement is
required in estimating
the amount and timing of future cash ﬂows when determining the level of impairment loss.
Such estimates are based on assumptions about a number of factors, and actual results may differ, resulting in future
changes to the individually assessed impairment losses.
–
Recognition and measurement of legal claims: key assumptions about the likelihood and magnitude of an
outﬂow of resources.
–
Recognition of deferred tax assets: availability of future taxable proﬁt against which deferred tax assets can be
used.
–
Impairment testing for cash generating units containing goodwill: key assumptions underlying recoverable
amounts.
Separate Financial Statements
152
2.
Changes in accounting policies
A few of the new standards and amendments to standards became effective for annual periods beginning after
1 January 2025. These, however, have no
material effect on the ﬁnancial statements
.
Except for the changes below, the Bank has consistently applied the accounting policies as set out in note 3 to all
periods presented in the ﬁnancial statements.
2.1.
Standards and interpretations relevant to the Bank’s operations issued that are effective for the current year
and have been endorsed by the European Union
Lack of exchangeability (Amendments to IAS 21)
Amendments to IAS 21 The Effects of Changes in Foreign Exchange Rates
speciﬁes how
the Bank should assess
whether a currency is exchangeable and how it should determine a spot exchange rate when exchangeability is
lacking. The amendments also require disclosure of information that enables users of the Bank
’s ﬁnancial statements
to understand how the currency not being exchangeable into the other currency affects, or is expected to affect,
the Bank
’s ﬁnancial performance, ﬁnancial position
,
and cash ﬂow
s.
This amendment did not have a material impact on the Bank’s ﬁnancial statements.
2.2.
Standards and interpretations issued but not yet effective or not early adopted by the Bank
A few new standards and amendments to standards are not yet effective or not yet adopted by the European Union.
Early adoption is permitted; however, the Bank has not adopted the new and amended standards in preparing these
consolidated ﬁnancial statements. The
Bank intends to adopt these standards when they become effective.
Classiﬁcation and Measurement of Financial Instruments (Amendments to IFRS 9 and IFRS 7)
In May 2024, the IASB issued Amendments to the classiﬁcation and Measurement of Financial Instruments which
amended IFRS 9 and IFRS 7.
The requirements will be effective for annual reporting periods beginning on or after 1 January 2026, with early
application permitted, and relate to:
–
S
ettling ﬁnancial liabilities using electronic payments system; and
–
A
ssessing contractual cash ﬂow characteristics of ﬁnancial assets, including those with sustainability
-linked
features.
The Bank has performed an assessment of all material electronic payment systems used. Most of the electronic
settlement systems used by the Bank result in real-time settlement.
There is a number of electronic settlement systems used by the Bank that do not result in real-time settlement. The
Bank derecognises
the ﬁnancial liability and the associated cash when the payment has reached the beneﬁciary,
which is when the obligation is discharged. The amendments are not expected to have a material impact.
In addition, the Bank has assessed the impact of the Amendments on its ﬁnancial assets that
sustainability-linked
features and other similar contingent features, as well as on non-
recourse ﬁnancing and contractually linked
instruments. Based on the assessments performed, the amendments in these areas are not expected to have a
material impact on the ﬁnancial
statements.
Separate Financial Statements
153
IFRS 18 Presentation and Disclosures in Financial Statements
IFRS 18 will replace lAS 1 Presentation of Financial Statements and applies for annual reporting periods beginning
on or after 1 January 2027.
The new standard introduces the following key new requirements:
–
The Bank is
required to classify all income and expenses into ﬁve categories in the statement of proﬁt or loss,
namely the operating, investing, ﬁnancing, discontinued operations and income tax categories.
The Bank is also
required to present a
newly deﬁned
operating proﬁt subtotal.
The Bank's
net proﬁt will not change.
–
Management-
deﬁned performance measures (
‘MPMs‘
) are disclosed in a single note in the ﬁnancial statements.
–
Enhanced guidance is provided on how to group information in the ﬁnancial statements.
In addition, all entities are required to use the operating proﬁt subtotal as the starting point for the statement of
cash ﬂows when presenting operating cash ﬂows under the indirect method.
The Bank is currently working to identify the impacts the standard will have on the primary ﬁnancial statements and
notes to the ﬁnancial statements. The Bank considers its main business activities to include the provision of ﬁnancing
to customers and i
nvesting in ﬁnancial assets. In accordance with IFRS 18, some of the income and expenses related
to those activities are classiﬁed in the operating category, as an exception to the general requirements that would
otherwise have resulted in their classiﬁcation in the investing or ﬁnancing categories.
The initial expected impacts of IFRS 18 on the Bank’s ﬁnancial statements are, as follows:
–
Income and expenses from the following will be classiﬁed in the operating category within the statement of
proﬁt or loss: cash and cash equivalents; liabilities from transactions that involve only the raising of ﬁnance;
generally, assets invested in as
part of the Bank’s main business activity of investing in ﬁnancial assets that
generate a return individually and largely independently of the Bank’s other resources.
–
Foreign exchange differences will be classiﬁed in the same category as the related income and expense giving
rising to the foreign exchange difference, with some exceptions.
–
Gains and losses on hedging instruments, including those not designated as such, but used to manage exposure
to identiﬁed risks, will be classiﬁed in the same category as the income and expenses relating to the risk being
covered, with some exceptions.
–
For the statement of cash ﬂows, the ‘operating proﬁt’ subtotal will be used as the starting point for determining
cash ﬂows from operating activities. Furthermore, the classiﬁcation of the total cash ﬂows from all dividends
received, all interest paid,
and all interest received will each, respectively, be classiﬁed in a single category in the
statement of cash ﬂows following the classiﬁcation of the related income and expenses in the statement of proﬁt
or loss.
–
New disclosures will be added for management-
deﬁned performance measures;
–
A reconciliation for each line item in the statement of proﬁt or loss between the restated amounts presented
applying IFRS 18, and the amounts previously presented applying IAS 1.
The Bank is also assessing the impact on how information is grouped in the ﬁnancial statements, including for items
currently labelled as 'other'.
The following new and amended standards are not expected to have a signiﬁcant impact on the
ﬁnancial statements:
–
Contracts Referencing Nature-dependent Electricity (Amendments to IFRS 9 and IFRS 7);
–
Annual Improvements to IFRS Accounting Standards (Volume 11);
–
IFRS 19 Subsidiaries without Public Accountability: Disclosures;
–
Translation to a Hyperinﬂationary Presentation Currency (Amendments to IAS 21);
–
Sale or Contribution of Assets between an Investor and its Associate or Joint Venture (Amendment in IFRS 10
and IAS 28).
Separate Financial Statements
154
3.
Material accounting policies
3.1.
Foreign currency transactions
Transactions in foreign currencies are translated into the EUR
at the ofﬁcial European Central Bank (’ECB’) spot
exchange rate at the date of the transactions.
Monetary assets and liabilities denominated in foreign currencies are translated into EUR
at the ofﬁcial ECB spot
exchange rate at the reporting date. The foreign currency gain or loss on monetary items is the difference between
the amortized cost in the functional currency at the beginning of the year, adjusted for effective interest and
payments during the year, and the amortized cost in the foreign currency translated at the spot exchange rate at
the end of the year.
Non-monetary assets and liabilities that are measured at fair value in a foreign currency are translated into EUR at
the ofﬁcial ECB spot exchange rate at the date on which the fair value is determined. Non
-monetary items that are
measured based on historical cost in a foreign currency are translated using the ofﬁcial ECB spot exchange rate at
the date of the transaction.
The foreign currency gain or loss is the difference between the contractual exchange rate of a transaction and the
ofﬁcial ECB exchange rate at the date of the transaction. Foreign currency gain or loss is included in ‘Net trading
result’, as well as gains or losses arising from movements in exchange rates after the date of the transaction.
Foreign currency differences arising on translation are generally recognized
in proﬁt or loss. However, foreign
currency differences arising from the translation of the following items are recognized in other comprehensive
income (’OCI’):
–
Q
ualifying cash ﬂow hedges to the extent that the hedge is effective;
and
–
Equity investments in respect of which an election has been made to present subsequent changes in fair value in
OCI.
3.2.
Foreign operations
The ﬁnancial statements include foreign operations in the Czech Republic. The assets and liabilities of foreign
operations are translated into EUR at the spot exchange rate at the reporting date. The income and expenses of
foreign operations are translated to EUR at rates approximating the foreign exchange rates at the dates of the
transactions.
Foreign currency differences arising on these translations are recognized in OCI, and accumulated in the foreign
currency translation reserve (‘Translation of foreign operation’ reserve).
3.3.
Cash and cash equivalents
‘Cash and cash equivalents’ include notes and coins on hand, balances held with central banks, including compulsory
minimum reserves, and highly liquid ﬁnancial assets with original maturities of three months or less from the date
of acquisition that are
subject to an insigniﬁcant risk of changes in their fair value, and are used by the Bank in the
management of its short-term commitments.
‘Cash and cash equivalents’ are carried at amortized
cost in the statement of ﬁnancial position (note 7).
3.4.
Financial assets and ﬁnancial liabilities
3.4.1.
Recognition and initial measurement
The Bank initially recognises loans and advances (e.g. ‘Due from banks’, ‘Due from customers’), deposits (e.g. ‘Due
to banks’, ‘Due to customers‘), debt securities issued and subordinated debt on the date on which they originated.
All other ﬁnancial instr
uments (including regular-
way purchases and sales of ﬁnancial assets) are
recognized on the
trade date, which is the date on which the Bank becomes a party to the contractual provisions of the instrument.
A ﬁnancial asset or ﬁnancial liability is measured initially at fair value plus, for an item not at fair value through proﬁ
t
or loss, transaction costs that are directly attributable to its acquisition or issue.
Separate Financial Statements
155
3.4.2.
Classification
On initial recognition, a ﬁnancial asset is classiﬁed as measured at:
–
Amortised cost (‘AC’),
–
Fair value through other comprehensive income (‘FVOCI’), or
–
Fair value through proﬁt or loss (‘FVTPL’).
A ﬁnancial asset is measured at AC, if it meets both of the following conditions and is not designated as at FVTPL:
–
The asset is held within a business model whose objective is to hold assets to collect contractual cash
ﬂows; and
–
The contractual terms of the ﬁnancial asset give rise on speciﬁed dates to cash ﬂows that are SPPI.
A debt instrument is measured at FVOCI only if it meets both of the following conditions and is not designated as
at FVTPL:
–
The asset is held within a business model whose objective is achieved by both collecting contractual cash
ﬂows
and selling ﬁnancial assets; and
–
The contractual terms of the ﬁnancial asset give rise on speciﬁed dates to cash ﬂows that are SPPI.
On initial recognition of an equity investment that is not held for trading, the Bank may irrevocably elect to present
subsequent changes in fair value in OCI (note 3.6.2). This election is made on an investment-by-investment basis.
All other ﬁnancial assets are classiﬁed as measured at FVTPL.
In addition, on initial recognition, the Bank may irrevocably designate a ﬁnancial asset that otherwise meet the
requirements to be measured at amortized
cost or at FVOCI as at FVTPL if doing so eliminates or signiﬁcantly reduces
an accounting mismatch that would otherwise arise (note 3.4.7).
Business model assessment
The Bank uses the following business models:
–
Held to collect,
–
Held to collect and sell,
–
Held for trading/Other.
The Bank makes an assessment of the objective of a business model in which an asset is held at a portfolio level
because this best reﬂects the way the business is managed and information is provided to management. The
information considered includes:
–
The stated policies and objectives for the portfolio and the operation of those policies in practice. In particular,
whether management’s strategy focuses on earning contractual interest revenue, maintaining a particular
interest rate proﬁle,
aligning
the duration of ﬁnancial assets
with that of the corresponding liabilities, or realizing
cash ﬂows through asset sales;
–
How the performance of the portfolio is evaluated and reported to the Bank’s management;
–
The risks that affect the performance of the business model (and the ﬁnancial assets held within that business
model) and its strategy for how those risks are managed;
–
How managers of the business are compensated (e.g. whether compensation is based on the fair value of the
assets managed or the contractual cash ﬂows collected); and
–
The frequency, volume and timing of sales, in prior periods, the reasons for such sales and its expectations about
future sales activity. However, information about sales activity is not considered in isolation, but rather as part
of an overall assessment of how the Bank states objective for managing the ﬁnancial assets is achieved and how
cash ﬂows are realised.
Financial assets that are held for trading or managed and whose performance is evaluated on a fair value basis are
measured at FVTPL because they are neither held to collect contractual cash ﬂows
, nor held both to collect
contractual cash ﬂows
,
and to sell ﬁnancial assets.
Assessment of whether contractual cash ﬂows are SPPI
For the purposes of this assessment, ‘principal’ is deﬁned as the fair value of the ﬁnancial asset on initial recognition.
‘Interest’ is deﬁned as consideration for the time value of money and for the credit risk associated with the principal
amount outstanding during a particular period of time and for other basic lending risks and costs (e.g. liquidity risk
and administrative costs), as well as proﬁt margin.
Separate Financial Statements
156
In assessing whether the contractual cash ﬂows are SPPI, the Bank considers the contractual terms of the instrument.
This includes assessing whether the ﬁnancial asset contains a contractual term that could change the timing or
amount of contractual cash
ﬂows such that it would not meet this condition. In making the assessment, the Bank
considers:
–
Contingent events that would change the amount and timing of cash ﬂows;
–
Leverage features;
–
Prepayment and extension terms;
–
Terms that limit the Bank’s claim to cash ﬂows from speciﬁed assets (e.g. non
-recourse loans); and
–
Features that modify consideration of the time value of money (e.g. periodical reset of interest rates).
The Bank holds a portfolio of long-
term ﬁxed
-rate loans for which the Bank has the option to propose to revise the
interest rate at periodic reset dates. These reset rights are limited to the market rate at the time of revision. The
borrowers have an option to either accept the revised rate or redeem the loan at par without penalty. The Bank has
determined that the contractual cash ﬂows of these loans are SPPI because the option
adjusts the interest rate in a
way that
reﬂects
the time value of money, credit risk, other basic lending risks and costs associated with the principal
amount outstanding.
The Bank classiﬁes its ﬁnancial liabilities, other than ﬁnancial guarantees and loan commitments, as measured at
amortized cost or FVTPL.
Reclassiﬁcations
Financial assets are not reclassiﬁed subsequent to their initial recognition, except in the period after the Bank changes
its business model for managing ﬁnancial assets. Financial liabilities are never reclassiﬁed.
3.4.3.
Subsequent measurement
After initial recognition, the Bank measures ﬁnancial assets and ﬁnancial liabilities in accordance
with the
classiﬁcation at fair value through proﬁt or loss (note 3.5), fair value through other comprehensive income (note 3.6)
or at amortized cost (note 3.7).
3.4.4.
Derecognition
Derecognition due to substantial modiﬁcation of terms and conditions
The Bank derecognises
a ﬁnancial asset, such as a loan to a customer, when the terms and conditions have been
renegotiated to the extent that, substantially, it becomes a new loan, with the difference recognized as a
derecognition gain or loss, to the extent that an impairment loss has not already been recorded. When assessing
whether to derecognise a loan to a customer, the Bank considers, among other factors, such as changes in the
currency of the loan, introduction of an equity feature, change in counterparty, and
whether the modiﬁcation is
such that the instrument would no longer meet the SPPI criterion.
Where an existing ﬁnancial liability is replaced by another from the same lender on substantially different terms, or
the terms of an existing liability are substantially modiﬁed, such an exchange or modiﬁcation is treated as a
derecognition of the original liability and the recognition of a new liability. The difference between the carrying
amount
of the original ﬁnancial liability and the consideration paid is
recognized
in proﬁt or loss.
Derecognition other than due to substantial modiﬁcation
The Bank derecognises
a ﬁnancial asset when the contractual rights to the cash ﬂows from the ﬁnancial asset expire,
or it transfers the rights to receive the contractual cash ﬂows in a transaction in which substantially all of the risks
and rewards of ownership of the ﬁna
ncial asset are transferred, or in which the Bank neither transfers, nor retains
substantially all of the risks and rewards of ownership,
and it does not retain control of the ﬁnancial asset.
On derecognition of a ﬁnancial asset, the difference between the carrying amount of the asset (or the carrying
amount allocated to the portion of the asset derecognized), and the sum of (i) the consideration received (including
any new asset obtained less any new liability assumed), and (ii) any cumulative gain or loss that had been recognized
in OCI is recognized
in proﬁt or loss.
Separate Financial Statements
157
Any cumulative gain or loss recognized in OCI in respect of equity investment securities designated as at FVOCI is
not recognized
in proﬁt or loss on derecognition of such securities, as explained above. Any interest in transferred
ﬁnancial assets that qualify for derecognition that is created or retained by the Bank is
recognized as a separate asset
or liability.
The Bank enters into transactions that transfer assets recognized
on its statement of ﬁnancial position, but retains
either all or substantially all of the risks and rewards of the transferred assets or a portion of them. In such cases, the
transferred assets are not derecognized. Examples of such transactions are securities lending and sale-and-
repurchase transactions. (note 3.8)
In transactions in which the Bank neither retains nor transfers substantially all of the risks and rewards of ownership
of a ﬁnancial asset
, and it retains control over the asset, the Bank continues to recognise the asset to the extent of
its continuing involvement, determined by the extent to which it is exposed to changes in the value of the transferred
asset.
The Bank derecognises
a ﬁnancial liability when its contractual obligations are discharged or cancelled, or expire.
3.4.5.
Modifications
If the terms of a ﬁnancial asset are modiﬁed, then the Bank evaluates whether the cash ﬂows of the modiﬁed asset
are substantially different.
If the cash ﬂows are substantially different, then the contractual rights to cash ﬂows from the original ﬁnancial asset
are deemed to have expired. In this case, the original ﬁnancial asset is
derecognized (see above under Derecognition
other than due to substantial modiﬁcation)
,
and a new ﬁnancial asset is
recognized at fair value plus any eligible
transaction costs. Any fees received as part of the modiﬁcation are accounted for as follows:
–
Fees that are considered in determining the fair value of the new asset and fees that represent reimbursement
of eligible transaction costs are included in the initial measurement of the asset;
–
Other fees are included in proﬁt or loss as part of the gain or loss on
derecognition.
If cash ﬂows are modiﬁed when the borrower is in ﬁnancial difﬁculties, then the objective of the modiﬁcation is
usually to maximise recovery of the original contractual terms rather than to originate a new asset with substantially
different terms. If
the Bank plans to modify a ﬁnancial asset in a way that would result in forgiveness of cash ﬂows,
then it ﬁrst considers whether a portion of the asset should be written off before the modiﬁcation takes place (see
below for write-off policy, note 4.1.5). This approach impacts the result of the quantitative evaluation and means
that the derecognition criteria are not usually met in such cases.
If the modiﬁcation of a ﬁnancial asset measured at
amortized cost or FVOCI does not result in derecognition of the
ﬁnancial asset, then the Bank ﬁrst recalculates the gross carrying amount of the ﬁnancial asset using the original
effective interest rate of the asset,
and recognises the resulting adjustment as a modiﬁcation gain or loss in proﬁt or
loss. For ﬂoating
-
rate as well as ﬁxed
-
rate ﬁnancial assets
, where reset to market is expected, the original effective
interest rate used to calculate t
he modiﬁcation gain or loss is adjusted to reﬂect current market terms at
the time of
the modiﬁcation.
The effective interest rate is therefore altered. Any costs or fees incurred, and fees received as part
of the modiﬁcation adjust the gross carrying amount of the modiﬁed ﬁnancial asset
, and are amortized over the
remaining term of the modiﬁed ﬁnancial asset.
If such a modiﬁcation is carried out because of ﬁnancial difﬁculties of the borrower (note 4.1.2), then the gain or
loss is presented together with impairment losses.
3.4.6.
Offsetting
Financial assets and ﬁnancial liabilities are offset and the net amount presented in the statement of ﬁnancial
positiononly when the Bank currently has a legally enforceable right to set off the amounts and intends either to
settle them on a net basis or to realise the asset and settle the liability simultaneously.
Income and expenses are presented on a net basis only when permitted under IFRS, or for gains and losses arising
from a group of similar transactions such as in the Bank’s trading activity.
Separate Financial Statements
158
3.4.7.
Fair value measurement
‘Fair value’ is the price that would be received for the sale of an asset or paid for the transfer of a liability in an
orderly transaction between market participants at the measurement date in the principal on the main market, or if
such a market does not exist, the most advantageous market to which the VUB Group has access at that date. The fair
value of a liability reﬂects its non
-performance risk.
When one is available, the Bank measures the fair value of an instrument using the quoted price in an active market
for that instrument. A market is regarded as ‘active’ if transactions for the asset or liability take place with sufﬁcient
frequency and volume to provide pricing information on an ongoing basis.
If there is no quoted price in an active market, then the Bank uses valuation techniques that maximise the use of
relevant observable inputs and minimise the use of unobservable inputs. The chosen valuation technique
incorporates all of the factors that market participants would take into account in pricing a transaction. The hierarchy
of valuation techniques is explained in note 5.
The best evidence of the fair value of a ﬁnancial instrument on initial recognition is normally the transaction price,
i.e. the fair value of the consideration given or received.
If the Bank determines that the fair value on initial recognition differs from the transaction price and the fair value
is evidenced neither by a quoted price in an active market for an identical asset or liability nor based on a valuation
technique for wh
ich any unobservable inputs are judged to be insigniﬁcant in relation to the measurement, then the
ﬁnancial instrument is initially measured at fair value
according to model, adjusted to defer the difference between
the fair value on initial recognition and the transaction price. Subsequently, that difference is recognized
in proﬁt or
loss on an appropriate basis over the life of the instrument but no later than when the valuation is wholly supported
by observable market data or the transaction is closed out.
3.5.
Financial assets and ﬁnancial liabilities at fair value through proﬁt or loss
Financial assets and ﬁnancial liabilities at fair value through proﬁt or loss comprise ﬁnancial assets held for trading,
including derivative ﬁnancial instruments and ﬁnancial assets at fair value through proﬁt or loss.
3.5.1.
Financial assets and financial liabilities held for trading
The Bank classiﬁes trading portfolio as ﬁnancial assets or ﬁnancial liabilities measured at fair value through proﬁt or
loss when they have been purchased or issued primarily for short-
term proﬁt making through trading activities or
form part of a por
tfolio of ﬁnancial instruments that are managed together, for which there is evidence of a recent
pattern of short-
term proﬁt taking. Financial assets and ﬁnancial liabilities held for trading are recorded and
measured in the statement of ﬁnancial position at fair value. Changes in fair value are recorded in proﬁt or loss with
the exception of movements in fair value of liabilities designated at FVTPL due to changes in the Bank’s own credit
risk. Such changes in fair value are recorded in the ‘Fair value gains and losses arising from the Bank‘s own credit
risk related to derivative liabilities’ and do not get recycled
to the proﬁt or loss. Interest earned or incurred on
instruments designated at FVTPL is presented in ‘Other interest income’. Dividend income from equity instruments
measured at FVTPL is considered to be incidental to the Bank’s trading operations and is
recorded in proﬁt or loss as
‘Net trading result’ when the right to the payment has been established.
Included in this classiﬁcation are debt securities, equities, short positions and customer loans that have been acquired
principally for the purpose of selling in the near term.
The Bank monitors changes in fair values on a daily basis and recognises unrealised gains and losses in the statement
of proﬁt or loss in ‘Net trading result’.
Derivative ﬁnancial instruments
In the normal course of business, the Bank is a party to contracts with derivative ﬁnancial instruments, which
represent a very low initial investment compared to the notional value of the contract. The derivative ﬁnancial
instruments used include forward rate agreements, foreign exchange and commodity forwards, interest rate, foreign
exchange and commodity swaps, interest rate, foreign exchange, equity options, cross currency swaps and futures.
The Bank also uses ﬁnancial instruments to hedge interest r
ate risk and currency exposures associated with its
transactions in the ﬁnancial markets. They are accounted for as trading derivatives if they do not fully comply with
the deﬁnition of a hedging derivative as prescribed by IFRS. The Bank also acts as an
intermediary provider of these
instruments to certain customers.
Separate Financial Statements
159
Derivative ﬁnancial instruments not used for hedge accounting purposes are initially
recognized and subsequently
re-
measured in the statement of ﬁnancial position at fair value as part of ‘Financial assets held for trading’.
All derivatives are carried as assets when the fair value is positive and as liabilities when the fair value is negative.
Changes in the fair value of derivatives are included in ‘Net trading result’.
Fair values are obtained from quoted market prices. If such values are not available, discounted cash ﬂow models
and option pricing models are used. The fair values of derivative positions are computed using standard formulas
and prevailing interest rates applicable for respective currencies available on the market at reporting dates.
Embedded derivatives
An embedded derivative is a component of a hybrid (combined) instrument that also includes a non-derivative host
contract with the effect that some of the cash ﬂows of the combined instrument vary in a way similar to a stand
-
alone derivative. An embedded
derivative causes some or all of the cash ﬂows that otherwise would be required by
the contract to be modiﬁed according to a speciﬁed interest rate, ﬁnancial instrument price, commodity price, foreign
exchange rate, index of prices or rates, credit rating or credit index, or other variable, provided that, in the case of a
non-
ﬁnancial variable, it is not speciﬁc to a party to the contract. A derivative that is attached to a ﬁnancial
instrument, but is contractually transferable independently of that instrument, or has a different counterparty from
that instrument, is not an embedded derivative, but a separate ﬁnancial instrument.
The Bank assesses whether any embedded derivatives contained in a given contract are required to be separated
from the host contract and accounted for as derivatives.
Derivatives may be embedded in another contractual arrangement (a host contract). The Bank accounts for an
embedded derivative separately from the host contract when:
–
The host contract is not an asset in the scope of International Financial Reporting Standard 9 Financial
Instruments (‘IFRS 9’);
–
The host contract is not itself carried at FVTPL;
–
T
he terms of the embedded derivative would meet the deﬁnition of a derivative if they were contained in a
separate contract; and
–
The economic characteristics and risks of the embedded derivative are not closely related to the economic
characteristics and risks of the host contract.
Separated embedded derivatives are measured at fair value, with all changes in fair value recognized
in proﬁt or loss
in ‘Net trading result’
unless they form part of a qualifying cash ﬂow hedging relationship. Separated embedded
derivatives are presented in the statement of ﬁnancial position together with other derivatives.
3.5.2.
Financial assets at fair value through profit or loss
Financial assets in this category are those that are not held for trading and are required to be measured at fair value
under IFRS 9, as they do not meet the requirements of the SPPI test.
Financial assets at fair value also comprises equity instruments not held for trading where the Bank did not elect the
option to classify investments at FVOCI. Financial assets at fair value through proﬁt or loss are recorded in the
statement of ﬁnancial
position at fair value. Changes in fair value are recognized in ‘Net trading result’. Interest
income is recorded in ‘Other interest income’ and dividend income in ‘Net trading result’ according to the terms of
the contract, or when the right to payment has been established.
3.6.
Financial assets at fair value through other comprehensive income
3.6.1.
Debt instruments measured at fair value through other comprehensive income
The Bank classiﬁes debt instruments as measured at FVOCI under IFRS 9 if both of the following conditions are met:
–
The instrument is held within a business model, the objective of which is achieved by both collecting contractual
cash ﬂows and selling ﬁnancial
assets.
–
The contractual terms of the ﬁnancial asset meet the SPPI
test.
Separate Financial Statements
160
Debt instruments at FVOCI are subsequently measured at fair value with gains and losses arising due to changes in
fair value recognized in equity. Interest income and foreign exchange gains and losses are recognized
in proﬁt or
loss in the same manner as is applicable
for ﬁnancial assets at
amortized cost. The Bank applies the impairment
requirements for the recognition and measurement of a loss allowance for ﬁnancial assets that are measured at fair
value through other comprehensive income. However, the loss allowance is recognized in other comprehensive
income and does not reduce the carrying amount of the ﬁnancial asset in the statement of ﬁnancial position.
Where the Bank holds more than one investment in the same security, they are deemed to be disposed of on a ﬁrst
-
in ﬁrst
-out basis. On derecognition, cumulative gains or losses previously recognized
in equity are reclassiﬁed from
equity to proﬁt or loss.
The fair value of debt instruments, for which an active market exists, and a market value can be estimated reliably,
is measured at quoted market prices. In circumstances where the quoted market prices are not readily available, the
fair value is estimated
using the present value of future cash ﬂows.
In the case of debt instruments measured at fair value through other comprehensive income, impairment is assessed
based on the same criteria as ﬁnancial assets carried at
amortized cost. If, in a subsequent year, the fair value of a
debt instrument increases and the increase can be objectively related to an event taking place after the impairment
loss was recognized
in ‘Impairment losses’ in the statement of proﬁt or loss and other comprehensive income, the
impairment loss is reversed through the statemen
t of proﬁt or loss.
3.6.2.
Equity instruments measured at fair value through other comprehensive income
Upon initial recognition, the Bank occasionally elects to irrevocably classify some of its equity investments as equity
instruments at FVOCI when they meet the deﬁnition of Equity under IAS 32 Financial Instruments: Presentation and
are not held for trading. Such classiﬁcation is determined on an instrument
-by-instrument basis.
Gains and losses on these equity instruments are never recycled to proﬁt or loss. Dividends are
recognized
in proﬁt
or loss as ‘Net trading result when the right to the payment has been established, except when
the Bank beneﬁts
from such proceeds as a recovery of part of the cost of the instrument. In such a case, these gains are recorded in
OCI. Equity instruments at FVOCI are not subject to any impairment assessment.
3.7.
Financial assets and ﬁnancial liabilities at
amortized costs
Financial assets at amortized costs comprise balances due from banks and due from customers including debt
securities. Financial liabilities at amortized costs comprise balances due to banks, due to customers, subordinated
debt and debt securities in issue.
3.7.1.
Financial assets at amortized costs: Due from banks and Due from customers
The Bank only measures ‘Due from banks’ and ‘Due from customers’ at amortized cost if both of the following
conditions are met:
–
The ﬁnancial asset is held within a business model with the objective to hold ﬁnancial assets in order to collect
contractual cash ﬂows
;
–
The contractual terms of the ﬁnancial asset give rise on speciﬁed dates to cash ﬂows that are solely payments of
principal and interest on the principal amount outstanding.
Due from banks
Due from banks include receivables from central banks with a maturity over 90 days, receivables from current
accounts in other than central banks, term deposits, loans provided and securities purchased from commercial banks.
Balances are presented at amortized cost including interest accruals less any impairment losses.
Due from customers
Due from customers balances comprise loans and advances and securities with ﬁxed or determinable payments and
ﬁxed maturities. These receivables are recorded at
amortized cost less any impairment losses (note 11.2).
Impairment
The detailed description of policy is in the note 4.1.2.
Separate Financial Statements
161
The Bank writes off ‘Due from banks’ and ‘Due from customers’ when it determines that the loans and advances
are uncollectible. Loans and advances are written off against the Impairment losses on Financial Assets in amortized
cost with the remaining part being written-
off against proﬁt or loss reported under ‘Net loss arising from the
derecognition of ﬁnancial assets at
amortized cost‘. Any recoveries of written off loans are credited to the same line
in the statement of proﬁt or loss on receipt.
3.7.2.
Financial liabilities at amortized costs: Due to banks, Due to customers, Subordinated debt and Debt
securities in issue
Deposits, debt securities issued and subordinated liabilities are the Bank’s sources of debt funding.
The Bank classiﬁes capital instruments as ﬁnancial liabilities or equity instruments in accordance with the substance
of the contractual terms of the instruments.
Deposits, debt securities issued and subordinated liabilities are initially measured at fair value minus incremental
direct transaction costs and subsequently measured at their amortized cost using the effective interest rate method.
3.8.
Repurchase and reverse repurchase agreements
Securities sold under sale and repurchase agreements (‘repo transactions’) remain as assets in the statement of
ﬁnancial position under the original caption
while the liability from the received loan is included in ‘Financial assets
at amortized cost: Due to banks’ or ‘Financial assets at amortized cost: Due to customers’.
Securities purchased under agreements to purchase and resell (‘reverse repo transactions’) are recorded only in the
off-
balance sheet and the loan provided is reported in the statement of ﬁnancial position in ‘Cash, cash balances at
central banks’, ‘Financial assets at amortized cost: Due from banks’ or ‘Financial assets at amortized cost: Due from
customers’, as appropriate.
The price differential between the purchase and sale price of securities is treated as interest income or expense and
deferred over the life of the agreement.
3.9.
Derivatives – Hedge accounting
When initially applying IFRS 9, the Bank has elected to continue applying the requirements of IAS 39 instead of those
of IFRS 9.
Derivatives held for risk management purposes include all derivative assets and liabilities that are not classiﬁed as
trading assets or liabilities. Derivatives held for risk management purposes are measured at fair value in the statement
of ﬁnancial pos
ition in ‘Derivatives – Hedge accounting’.
The Bank makes use of derivative instruments to manage exposures to interest rate risks, foreign currency risk,
inﬂation risk and credit risk including exposures arising from highly probable transactions. In order to manage
individual risks, the Bank appl
ies hedge accounting for transactions which meet the speciﬁed criteria.
At the inception of the hedge relationship, the Bank formally documents the relationship between the hedged item
and the hedging instrument, including the nature of the risk, the objective and strategy for undertaking the hedge
and the method that will be used to assess the effectiveness of the hedging relationship.
Also, at the inception of the hedge relationship, a formal assessment is undertaken to ensure the hedging instrument
is expected to be highly effective in offsetting the designated risk in the hedged item. Hedges are formally assessed
each month. A hedge i
s regarded as highly effective if the changes in fair value or cash ﬂows attributable to the
hedged risk during the period for which the hedge is designated are expected to offset in a range of 80% to 125%.
In situations where that hedged item is treated as an expected transaction, the Bank assesses whether the transaction
is highly probable and presents an exposure to variations in cash ﬂows that could ultimately affect the statement of
proﬁt or loss.
Separate Financial Statements
162
Cash ﬂow hedges
For designated and qualifying cash ﬂow hedges, the effective portion of the gain or loss on the hedging instrument
is initially recognized
in other comprehensive income as ‘Cash ﬂow hedges’. The ineffective portion of the gain or
loss on the hedging instrument is immediately recognised
as gain or loss in the statement of proﬁt or loss in ‘Net
trading result’.
When the hedged cash ﬂow affects proﬁt or loss, the gain or loss on the hedging instrument is reclassiﬁed from
other comprehensive income to proﬁt or loss as a reclassiﬁcation adjustment in ‘Net trading result’. When a hedging
instrument expires or is sold, terminated, exercised, or when a hedge no longer meets the criteria for hedge
accounting
and the hedged cash ﬂows are still probable
, any cumulative gain or loss that has been recognized in
other comprehensive income remains separately in equity an
d is reclassiﬁed from other comprehensive income to
statement of proﬁt or loss as a reclassiﬁcation adjustment when the hedged expected transaction is ultimately
recognized. When an expected transaction is no longer expected to occur, the cumulative gain or loss that was
reported in equity is immediately reclassiﬁed from other comprehensive income to statement of proﬁt or loss as a
reclassiﬁcation adjustment.
Fair value hedges
For designated and qualifying fair value hedges, the change in the fair value of a hedging derivative is recognized in
the statement of proﬁt or loss in ‘Net trading result’. Meanwhile, the change in the fair value of the hedged item
attributable to the risk hedged is recorded as part of the carrying value of the hedged item and is also recognized in
the statement of proﬁt or loss in ‘Net trading result’.
In case of macro hedge, the change in the fair value of the hedged items attributable to the risk hedged is presented
separately as ‘Fair value changes of the hedged items in portfolio hedge of interest rate risk’.
If the hedging instrument expires or is sold, terminated or exercised, or where the hedge no longer meets the criteria
for hedge accounting, the hedge relationship is terminated. For hedged items recorded at amortized cost, the
difference between the carrying value of the hedged item on termination and the face value is amortized over the
remaining term of the original hedge using the effective interest rate (‘EIR’). If the hedged item is derecognized, the
unamortised fair value adjustment is recognized imm
ediately in proﬁt or loss when the item is
derecognized.
Speciﬁc policies for hedges affected by IBOR reform
The Phase 1 amendments
If a hedging relationship is directly affected by IBOR reform, then certain exceptions can be applied (referred to as
‘the Phase 1 amendments’) to the general hedge accounting policy.
All hedges affected by IBOR reform either matured or were discontinued. Therefore, the VUB Group ceased to follow
the respective Phase 1 amendments.
The Phase 2 amendments
Policies speciﬁc to non
-
contractually speciﬁed risk portions
When the Bank designates an alternative benchmark rate as a hedged risk and the alternative benchmark rate is a
non-
contractually speciﬁed risk portion that is not separately identiﬁable at the date it is designated, the Bank deems
that the rate meets th
e separately identiﬁable criterion if it reasonably expects that the alternative benchmark rate
will be separately identiﬁable within a 24
-month period. The 24-month period applies on a rate-by-rate basis and
starts from the date when the Bank ﬁrst desi
gnates the alternative benchmark rate as a hedged risk.
If the Bank subsequently expects that a non-
contractually speciﬁed alternative benchmark rate risk component will
not be separately identiﬁable within the 24
-month period, then it discontinues hedge accounting prospectively from
the date of that reassessment for all hedging relationships in which the alternative benchmark rate is designated as
a non-
contractually speciﬁed risk portion.
Policies speciﬁc to cash ﬂow hedges
When the interest rate benchmark on which the hedged future cash ﬂows had been based is changed as required
by IBOR reform, for the purpose of determining whether the hedged future cash ﬂows are expected to occur, the
Bank deems that the hedging reserve recognized in OCI for that hedging relationship is based on the alternative
benchmark rate on which the hedged future cash ﬂows
is to be based.
Separate Financial Statements
163
3.10.
Investments in subsidiaries, joint ventures and associates
Investments in subsidiaries, joint ventures and associates are recorded at historical cost less impairment losses, if any.
Investments in subsidiaries, joint ventures and associates are tested for impairment annually or more frequently if
events or changes in circumstances indicate that the carrying amount may be impaired.
The Bank uses Capital Asset Pricing Model (‘CAPM’) for impairment testing, using cash ﬂow projections based on
the most recent ﬁnancial budgets approved by senior management covering a budgeted ﬁve
-year period. The
discount rates applied to future cash
ﬂow projections beyond the ﬁve
-year period are adjusted by the projected
growth rate. Both discount rates and growth rates are determined on ISP Group level speciﬁcally for the Slovak
market.
The calculation of the recoverable amount considers the following key assumptions:
–
Interest margins – the development of margins and volumes by product line,
–
Discount rates – based on CAPM,
–
Market share during the budget period,
–
P
rojected growth rates used to extrapolate cash ﬂows beyond the budget period,
–
Current local GDP,
–
L
ocal inﬂation rates.
The following rates are used by the VUB Group:
€ ’000
2025
2024
Pre-tax discount rate – cash flows
15.87 %
14.71 %
Pre-tax discount rate – terminal value
16.23 %
15.70 %
Projected growth rate
4.33 %
4.44 %
3.11.
Property and equipment
Land and buildings are recognized at fair value based on periodic, but at least annual, valuations by external
independent specialized companies, less subsequent depreciation for buildings.
For buildings and land the Bank uses the revaluation model for subsequent measurement. Management determined
that these constitute one class of asset, based on the nature, characteristics and risks. The Bank uses the income
method, using market rents and yields as key inputs. Fair values are based on valuations performed by an accredited
independent valuer. The revaluation model aligned the book value to the current market value. Level 3 revaluation
was recognized due to signiﬁcant unobservable estimated v
aluation inputs.
The recoverable amount is determined with reference to the fair value less costs to sell or the value in use, if
determinable and if it is higher than fair value. For property and equipment other than buildings and land, ithe
carrying amount is generally assumed to correspond to the value in use, as it is determined through a depreciation
process based on the asset´s effective contribution to the production process, given that the determination of fair
value is extremely subjective. The two values diverge and lead to impairment in case of damages, exit from the
production process or other similar non-recurring circumstances. The Bank measures buildings and land according
to the revaluation model; in this case, any impairment loss on a revalued asset must be treated as a decrease in the
revaluation up to the relevant amount, after which any difference is taken to the income statement.
If the new fair value is higher than the carrying amount, the value of the asset on the balance sheet is increased
through other comprehensive income and accumulated in equity under the heading ‘Revaluation surplus of buildings
and land’. In case that an impairment loss was previously recorded in the income statement, the reversal of this
impairment is recorded in the income statement up to the amount previously recognized in the income statement.
If the new fair value is lower than the carrying amount, the decrease is recognized
in proﬁt or loss. The ISP Group
chose to apply the elimination approach, which means that the accumulated depreciation is eliminated against the
gross carrying amount of the asset at revaluation date. The assets subject to the revaluation model are depreciated
based on their revalued value.
Signiﬁcant part of branch premises that the Bank uses is a result of sale and leaseback transactions. These leasebacks
are recognized as rights of use assets and lease liabilities. Average lease term of these premises was estimated to
four years.
Separate Financial Statements
164
All other property and equipment are recorded at historical cost less accumulated depreciation and impairment
losses. Acquisition cost includes the purchase price plus other costs related to acquisition such as freight, duties or
commissions. The costs of expansion, modernisation or improvements leading to increased productivity, capacity or
efﬁciency are capitalised. Repairs and renovations are charged to the statement of proﬁt or loss when the
expenditure is incurred.
Depreciation charge is calculated on a straight-line basis in order to depreciate the cost of each asset to its residual
value over its estimated useful economic life, as follows:
Years
Buildings
10 – 33
Equipment
4 – 12
Other tangibles
4 – 12
Land, assets under construction and art collections are not depreciated. The depreciation of the assets under
construction begins when the related assets are put into use.
The Bank tests its assets for impairment on annual basis. Where the carrying amount of an asset is greater than its
estimated recoverable amount, it is written down to this recoverable amount.
Depreciation methods, useful lives and residual values are reassessed at the reporting date. Property and equipment
involve also right-of-use assets.
3.12.
Intangible assets
Intangible assets are recorded at historical cost less accumulated amortization and impairment losses. Amortisation
is calculated on a straight-line basis in order to amortise the cost of each asset to its residual value over its estimated
useful economic life as follows:
Years
Software and Other intangible assets
7 – 10
Amortisation methods, useful lives and residual values are reassessed at the reporting date.
Assets under development are not amortised. The amortization of the assets under development begins when the
related assets are put into use.
3.13.
Goodwill
Goodwill represents the excess of the cost of an acquisition over the fair value of the Bank’s share of the identiﬁable
assets, liabilities and contingent liabilities of the acquired subsidiary at the date of acquisition.
Goodwill is measured at cost less impairment, if any. Goodwill is tested for impairment annually or more frequently
if events or changes in circumstances indicate that the carrying amount may be impaired.
The impairment test is performed in the same way as stated in note 3.10.
3.14.
Leasing
Leases in which the Bank is a lessor
In case of lease contracts under which the Bank is acting as a lessor,
each of its leases is classiﬁed as either operating
or ﬁnance lease. Leases where a signiﬁcant portion of the risks and rewards of ownership are retained by the lessor
are classiﬁed as operating leases.
Separate Financial Statements
165
Finance leases
A lease is classiﬁed as a ﬁnance lease if it transfers substantially all the risks and rewards incidental to ownership to
the lessee. Examples of situations where the risks and rewards of ownership are considered as having been
transferred to the lessee are as follows:
–
The lease transfers ownership of the asset to the lessee by the end of the lease term,
–
The lessee has the option to purchase the asset at a price that is expected to be sufﬁciently lower than the fair
value at the date the option becomes exercisable for it to be reasonably certain, at the inception of the lease,
that the option will be exercised,
–
The lease term covers at least 3/4 of the economic life of the asset even if title is not transferred,
–
At the inception of the lease the present value of the minimum lease payments amounts to at least 90% of the
fair value of the leased asset, or
–
The leased assets are of such a specialized nature that only the lessee can use them without major modiﬁcations.
Lease classiﬁcation is made at the inception date and is reassessed only if there is a lease modiﬁcation.
At the commencement date, receivable from ﬁnance
leasing equal to the net investment in the lease is recognized
in the statement of ﬁnancial position in ‘Due from customers’.
Initial measurement of the lease payments included in the net investment in the lease:
–
Fixed payments, less any lease incentives payable;
–
Any residual value guarantees provided to the lessor by the lessee, a party related to the lessee or a third party
unrelated to the lessor that is ﬁnancially capable of discharging the obligations under the guarantee;
–
The exercise price of a purchase option if the lessee is reasonably certain to exercise that option; and
–
P
ayments of penalties for terminating the lease, if the lease term reﬂects the lessee exercising an option to
terminate the lease.
Subsequent measurement
Interest income is recognized
in proﬁt or loss statement in ‘Other interest income’ over the lease term using rate
implicit in the lease, which represents the discount rate that, at the inception of the lease, causes the aggregate
present value of the minimum lease payments and the unguaranteed residual value to be equal to the sum of the
fair value of the leased asset and any initial direct costs of the lessor.
The lease payments are charged against the gross investment in the lease and reduce both the principal and the
unearned ﬁnance income.
The detailed description of impairment of the net investment in the lease is to be found in the note 4.1.2.
Unguaranteed residual values are reviewed and estimated regularly in order to calculate the gross investment in the
lease. If there has been a reduction in the estimated unguaranteed residual value, income allocation over the lease
term is revised and any reduction in respect of amounts accrued is recognized immediately.
3.15.
Provisions
Provisions comprise litigations and claims, ﬁnancial guarantees and loan commitments.
Provisions for litigation and claims are recognized when the Bank has a present obligation (legal or constructive) as
a result of a past event, and it is probable that an outﬂow of resources embodying economic beneﬁts will be required
to settle the obligation, and a reliable estimate can be made of the amount of the obligation.
Financial guarantees are contracts that require the Bank to make speciﬁed payments to reimburse the holder for a
loss it incurs because a speciﬁed debtor fails to make a payment when it falls due, in accordance with the terms of
a debt instrument consisting of letters of credit, guarantees and acceptances.
Provisions for ﬁnancial guarantees are initially
recognized
in the ﬁnancial statements at fair value, being the premium
received. Subsequent to initial recognition, the Bank’s liability under each guarantee is measured at the higher of
the amount initially recognized less cumulative amortization recognized
in the in the statement of proﬁt or loss in
‘Fee and commission income’ on a straight-line basis over the lifetime of the guarantee, and an ECL allowance.
ECL allowances for ﬁnancial guarantees are
recognized
based on stage of ﬁnancial instrument (three
-stage approach)
which affects expected loss calculation for the ﬁnancial guarantee. Any increase or decrease in the provision deriving
from changes in ECL allowances relating to ﬁnancial guarantees is recorded in the statement of proﬁt or loss in
‘Impairment losses’.
Separate Financial Statements
166
In case when the Bank
is called to fulﬁl the guarantee and the guarantee is paid to the holder of the guarantee it
ceases to exist. Instead, a receivable against the counterparty for which the Bank issued the guarantee is created
and the former provision for ﬁnancial guarantees is converted into impairment losses allowance on such receivable
along with the movement, if any, within ’Impairment losses’.
Loan commitments are ﬁrm commitments to provide credit under pre
-
speciﬁed terms and conditions.
For loan
commitments the VUB Group also recognises Provisions based on stage of financial instrument. Any increase or decrease
in the provision relating to Loan commitments is reflected in the statement of profit or loss in ’Impairment losses’.
3.16.
Liabilities
for employee beneﬁts
The Bank’s obligation in respect of retirement and jubilee employee beneﬁts is the amount of future beneﬁt that
employees have earned in return for their service in the current and prior periods. Employee beneﬁt reserves are
disclosed in the statement o
f ﬁnancial position in ‘Other liabilities’. All gains or losses in relation to the employee
beneﬁts are
recognized
in ‘Salaries and employee beneﬁts’.
‘
Severance and Jubilee beneﬁts
‘ are discounted to determine their present value. The discount rate is determined by
reference to yield curve on Slovak government bonds with a ﬁfteen
-year term that represents the period closest to
the average beneﬁt duration. The calculation is performed using the Projected Unit Credit Method. For the
calculation the Bank used an average turnover rate which is based on historical data on employees’ turnover at the
Bank for the last three years. The average age-
speciﬁc tu
rnover rate is calculated as the ratio of number of
terminations and the average number of employees. All employees are covered by the retirement and jubilee
employee beneﬁts program.
3.17.
Equity reserves
The reserves recorded in equity that are disclosed in the statement of ﬁnancial position include:
–
‘Revaluation surplus of buildings and land’ reserve which consists of the revaluation surplus of buildings and
land measured at fair value using a revaluation model.
–
‘Cash ﬂow hedges’ reserve which comprises the portion of the gain or loss on a hedging instrument in a cash
ﬂow hedge that is determined to be an effective hedge.
–
‘Financial assets at fair value through other comprehensive income’ reserve which comprises changes in the fair
value of ﬁnancial assets at FVOCI.
–
‘Translation of foreign operation’ reserve which is used to record exchange differences arising from the
translation of the net investment in foreign operations.
3.18.
Net interest income
Net interest income comprises interest income and interest expense calculated using both the effective interest
method and other methods. These are disclosed separately on the face of the income statement for both interest
income and interest expense to provide symmetrical and comparable information.
Interest income and expense is recognized
in the statement of proﬁt or loss on an accrual basis using the effective
interest rate method (EIR) for all ﬁnancial instruments measured at
amortized cost (note 3.7.1. and 3.7.2).
In case of hedging relationship (as deﬁned in note 3.9) interest from interest rate swap effectively replaces the
contractual interest rate of the hedged item and such interest is disclosed under in ‘Interest income calculated using
the effective interest method’.
The IBOR reform Phase 2 amendments allow as a practical expedient for changes to the basis for determining
contractual cash ﬂows to be treated as changes to a ﬂoating rate of interest, provided certain conditions are met.
The conditions include that the change is necessary as a direct consequence of IBOR reform and that the transition
takes place on an economically equivalent basis.
Other interest income includes interest received on ﬁnancial assets at fair value through proﬁt or loss other than
interest on derivatives using the contractual interest rate and ﬁnance leases where the rate implicit in the lease is
being used.
Separate Financial Statements
167
Interest income/expense on all derivatives is recognized as a part of the fair value change in ‘Net trading result’.
Negative interest arising from ﬁnancial assets is presented in interest expense and negative interest arising from
ﬁnancial liabilities is presented in interest income.
According to the VUB Group´s accounting policy, the revision of the conditions of the instrument by the ECB is considered
as a change to a floating rate pursuant to par. B5.4.5 of IFRS 9, with a forward-looking adjustment to the interest rate,
considering the fact that the ECB has the option to change interest rates at its discretion in defining monetary policy rates.
The interest is therefore recognised periodically based on the interest rate of the instrument for each period as required by
paragraph B5.4.5 of IFRS 9.
3.19.
Net fee and commission income
The Bank earns fee and commission income from a diverse range of ﬁnancial services it provides to its customers.
Fee and commission income is recognized
at an amount that reﬂects the consideration to which the Bank expects
to be entitled in exchange for providing the services.
Fee and commission income and expense such as up-front and commitment fees that are integral to the effective
interest rate on a ﬁnancial asset or ﬁnancial liability are included in the effective interest rate (see note 3.
18).
Other fee and commission income arises on ﬁnancial services provided by the Bank including account maintenance,
cash management services, brokerage services, administrative services regarding loans, investment advice and
ﬁnancial planning, investment banking services, project ﬁnance transactions, asset management services, factoring
services and other. Fee and commission income and expense are recognized when the corresponding service is
provided. If a loan commitment is not expected to result in the draw-down of a loan, then the related loan
commitment fee is recognized on a straight-line basis over the commitment period.
The performance obligations, as well as the timing of their satisfaction, are identiﬁed and determined at the inception
of the contract. The Bank´s revenue contracts do not include multiple performance obligations.
The Bank has concluded that it is the principal in its revenue arrangements because it typically controls the services
before transferring them to the customer.
When the Bank provides a service to its customers, consideration is invoiced and generally due immediately upon
satisfaction of a service provided at a point in time or at the end of the contract period for a service provided over
time.
Separate Financial Statements
168
Nature and timing of satisfaction of performance obligations, including signiﬁcant payment terms:
Current accounts
Fees for ongoing account management are charged to the customer‘s account on a monthly
basis. The Bank sets the rates separately for retail and corporate banking customers in each
jurisdiction on an annual basis.
Cards
Credit card and debit card fees relate to both fees for issuance of credit card for the period of
card‘s validity as well as fees for specific transactions.
Payments and cash
management
Transaction-based fees for interchange and foreign currency transactions are charged to the
customer‘s account when the transaction takes place.
Loans
Services for loans comprise mainly fees for overdrafts, which are recognized on a straight-line
basis over the overdraft duration.
They also include other servicing fees, including finance leases, which are charged on a monthly
basis and are based on fixed-rates reviewed annually by the Bank.
Indirect deposits
These fees mainly relate to providing Bank’s retail network for the mediation of investments
into funds. These fees are paid to the Bank by Eurizon Asset Management Slovakia,
správ.
spol.,
a.s. Since the Bank does not have any ongoing performance obligation regarding these fees,
they are recognized in full when charged.
Insurance
The Bank provides insurance mediation along with selling its products. Except for life insurance
mediation, only aliquot part of commission is sent by the insurance company on a monthly
basis. Therefore,
the Bank only recognises aliquot part of commission as income with the
passage of time. In case a client cancels insurance contract with the insurance company, the
insurance company stops paying the aliquot part of the commission and the Bank therefore
stops to recognise
these fees. The Bank is not liable to return aliquot part of commissions
recognized in fees to insurance company.
Regarding life insurance mediation the Bank is exposed to clawbacks if client cancels the
insurance contract within certain periods. The Bank calculated effect of International Financial
Reporting Standard 15 Revenue from Contracts with Customers (‘IFRS 15
’) impact and
evaluated this impact as non-material and continues to recognise income on these fees as the
related mediation service is provided.
Trade finance, Structured
finance
Fees for loan commitments which are not expected to result in the draw-down of a loan are
recognized on a straight-line basis over the commitment period.
Administration of a loan syndication, execution of client transactions with exchanges and
securities underwriting, charges for premature termination of loans and other are charged
when transaction takes place.
Factoring
Services related to factoring include:
-
Facility commitment, where fee is recognized on a straight-line basis over the commitment
period;
-
Invoice processing fee, where fixed amount for each processed invoice is charged;
-
Factoring fee, where fee represent a percentage on a total receivable amount factored.
Revenue recognition under IFRS 15:
Current accounts
Revenue from account service and servicing fees is recognized over time as the services are
provided.
Cards
Revenue from card issuance is recognized over time as the services are provided.
Revenue related to transactions is recognized at the point in time when the transaction takes
place.
Payments and cash
management
Revenue related to transactions is recognized at the point in time when the transaction takes
place.
Loans
Overdraft fee is recognized on a straight-line basis over the overdraft duration.
Revenue related to transactions, including finance leases, is recognized
at the point in time
when the transaction takes place.
Indirect deposits
Revenue related to transactions is recognized at the point in time when the transaction takes
place.
Insurance
Revenue from insurance mediation services is recognized over time for the duration of contract,
except for life insurance mediation where service fee is recognized when service is provided and
clawbacks are recognized when they occur.
Trade finance, Structured
finance
Loan commitment fee is recognized on a straight-line basis over the commitment period.
Revenue related to transactions is recognized at the point in time when the transaction takes
place.
Factoring
Facility fee is recognized on a straight-line basis over the commitment period.
Revenues related to invoice processing and factoring fee are recognized
at the point in time
when the transaction takes place.
Separate Financial Statements
169
3.20.
Net trading result
‘Net trading result’ includes gains and losses arising from purchases, disposals and changes in the fair value of
Financial assets and financial liabilities including securities and derivative instruments. It also includes the result of all
foreign currency transactions.
3.21.
Current and deferred income tax and special levy
Income tax is calculated in accordance with the regulations of the Slovak Republic and other jurisdictions, in which
the Bank operates.
Income tax expense is recognized at each time interval during the accounting year based on the best estimate of the
weighted average annual income tax rate expected for the entire accounting year. In the event of a change in the
estimate of the annual income tax rate, the accrued amount of income tax costs in one of the time intervals during
the accounting year may be adjusted in the following period of the given accounting year.
Deferred income tax assets and liabilities are recognized, using the balance sheet method, for all temporary
differences arising between the carrying amounts of assets and liabilities and their tax bases. Expected tax rates,
applicable for the periods when assets and liabilities are realised, are used to determine deferred tax.
The Bank is also subject to various indirect operating taxes, which are included in ‘Other operating expenses’.
With effect from January 2024, a new type of special levy for the banking sector came into force in Slovakia. For the
year 2025, the amount of the special levy is set at 24.96
% of the proﬁt before tax, and in the following years, it will
gradually decrease to 15% in 2027. From 2028, banks will be subject to the standard rate of the special levy on
business in regulated sectors. The special levy for regulated entities is a tax-deductible expense.
Separate Financial Statements
170
4.
Financial and operational risk management
This note presents information about the Bank’s exposure to the risks related to the use of ﬁnancial
instruments, the
Bank’s objectives, policies and processes for measuring and managing risk.
The Management Board is the statutory body governing the executive management of the Bank, and has absolute
authority over all matters concerning risk. The Management Board has primary responsibility to create and dissolute
risk-related governance bodies. The primary governance bodies overseeing risk-related issues are:
–
Assets and Liabilities Management Committee (‘ALCO’),
–
Credit Risk Governance Committee (‘CRGC’),
–
Operational Risk Committee (‘ORC’).
The Management Board delegates its risk authority to these governance bodies through statutes, which identify
members of the governance bodies, competencies and responsibilities of the members. The competency of each
governance body is established in relevant Charters.
The Bank’s risk management policies are established to identify and analyse the risks faced by the Bank, to set
appropriate risk limits and controls and to monitor risks and adherence to limits. Risk management policies and
systems are reviewed regularly t
o reﬂect changes in market conditions, products and services offered. The Bank,
through its training and management standards and procedures, aims to develop a disciplined and constructive
control environment, in which all employees understand their roles and obligations. The Bank’s Internal Audit
Department is responsible for monitoring compliance with the Bank’s risk management policies and procedures, and
for reviewing the adequacy of the risk management framework in relation to the risks faced by the Bank. Internal
Audit undertakes both regular and ad-hoc reviews of risk management controls and procedures.
4.1.
Credit risk
Credit risk is the risk of a ﬁnancial loss to the Bank if a customer or counterparty to a ﬁnancial instrument fails to
meet its contractual obligations, and arises principally from the Bank’s loans and advances to customers and banks
as well as investment securities. For risk management reporting purposes, the Bank considers and consolidates all
elements of credit risk exposure (such as individual obligor default risk, country and sector risk). For risk management
purposes, the credit risk arising on trading securities is managed independently, but reported as a component of
market risk exposure.
The Credit Risk Charter (‘CRC’) establishes the guidelines for measurement, control and management of credit risk
by deﬁning the legal framework, main responsibilities, policies and methodologies that support the credit risk
management process of VUB.
More speciﬁcally, CRC deﬁnes both the general and speciﬁc (retail, corporate) credit risk requirements for applied
methodologies and procedures, and includes, as separate sections, the policies governing the key aspects of the
Bank’s credit risk management process:
–
Authorised Approval Authority,
–
Collateral Management Policy,
–
Provisioning Policy,
–
Credit Concentration Limits,
–
Default Deﬁnition,
–
Risk Management Client Segmentation Policy,
–
Corporate Credit Policy, Retail Credit Policy,
–
Retail and Corporate Remedial Management and Collections.
Separate Financial Statements
171
4.1.1.
Management of credit risk
The Risk Management Division is established within the Bank as a Control Unit and managed by the Chief Risk
Ofﬁcer, who is a member of the Bank’s
Management Board. The Risk Management Division is organisationally
structured to provide support to the Business Units, as well as to provide reporting of credit, market and operational
risks to the Supervisory Board and Management Board. The Risk Management Division is responsible for overseeing
the Bank’s credit risk including:
–
The development of credit risk strategies, policies, processes and procedures covering rules for credit assessment,
collateral requirements, risk grading and reporting;
–
Setting limits for the concentration of exposure to counterparties, related parties, countries and total assets and
monitoring compliance with those limits;
–
Establishment of the authorisation structure for the approval and renewal of credit facilities. Authorisation limits
are set in the CRC;
–
Credit risk assessment according to deﬁned policy;
–
Monitoring of quality portfolio performance and its compliance with set limits (regulatory, internal). Regular
reports are provided to the Management Board and the CRC on the credit quality of the Bank’s portfolios;
–
Development, maintenance and validation of scoring and rating models – both application and behavioural;
–
Development, maintenance and back-testing of impairment loss models.
4.1.2.
Impairment losses
The Bank establishes an allowance for impairment losses, which represents its ECL in its loan portfolio.
If there is evidence of impairment for any individually signiﬁcant client of the Bank, such as a breach of contract,
problems with repayments or collateral, the Bank transfers such a client to be managed by the Recovery Department
for pursuing collection activities. Such clients exceeding signiﬁcant thresholds (
EUR 500 thousand) are considered to
be individually impaired. For collective impairment (other than individually signiﬁcant client), the Bank uses historical
evidence of impairment and forward-looking information on a portfolio basis, mainly based on the payment
discipline of the clients.
Rules for identiﬁcation of signiﬁcant clients and methodology for calculation are set in the Credit Risk Charter or
are
stated in the Provisioning Policy procedure.
The individual assessment of exposures is based on the detailed review and analysis of the borrower’s situation.
The individual assessment, formulated analytically for each exposure, shall be based on the detailed and
comprehensive review of all elements that are available.
Inputs, assumptions and techniques used for estimating impairment
Calculation of ECL on a collective basis is based on particular regulatory segment, exposure at default (‘EAD‘),
probability of default (‘PD’), loss given default (‘LGD’), credit conversion factor (‘CCF’). For each segment were
developed models for such risk parameters. These models are regularly reviewed by development function,
Department Internal Validation and Controls and Department Internal Audit.
The methodology of risk parameters used in ECL calculation is compliant with the ISP Group methodology provided
by the Parent Company.
For PD models of the portfolios where the Bank uses internal models, the advanced approach is used.
For the portfolios, where it is unable to follow this approach (unavailability of internal model, low number of
observations, low number of defaults, unavailability of macroeconomic model for the portfolio) the Bank follows a
simpliﬁed approach, e.g. ﬁna
l values provided from the Parent Company, notching criteria, using the country rating
and LGD, etc.
The counterparties with low number of observations and with low numbers of observed defaults, where the Bank
was unable to create reliable migration matrices or develop the macroeconomic satellite models for prediction of
default rate, were deﬁned as the Low default portfolio. The parameters for these portfolios are obtained from
the
Parent Company.
EAD is calculated separately for amortizing and non-amortizing products. EAD for amortizing products is based on
the repayment plans, while EAD for non-amortizing products is calculated using Credit Conversion Factor (CCF).
Currently, the Bank uses CCF models only for Retail Credit Cards, Retail Overdrafts and Corporate. For all other
segments, regulatory CCF values are used.
Separate Financial Statements
172
Financial assets exposed to credit risk, broken down by institutional sector based on the ESA 2010 methodology:
2025
2024
€ ’000
Gross
amount
Impairment
losses
Net
amount
Gross
amount
Impairment
losses
Net
amount
Financial assets at AC
Due from banks
219 786
(6 711)
213 075
318 307
(5 869)
312 438
Due from customers
Financial corporations
1 141 423
(3 143)
1 138 280
1 333 387
(488)
1 332 899
Non-financial orporations
6 925 942
(146 748)
6 779 194
6 896 096
(139 148)
6 756 948
Retail
12 127 454
(207 724)
11 919 730
11 587 538
(198 875)
11 388 663
Public administration
1 992 590
(1 765)
1 990 825
981 052
(1 457)
979 595
Total due from customers
22 187 409
(359 380)
21 828 029
20 798 073
(339 968)
20 458 105
Total financial assets at AC
22 407 195
(366 091)
22 041 104
21 116 380
(345 837)
20 770 543
Financial assets
at FVOCI – debt securities
1 419 309
(270)
1 419 039
1 476 701
(212)
1 476 489
Loan commitments
and financial guarantees
5 830 124
(19 997)
5 810 127
5 682 652
(23 170)
5 659 482
Staging methodology
The three-stage approach is based on changes in credit quality since initial recognition:
–
Stage 1 includes ﬁnancial instruments that have not deteriorated signiﬁcantly in credit quality since
initial
recognition or that have low credit risk at the reporting date.
–
Stage 2 includes ﬁnancial instruments that have deteriorated signiﬁcantly in credit quality since initial recognition
but that do not have objective evidence of a credit loss event.
–
Stage 3 includes ﬁnancial assets that have objective evidence of impairment at the reporting
date.
The Bank implemented internal rules using signiﬁcant days past due, signiﬁcant increase of PD, forbearance
measures, early warning system, proactive credit management (‘PCM’) process, non-performing categories to assess
correct stage for expected loss calculation. These indicators are described in more detail below.
The Bank’s classiﬁcation of exposures into the stages is based on the following criteria:
STAGE 1
STAGE 2
STAGE 3
Performing exposures with DPD less
than 30
Performing non-defaulted contracts
with more than 30 days past due
Non-performing Past Due
Forborne performing exposures
Non-performing Unlikely to Pay
Performing exposures under PCM
Non-performing Doubtful
Performing exposures
with significant increase in PD
In general, the following rules are applied:
–
At origination ﬁnancial instruments are classiﬁed in Stage 1, except instruments which are credit
-impaired at the
date of acquisition, which are classiﬁed in the relevant stage;
–
If there is not enough information to determine if credit has deteriorated signiﬁcantly since origination, a ﬁnancial
instrument is classiﬁed into Stage 2.
As of 31 December 2025 and 31 December 2024
the Bank did not classify any ﬁnancial assets as Purchased or
Originated Credit Impaired (‘POCI‘).
Stage 2 criterion: Performing exposures with more than 30 past due days
There
is a rebuttable presumption that the credit risk on a ﬁnancial asset has increased signiﬁcantly since initial
recognition when contractual payments are more than 30 days past due.
Separate Financial Statements
173
Stage 2 criterion: Forborne performing exposures
Forborne status for performing exposures is identiﬁed as another criterion of credit deterioration since it represents
concessions towards a client facing or about to face difﬁculties in meeting its ﬁnancial commitments. Forborne
performing exposures represent Forborne performing (originally) and Forborne performing stemming from Non-
performing. The minimum probation period for these contracts is 24 months, after this period the contract might
migrate to Stage 1 if it meets exit criteria from Forborne cl
assiﬁcation (for example there is not more than 30 DPD,
contract is Performing or counterparty has repaid more than signiﬁcant amount of its debt since entering to
Forborne).
Stage 2 criterion: Performing exposures under proactive credit management
Exposures under
PCM are classiﬁed in Stage 2 since they can be considered as exposures that have deteriorated
signiﬁcantly in credit quality since their recognition.
Stage 2 criterion: Performing exposures with signiﬁcant increase in PD
A signiﬁcant increase of PD between origination (or initial recognition) and reporting date is used as
an indicator of
credit quality deterioration.
At each reporting date, an entity shall assess whether the credit risk on a ﬁnancial
instrument has increased signiﬁcantly since initial recognition. When making the assessment, an entity shall use the
change in the risk of a default occurring over the e
xpected life of the ﬁnancial instrument. PD at origination is used
solely for the purposes of staging.
This criterion is applied for all the portfolios. The thresholds for each portfolio can vary. In order to assess whether
credit risk has increased signiﬁcantly since the origination, it is necessary to compare Lifetime PD between
the
origination and reporting date.
This criterion is set individually for each portfolio however the main features of the methodology are common.
The proper setting of PD threshold is the core of this criterion. The Group methodology states the PD threshold could
be different based on portfolio/model, residual maturity, rating class or other potential drivers. Indeed, the
cumulative PDs and their relative differences (between some two rating grades) are changing very swiftly with
increasing residual maturity. That’s why the one common threshold for all maturities would not lead to proper
staging. The differentiation of thresholds between rating classes is important, too generally, the worse rating leads
to the lower threshold.
Stage 3 criterion
Stage 3 ﬁnancial assets are considered credit impaired. It is when one or more events that have a detrimental impact
on the estimated future cash ﬂows have occurred.
Evidence that a ﬁnancial asset is credit
-impaired includes the following observable data:
–
Signiﬁcant ﬁnancial difﬁculty of the borrower or issuer;
–
A breach of contract such as a default or past due event;
–
The restructuring of a loan or advance by the Bank on terms that the Bank would not consider otherwise;
–
It is becoming probable that the borrower will enter bankruptcy or other ﬁnancial reorganisation; or
–
The disappearance of an active market for a security because of ﬁnancial difﬁculties.
A loan that has been renegotiated due to a deterioration in the borrower’s status is usually considered to be credit-
impaired unless there is evidence that the risk of not receiving the contractual cash ﬂows has reduced signiﬁcantly
and there are no other indicators of impairment.
Staging criteria for debt securities
Staging process for bonds is performed in parallel to the staging of loans. The criteria used to assess whether the
credit quality of the bond has deteriorated signiﬁcantly since origination is Lifetime PDs comparison.
The following criteria are approved for each stage for debt securities:
STAGE 1
STAGE 2
STAGE 3
Bonds with no significant credit quality
deterioration
Investment grade bonds (Low Credit
Risk Exemption rule valid only for FVOCI
Bonds for First Time Adoption of IFRS 9
(‘FTA’))
Bonds with significant increase in PD
since origination
Defaulted bonds
Separate Financial Statements
174
In addition to the above-mentioned criteria, the following rules should be followed for Stage Assignment:
–
A
t origination ﬁnancial instruments are classiﬁed in Stage 1;
–
If there is not enough information to determine whether
credit has deteriorated signiﬁcantly since origination, a
ﬁnancial instrument is classiﬁed into Stage 2.
Staging criteria for Low Default Portfolio and Intragroup exposures
Low Default Portfolio consists of exposures with the following parties:
–
Sovereign (Central Banks, Governments, Municipalities, Public Sector Entities);
–
Institutions (Banks, and Other Non-banking Financial Institutions);
–
Large Corporate (Corporate with turnover more than EUR 500 million).
Intragroup exposures are exposures with the following parties:
–
Parent Company;
–
Bank’s own subsidiaries;
–
Other ISP Group subsidiaries.
Given their particular nature (exposures are within own bank group with low risk proﬁle), intragroup transactions
are always classiﬁed as Stage 1 with a 12
-months ECL.
Since the models for Low Default Portfolio were developed by the Parent Company, the staging rules for Low Default
Portfolio and Intragroup exposures are set by the Parent Company for loans and bonds and valid at ISP Group level.
Exposures are classiﬁed to Stage 2 based on the signiﬁcant increase of the credit risk criterion measure
d by Lifetime
PD comparison. This criterion for Low Default Portfolio is deﬁned based on the speciﬁc rating and residual maturity
of exposure. Thresholds are provided by the Parent Company. The thresholds are applied in the same way as
described above in
Stage 2 criterion: Performing exposures with signiﬁcant increase in PD.
Expected credit loss calculation
Stage 1
The Expected Loss for exposures in Stage 1 is calculated based on 1-year risk parameters (i.e. PD, LGD and EAD). In
the calculation for positions expiring during the ﬁrst
year, in order to avoid the counting of an entire PD on yearly
basis and to consider the real expiration date, PD can be adjusted appropriately. For the transactions without a
maturity date, it is conservatively assumed that they are subjected to annual review, and their maturity is assumed
to be equal to one year.
Stage 2
The Expected Loss for exposures in Stage 2 is based on a lifetime approach considering the residual maturity with
respect to the reporting date using appropriate cumulative values of risk parameters. In the calculation of Expected
Credit Loss for position
expiring during the ﬁrst year in order to avoid the counting of an entire PD on yearly basis
and to consider the real expiration date, PD should be adjusted. For the transactions without a maturity date, it is
assumed that they are subjected to an annual review, and their maturity is assumed to be equal to one year.
Stage 3
The VUB Group decided to determine the provision for Non-Performing exposures (transactions in Stage 3) as IAS 39
provision including an Add-on, which estimation is based on forward looking elements, increasing the current level
of coverage on NPLs.
Incorporation of forward-looking information
In order to incorporate forward-looking information, the VUB Group follows the methodology provided by the Parent
Company in both the PD and the LGD models. The predicted values of macro variables used in the models are
delivered by Parent Company.
PD models incorporate forward-looking information by using the Base scenario from the internal satellite models.
Other scenarios are incorporated in the form of “add-on”. Add-
on is calculated as a combination of ﬁnal PD values
calculated for all three scenarios for 3 upcoming years.
The VUB Group uses internally developed satellite models for the prediction of default rate for various segments.
These models are based on relevant macroeconomic variables. The output of these models contains the model for
the base scenario as well as the other scenarios, which are used to calculate the add-on.
Separate Financial Statements
175
For LGD models, the bank uses internally developed macroeconomic satellite models to include forward-looking
information into LGD parameter. The outputs of those models are the predicted values of loss given default for base
scenario increased by add-on, which incorporates the other scenarios. For NPL positions, the add-on is derived only
from the baseline and worst scenario and applied on TTC LGD value.
The VUB Group carries out recalibration or update of scenarios of satellite models on a regular basis.
4.1.3.
Non-performing loan classification
The Bank considers a ﬁnancial asset to be
of Non-performing status in compliance with the Commission’s
Implementing Regulation (EU) No 680/2014 and its further amendments (Implementing Technical Standards, ‘ITS’)
when:
–
The borrower is unlikely to pay its credit obligations to the Bank in full, without recourse by the Bank to actions
such as realising security (if any is held); or
–
The borrower is more than 90 days past due on any material credit obligations to the Bank.
The Bank uses the deﬁnitions of non
-performing loans derived from the Harmonisation project. The Harmonisation
project was driven by Intesa Sanpaolo in order to unify the deﬁnitions and categories of non
-performing loans across
the foreign subsidiaries o
f the ISP Group. The deﬁnition of non
-performing loans, which comprises
three classiﬁcation
categories (past due, unlikely to pay, doubtful), is based on delinquency (days past due) and judgemental criteria for
the categories doubtful and unlikely to pay. In case of the past due category, DPD and materiality thresholds of
borrower are taken into account.
The description of the classiﬁcation categories of loans is as follows:
Classification category
Description
Doubtful
Exposures to borrowers being in a state of insolvency (although not yet legally) or in a de facto
equivalent status, regardless of any loss forecasts made by the Bank.
Unlikely to pay
Exposures to borrowers assessed as improbable to thoroughly meet their credit obligations
without recourse to actions such as the enforcement of guarantees/ collateral.
Past due
Exposures other than those classified as doubtful or unlikely to pay that, as at the reporting
date, are past due (DPD methodology above) for over 90 days
Performing
All exposures that are not classified as doubtful, unlikely to pay or past due.
For the Unlikely to Pay category, following qualitative indicators are taken into account:
–
Borrowers facing difﬁculties in meeting payment obligations in a timely manner (thus exposed to their creditors’
tolerance), despite the conﬁdent expectation of positive future operating cash ﬂows;
–
Borrowers under negotiations with the Bank for deﬁning an
Out-of-Court restructuring/settlement agreement;
–
Borrowers which signed Out-of-Court restructuring/settlement agreements and that are regularly servicing their
ﬁnancial obligations;
–
Borrowers whose credit quality indicators signiﬁcantly worsened and where future cash ﬂows are not expected
to fully service the debt toward the Bank;
–
Serious difﬁculties in borrower’s business (additional equity required, liquidity seriously stretched).
For the Doubtful category, following qualitative indicators are taken into account:
–
If the borrower is under voluntary dissolution or under any legally binding liquidation, without possibility to
operate on ‘going concern basis‘;
–
If the Court already ordered the legal liquidation, even if the borrower’s operations are not suspended under
the legal procedures;
–
If according to any public Registry or by Court order the borrower ceases to exist as legal entity;
–
If the borrower has been registered (has to be registered) in the Fraud/Black List;
–
Borrowers which expected cash ﬂows will not be generated from the borrowers’ operations, but from the
enforcement of collateral/guarantees (‘gone concern’ approach);
–
Borrowers (typically individuals) against whom the Bank initiates receivership or enforcement proceedings.
–
Non-performing status is carried out at borrower level following the united rules of the Parent Company.
Separate Financial Statements
176
The following table describes the Bank’s credit portfolio in terms of classiﬁcation categories:
2025
€ ’000
Performing
Past due
Unlikely to pay
Doubtful
Total
Financial assets at AC
Due from banks
182 675
-
37 111
-
219 786
Due from customers
Financial corporations
1 138 874
-
2 530
19
1 141 423
Non-financial corporations
6 786 297
10 744
67 730
61 171
6 925 942
Retail
11 861 350
50 164
69 434
146 506
12 127 454
Public administration
1 992 590
-
-
-
1 992 590
Total due from customers
21 779 111
60 908
139 694
207 696
22 187 409
Gross amount
21 961 786
60 908
176 805
207 696
22 407 195
Impairment losses
(130 189)
(25 274)
(67 244)
(143 384)
(366 091)
Net amount
21 831 597
35 634
109 561
64 312
22 041 104
Financial assets at FVOCI –
debt securities
1 419 309
-
-
-
1 419 309
Loan commitments
and financial guarantees
5 806 411
1 669
18 099
3 945
5 830 124
2024
€ ’000
Performing
Past due
Unlikely to pay
Doubtful
Total
Financial assets at AC
Due from banks
262 586
-
55 721
-
318 307
Due from customers
Financial corporations
1 333 369
-
-
18
1 333 387
Non-financial corporations
6 749 827
9 176
88 891
48 202
6 896 096
Retail
11 367 738
41 277
51 325
127 198
11 587 538
Public administration
981 052
-
-
-
981 052
Total due from customers
20 431 986
50 453
140 216
175 418
20 798 073
Gross amount
20 694 572
50 453
195 937
175 418
21 116 380
Impairment losses
(142 173)
(23 339)
(62 868)
(117 457)
(345 837)
Net amount
20 552 399
27 114
133 069
57 961
20 770 543
Financial assets at FVOCI –
debt securities
1 476 701
-
-
-
1 476 701
Loan commitments
and financial guarantees
5 665 118
1 335
12 918
3 281
5 682 652
Separate Financial Statements
177
The table below shows the three-stage approach based on changes in credit quality by days past due for all
ﬁnancial
assets exposed to credit risk.
2025
Gross amount
Impairment losses
Net amount
€ ’000
Stage 1
Stage 2
Stage 3
Stage 1
Stage 2
Stage 3
Financial assets at AC
Due from banks
No delinquency
182 675
-
-
-
-
-
182 675
Over 181 days
-
-
37 111
-
-
(6 711)
30 400
182 675
-
37 111
-
-
(6 711)
213 075
Due from customers
Financial corporations
No delinquency
1 078 468
58 735
-
(475)
(351)
-
1 136 377
1 – 30 days
1 671
-
-
(3)
-
-
1 668
91 – 180 days
-
-
2 530
-
-
(2 307)
223
Over 181 days
-
-
19
-
-
(7)
12
1 080 139
58 735
2 549
(478)
(351)
(2 314)
1 138 280
Non-financial corporations
No delinquency
5 909 644
812 403
64 285
(15 271)
(51 325)
(26 724)
6 693 012
1 – 30 days
30 574
26 626
11 111
(447)
(1 997)
(7 529)
58 338
31 – 60 days
803
4 315
1 636
(15)
(494)
(371)
5 874
61 – 90 days
-
1 541
995
-
(136)
(240)
2 160
91 – 180 days
-
303
7 299
-
(8)
(3 654)
3 940
Over 181 days
-
88
54 319
-
(14)
(38 523)
15 870
5 941 021
845 276
139 645
(15 733)
(53 974)
(77 041)
6 779 194
Retail
No delinquency
11 031 103
597 834
48 523
(8 702)
(31 185)
(16 242)
11 621 331
1 – 30 days
67 580
126 468
22 283
(745)
(11 599)
(6 858)
197 129
31 – 60 days
2 287
23 122
18 779
(20)
(3 349)
(5 998)
34 821
61 – 90 days
294
9 261
17 164
(2)
(1 794)
(5 788)
19 135
91 – 180 days
7
2 901
38 751
(1)
(422)
(17 715)
23 521
Over 181 days
24
469
120 604
(1)
(68)
(97 235)
23 793
11 101 295
760 055
266 104
(9 471)
(48 417)
(149 836)
11 919 730
Public administration
No delinquency
1 961 304
28 753
-
(1 259)
(504)
-
1 988 294
1 – 30 days
2 477
13
-
(1)
(1)
-
2 488
31 – 60 days
-
-
-
-
-
-
-
61 – 90 days
-
43
-
-
-
-
43
1 963 781
28 809
-
(1 260)
(505)
-
1 990 825
Total due from customers
20 086 236
1 692 875
408 298
(26 942)
(103 247)
(229 191)
21 828 029
Total financial assets at AC
20 268 911
1 692 875
445 409
(26 942)
(103 247)
(235 902)
22 041 104
Financial assets at FVOCI
– debt securities
No delinquency
1 419 309
-
-
(270)
-
-
1 419 039
Loan commitments
and financial guarantees
No delinquency
5 155 263
651 148
23 713
(3 650)
(6 010)
(10 337)
5 810 127
Separate Financial Statements
178
2024
Gross amount
Impairment losses
Net amount
€ ’000
Stage 1
Stage 2
Stage 3
Stage 1
Stage 2
Stage 3
Financial assets at AC
Due from banks
No delinquency
262 586
-
-
(3)
-
-
262 583
Over 181 days
-
-
55 721
-
-
(5 866)
49 855
262 586
-
55 721
(3)
-
(5 866)
312 438
Due from customers
Financial corporations
No delinquency
1 333 283
86
-
(481)
-
-
1 332 888
1 – 30 days
-
-
-
-
-
-
-
91 – 180 days
-
-
-
-
-
-
-
Over 181 days
-
-
18
-
-
(7)
11
1 333 283
86
18
(481)
-
(7)
1 332 899
Non-financial corporations
No delinquency
5 518 844
1 164 765
73 642
(16 696)
(51 063)
(27 112)
6 662 380
1 – 30 days
36 717
22 587
3 332
(477)
(1 330)
(1 048)
59 781
31 – 60 days
537
3 882
2 835
(10)
(181)
(1 043)
6 020
61 – 90 days
45
2 241
2 658
(1)
(187)
(518)
4 238
91 – 180 days
26
94
7 455
(1)
(11)
(2 551)
5 012
Over 181 days
-
89
56 347
-
(14)
(36 905)
19 517
5 556 169
1 193 658
146 269
(17 185)
(52 786)
(69 177)
6 756 948
Retail
No delinquency
10 575 292
596 443
44 116
(10 133)
(39 533)
(17 469)
11 148 716
1 – 30 days
57 560
100 925
20 586
(977)
(12 689)
(8 182)
157 223
31 – 60 days
2 506
21 816
15 728
(59)
(4 017)
(6 167)
29 807
61 – 90 days
408
9 520
13 718
(8)
(2 325)
(4 981)
16 332
91 – 180 days
12
2 696
27 908
(1)
(445)
(14 709)
15 461
Over 181 days
181
379
97 744
(2)
(72)
(77 106)
21 124
10 635 959
731 779
219 800
(11 180)
(59 081)
(128 614)
11 388 663
Public administration
No delinquency
961 878
15 385
-
(948)
(399)
-
975 916
1 – 30 days
958
2 590
-
(3)
(107)
-
3 438
31 – 60 days
241
-
-
-
-
-
241
61 – 90 days
-
-
-
-
-
-
-
Total due from customers
963 077
17 975
-
(951)
(506)
-
979 595
Total financial assets at AC
18 488 488
1 943 498
366 087
(29 797)
(112 373)
(197 798)
20 458 105
18 751 074
1 943 498
421 808
(29 800)
(112 373)
(203 664)
20 770 543
Financial assets at FVOCI
– debt securities
No delinquency
1 476 701
-
-
(212)
-
-
1 476 489
Loan commitments
and financial guarantees
No delinquency
4 780 731
884 387
17 534
(3 283)
(15 548)
(4 339)
5 659 482
Separate Financial Statements
179
The reconciliation from the opening balance to the closing balance of the impairment losses to explain the changes
in the impairment losses and the reasons for those changes:
2025
2024
€ ’000
Stage 1
Stage 2
Stage 3
Stage 1
Stage 2
Stage 3
Financial assets at AC
1 January
29 800
112 373
203 664
42 588
123 749
210 790
Origination
21 751
-
-
27 888
-
-
Derecognition
(9 355)
(15 398)
(4 151)
(9 324)
(4 968)
(1)
Changes in credit risk (net)
(15 254)
6 272
81 214
(31 352)
(6 408)
54 992
Assets written-off/sold
-
-
(44 825)
-
-
(62 117)
31 December
26 942
103 247
235 902
29 800
112 373
203 664
Financial assets at FVOCI
1 January
212
-
-
232
-
-
Origination
57
-
-
25
-
-
Derecognition
-
-
-
(32)
-
-
Changes in credit risk (net)
49
-
-
(13)
-
-
Assets written-off/sold
(48)
-
-
-
-
-
31 December
270
-
-
212
-
-
Loan commitments and financial guarantees
1 January
3 283
15 548
4 339
4 722
7 776
4 390
Origination
8 975
-
-
17 245
-
-
Derecognition
(1 643)
(3 375)
(2 241)
(2 459)
(1 781)
(2 835)
Changes in credit risk (net)
(6 965)
(6 163)
8 239
(16 225)
9 553
2 784
31 December
3 650
6 010
10 337
3 283
15 548
4 339
When there is transfer between stages, the original amount of the provision is transferred ﬁrst and then the change
in credit risk is reﬂected in the new stage.
The changes due to modiﬁcations that does not result in derecognition of the ﬁnancial assets were immaterial.
The changes in the gross carrying amount of ﬁnancial instruments during the year contributed to changes in the
impairment losses:
2025
2024
€ ’000
Stage 1
Stage 2
Stage 3
Stage 1
Stage 2
Stage 3
Financial assets at AC
1 January
18 751 074
1 943 498
421 808
16 895 804
1 769 458
414 381
Origination
22 701 329
-
615 881
21 829 709
-
-
Derecognition
(20 444 739)
(814 277)
(101 196)
(19 230 280)
(393 448)
(97 610)
Changes in credit risk (net)
(881 073)
705 974
175 099
(744 159)
567 488
176 671
Assets written-off/sold
-
-
(50 302)
-
-
(71 634)
31 December
20 126 591
1 835 195
1 061 290
18 751 074
1 943 498
421 808
Financial assets at FVOCI
1 January
1 476 701
-
-
1 246 816
-
-
Origination
713 815
-
-
485 837
-
-
Derecognition
-
-
-
(52 412)
-
-
Assets written-off/sold
(771 207)
-
-
(203 540)
-
-
31 December
1 419 309
-
-
1 476 701
-
-
Loan commitments and financial guarantees
1 January
4 780 731
884 387
17 534
4 634 050
683 854
16 240
Origination
4 597 933
-
-
3 853 436
-
-
Derecognition
(4 389 200)
(54 003)
(7 258)
(3 425 333)
(64 357)
(15 238)
Changes in credit risk (net)
148 688
(162 125)
13 437
(281 422)
264 890
16 532
31 December
5 138 152
668 259
23 713
4 780 731
884 387
17 534
In 2025, the presentation of the tables showing movements in impairment losses and in the gross carrying amounts
of ﬁnancial instruments was revised. Transfers between individual stages, which were presented in separate columns
in the previous year, are included in the current year within the ‘Changes in credit risk (net)’ line item. This
modiﬁcation represents a presentation change only, has no impact on the total amount of impairment
losses or
gross carrying amounts, and enhances the clarity of the information disclosed.
Separate Financial Statements
180
4.1.4.
Loans with renegotiated terms and forbearance policy
Loans with renegotiated terms are loans that have been restructured due to deterioration in the borrower’s ﬁnancial
position, where the Bank has made concessions by agreeing to terms and conditions that are more favourable for
the borrower than the Bank had provided initially. The revised terms usually include extending maturity, changing
timing of interest payments and amendments to the terms of loan covenants. The Bank implements a forbearance
policy in order to maximise collection opportunities and minimise the risk of default. Under the Bank’s forbearance
policy, an exposure is identiﬁed as forborne if both of th
e following conditions are met:
–
The Bank has identiﬁed ﬁnancial difﬁculties that the debtor is facing
, or is about to face;
–
The exposure has been subject to renegotiation or
reﬁnancing,
granted in relation to the borrower’s current
ﬁnancial difﬁculties
,
or ﬁnancial difﬁculties that would have occurred in the absence of the renegotiation or
reﬁnancing
measures.
The bank follows rules in ECB Guidance to banks on non-performing loans issued in March 2017.
Forborne exposures are those falling into the ‘Non-performing exposures with forbearance measures‘ and
‘Performing Forborne exposures‘ categories.
Forbearance measures consist of concessions towards a debtor facing or about to face difﬁculties in meeting its
ﬁnancial commitments (
‘
ﬁnancial difﬁculties
‘).
Forbearance measures entail:
–
Favou
rable contractual modiﬁcations granted to the debtor solely in consideration of its ﬁnancial difﬁculties
(modiﬁcation);
–
The granting, in favou
r of a debtor in ﬁnancial difﬁculties, of a new loan to allow the fulﬁlment of the pre
-
existing obligation (reﬁnancing);
–
C
ontractual modiﬁcations which may be requested by a debtor within the scope of a contract already subscribed
and granted by the Bank in the knowledge that the debtor is in ﬁnancial difﬁculties (so
-called ‘embedded
forbearance clauses‘).
Therefore, the deﬁnition of forborne exposure excludes the renegotiations made for commercial reasons/practices.
The qualiﬁcation of
‘Forborne Exposure‘ refers to the individual transactions subject to renegotiation and/or
reﬁnancing and should not be extended to the entire counterparty. The ﬁnancial difﬁculty, however, shall be assessed
at a debtor level.
The ﬁnancial distress is always assumed if the counterparty is classiﬁed as non
-performing (absolute presumption).
The aim of forborne exposures is to prevent potential ﬁnancial difﬁculties of the debtor or to allow the return of the
exposure to a situation of sustainable repayment. In case of performing borrowers, such a measure should not be
used to delay the recla
ssiﬁcation to non
-
performing statuses of a borrower whose ﬁnancial conditions already justify
a downgrade of its risk classiﬁcation.
The extension of Forbearance Measures does not automatically lead to the classiﬁcation of the forborne exposures
as Non-Performing. Instead, a net present value (NPV) test is performed by Finevare to identify whether a forbearance
measure leads to a dimin
ished ﬁnancial obligation according to:
where:
–
DO is diminished ﬁnancial obligation;
–
NPV0 is net present value of cash ﬂows (including unpaid interest and fees) expected under contractual
obligations before the changes in terms and conditions of the contract discounted using the customer’s original
effective interest rate;
–
NPV1 is net present value of the cash ﬂows expected based on the new arrangement discounted using the
customer’s original effective interest rate.
I
f the diminished ﬁnancial obligation is higher than the threshold of 1%, the exposure is classiﬁed as Non
-performing,
otherwise it is Performing.
In order to identify forborne exposures, the European regulation envisages a distinction between absolute
presumptions and relative presumptions (rebuttable). Absolute presumptions refer to circumstances which always
fall within the concept of forborne, and don’t admit contrary evidence. Relative presumptions refer to circumstances
that fall within the concept of forborne until proven otherwise. Exclusively on the basis of speciﬁc analyses the Bank
Separate Financial Statements
181
can prove that a certain circumstance does not give rise to a forbearance measure.
Listed below are some examples of the most common forms of contractual modiﬁcations which may be qualiﬁed as
forbearance measures, when referred to counterparties in ‘
ﬁnancial difﬁculties
‘ (the list is not exhaustive):
–
Short term credit facilities subject to debt consolidation/debt rescheduling plan;
–
Medium/long-term loans subject to:
–
Restructuring of the amortization plan with reductions or temporary suspensions of the instalments;
–
Extension of the maturity;
–
Extension of the pre-amortization period;
–
Conversion of the repayment terms from instalments into bullet repayment at maturity;
–
Consolidation.
–
Contractual modiﬁcation/renegotiation resulting from the breach of ﬁnancial covenants (waiver, amendment,
cancellation) reﬁnancing;
–
Restructuring of performing exposures, or past due exposures not yet classiﬁed as non
-performing, involving a
pool of banks;
–
Contractual modiﬁcation of the economic conditions
, i.e., granting a borrower a new, more favourable interest
rate (‘off-market conditions‘);
–
Reﬁnancing of exposure, even short
-
term, with new ﬁnancing that allow the debtor to postpone repayment to
the bank;
–
Conversion of Debt to Equity;
–
In case of the Sale and Repurchase Agreements (REPOs), the capitalization of outﬂows when mark to market is
negative.
Furthermore, according to the European regulation, the following cases have to be recognized as forborne exposures
(they therefore represent ‘absolute‘ presumptions):
–
Contractual modiﬁcations that imply partial or total write
-off of exposure;
–
The exercise of clauses which, when enforced at the discretion of the debtor, enable him to change the terms
of the contract (‘embedded forbearance clauses‘);
–
Providing new ﬁnancing to the debtor simultaneously (or almost) to the payment of principal and/or interest on
another exposure.
Both retail and corporate customers are subject to the forbearance policy:
Performing forborne
Non-performing forborne
2025
€ ’000
Gross
amount
Impairment
losses
Net
amount
Gross
amount
Impairment
losses
Net
amount
Financial assets at AC
Due from banks
-
-
-
37 111
(6 711)
30 400
Due from customers
Non-financial
corporations
83 663
(3 697)
79 966
67 567
(34 385)
33 182
Retail
70 349
(3 885)
66 464
42 438
(23 396)
19 042
Public administration
-
-
-
-
-
-
154 012
(7 582)
146 430
147 116
(64 492)
82 624
Loan commitments
and financial guarantees
15 727
(11)
15 716
1 491
(871)
620
Performing forborne
Non-performing forborne
2024
€ ’000
Gross
amount
Impairment
losses
Net
amount
Gross
amount
Impairment
losses
Net
amount
Financial assets at AC
Due from banks
-
-
-
55 721
(5 866)
49 855
Due from customers
Non-financial
corporations
64 496
(1 780)
62 716
67 811
(39 629)
28 182
Retail
71 973
(5 056)
66 917
37 222
(22 282)
14 940
Public administration
6
-
6
-
-
-
136 475
(6 836)
129 639
160 754
(67 777)
92 977
Loan commitments
and financial guarantees
5 018
(7)
5 011
2 915
(530)
2 385
Separate Financial Statements
182
4.1.5.
Write-off Policy
The Bank writes off a loan or security balance when it determines that the loans or securities are uncollectible. In
principle, the Bank considers the credit balances to be uncollectible based on the past due days (1 080 days past
due). Credit balances may be written off only if the collateral has already been realized. Receivables subject to write-
off are being collected by external collection agencies until they qualify for write-off.
The credit balance can be written off earlier than deﬁned
under the conditions described above if there is evidence
that the receivable cannot be collected. The write-off of such receivables is subject to the approval of the Credit Risk
Ofﬁcer.
Financial assets that are written-off are subject of continuous enforcement process. The majority of such assets are
subject to sale to third parties at the best available prices.
The amount of loans written off during the year that are still subject to enforcement activity is EUR 16 666 thousand
(31 December 2024: EUR 33 226 thousand).
4.1.6.
Collateral Policy
The Bank’s collateral policy is an integral and indispensable part of the credit risk management and credit risk
mitigation for VUB. Collateral is used primarily to provide the Bank with the means for repayment of an exposure in
the event of the default of the borrower. The principal objective of the policy is to clearly set up rules for a common
and standard set of collateral types used by the Bank in its lending activities. The rules, as the minimum, describe
and state:
–
Conditions for legal enforceability;
–
Conditions for the process of valuation and the maximum values accepted by the Bank at the origination for
speciﬁc types of collaterals; and
–
Conditions for the process of revaluation.
However, collateral management has a wider meaning than the simple taking of collateral in order to secure the
repayment of the Bank’s exposures. This includes the following:
–
The establishment and maintenance of a collateral policy deﬁning the types of collateral taken by the Bank, the
legal documentation used by the Bank to secure its right to this collateral in the event of default and the valuation
of this collateral at origination. These aspects of collateral management are addressed in the internal policy
document;
–
The relevant and proper implementation and registration of collateral to secure the Bank’s right to collateral in
the event of default by the borrower;
–
The regular monitoring and re-valuation of collateral held by the Bank during the life of the exposure;
–
The analysis, monitoring and review of realization rates achieved by Recovery Department activities in order to
assess the effectiveness of the collateral policy as a risk mitigant.
The Bank’s decision on the enforcement of collateral is individual and depends on factors such as the actual amount
of the receivable, the current condition and value of the collateral, the length of the collateral realization period or
collection related costs. The relevant competent body of the Bank decides which collateral instrument will be used.
The Bank mainly uses the following means of enforcement of collateral:
–
Voluntary auction,
–
Foreclosure procedure,
–
Realization of the collateral for the receivable in a bankruptcy procedure,
–
Sale of receivables including collateral.
The Bank holds collateral and other credit enhancements against certain of its credit exposures. The collateral against
loans and advances to customers is held in the form of mortgage interests over property, other registered securities
over assets, and guarantees. Estimates of fair value are based on the value of collateral assessed at the time of
borrowing and the Bank updates the fair value on a regular basis.
Separate Financial Statements
183
The Bank mitigates the credit risk of derivatives, reverse sale and repurchase agreements by entering into master
netting agreements and holding collateral in the form of cash and marketable securities. Derivative transactions are
either transacted on an exchange or over-the-counter (OTC). The relevant contractual documentation for derivative
transactions (e.g. the ISDA Master Agreement as a contractual standard published by the International Swaps and
Derivatives Association) contains provisions governing netting arrangements. In general, under the ISDA Master
Agreement or other similar types of master agreements for derivative transactions, in certain circumstances, for
example in the event of default, all or only some of the active transactions may be terminated, a ﬁnal value
determined and the net value used to settle the relevant affected transactions.
The value of collateral accepted by the Bank (fair value adjusted by internal haircuts limited to outstanding amount
of credit exposure) and other security enhancements held against ﬁnancial assets is shown below:
2025
2024
€ ’000
Total
Stage 3
Total
Stage 3
Property
11 190 436
93 243
10 855 118
143 088
of which LTV* higher than 60% and lower than 80%
4 915 773
39 763
3 159 036
12 586
of which LTV higher than 80% and lower than 100%
1 739 577
11 628
1 500 481
6 912
of which LTV higher than 100%
244 091
5 869
227 166
1 901
Debt securities
899 021
1 329
54 499
515
Other
892 074
15 344
595 192
71 830
12 981 531
109 916
11 504 809
215 433
* LTV (loan to value) is the ratio of the current balance sheet balance of a loan to the currently allocated value of collateral for a given contract.
4.1.7.
Offsetting financial assets and financial liabilities
Offsetting ﬁnancial assets and ﬁnancial liabilities relates to ﬁnancial assets and ﬁnancial liabilities that are:
–
Offset in the statement of ﬁnancial position; or
–
Subject to an enforceable master netting arrangement or similar agreement that covers similar ﬁnancial
instruments, irrespective of whether they are offset in the statement of ﬁnancial position.
In general, the similar agreements include derivative clearing agreements, global master repurchase agreements,
and global master securities lending agreements. Similar ﬁnancial instruments include derivatives, sales and
repurchase agreements, reverse sale and repurchase agreements, and securities borrowing and lending agreements.
Financial instruments such as loans and deposits are not disclosed in the tables below unless they are offset in the
statement of ﬁnancial position.
The ISDA and similar master netting arrangements do not meet the criteria for offsetting in the statement of ﬁnancial
position. This is due to the fact they create for the parties to the agreement a right of set-off of recognized amounts
that is enforceable only following an event of default, insolvency or bankruptcy of the Bank or the counterparties or
following other predetermined events. In addition, the Bank and its counterparties do not intend to settle on a net
basis or to realize the assets and settle the liabilities simultaneously.
The Bank receives and gives collateral in the form of cash and marketable securities in respect of the following
transactions:
–
Derivatives,
–
Security ﬁnancing transaction agreements.
Such collateral is subject to standard industry terms including, when appropriate, an ISDA/Credit Support Annex
(CSA) and Global Master Repurchase Agreement (‘GMRA’). This means that securities received or given as collateral
can be pledged or sold during the term of the transaction but have to be returned on maturity of the transaction.
The terms also give each party the right to terminate the related transactions on the counterparty’s failure to post
collateral.
Separate Financial Statements
184
The following tables show the ﬁnancial assets and ﬁnancial liabilities that are subject to enforceable master netting
arrangements and similar agreements in the statement of ﬁnancial position (‘SOFP‘):
Related amounts not offset in SOFP
2025
€ ’000
Note
Gross
amount
Gross
amount
offset
in SOFP
Net amount
presented
in SOFP
Financial
instrument and
non-cash
collateral
Cash
collateral
received
Net
amount
Types of financial assets
Reverse repo transactions
7
825 233
-
825 233
(825 233)
-
-
Derivative financial instruments
8, 9
136 259
-
136 259
-
(23 772)
112 487
Types of financial liabilities
Derivative financial instruments
8, 9
150 779
-
150 779
-
(182 411)
(31 632)
Related amounts not offset in SOFP
2024
€ ’000
Note
Gross
amount
Gross
amount
offset
in SOFP
Net amount
presented
in SOFP
Financial
instrument and
non-cash
collateral
Cash
collateral
received
Net
amount
Types of financial assets
Reverse repo transactions
7
990 078
-
990 078
(990 078)
-
-
Derivative financial instruments
8, 9
123 545
-
123 545
-
(660)
122 885
Types of financial liabilities
Derivative financial instruments
8, 9
247 868
-
247 868
-
(211 302)
36 566
4.1.8.
Concentrations of credit risk
The Bank monitors concentrations of credit risk by geographic location. An analysis of concentrations of credit risk
at the reporting date is shown below.
2025
€ ’000
Slovakia
The Czech
Republic
Other
European
countries
America
Asia
Rest of the
World
Total
Financial assets at AC
Due from banks
86
-
182 411
37 111
178
-
219 786
Due from customers
Financial corporations
239 902
499 737
401 784
-
-
-
1 141 423
Non-financial corporations
4 344 386
733 080
1 591 393
-
257 083
-
6 925 942
Retail
11 923 905
19 129
158 116
5 154
16 000
5 150
12 127 454
Public administration
1 784 843
-
207 747
-
-
-
1 992 590
Total due from customers
18 293 036
1 251 946
2 359 040
5 154
273 083
5 150
22 187 409
Gross amount
18 293 122
1 251 946
2 541 451
42 265
273 261
5 150
22 407 195
Impairment losses
(348 704)
(1 549)
(8 739)
(6 718)
(329)
(52)
(366 091)
Net amount
17 944 418
1 250 397
2 532 712
35 547
272 932
5 098
22 041 104
Financial assets at FVOCI –
debt securities
478 890
378 033
525 712
36 675
-
-
1 419 310
Loan commitments and financial
guarantees
3 524 010
1 393 819
816 405
389
95 275
226
5 830 124
Separate Financial Statements
185
2024
€ ’000
Slovakia
The Czech
Republic
Other
European
countries
America
Asia
Rest of the
World
Total
Financial assets at AC
Due from banks
78
-
262 384
55 721
124
-
318 307
Due from customers
Financial corporations
210 034
420 826
702 527
-
-
-
1 333 387
Non-financial corporations
4 309 927
861 727
1 377 978
-
345 745
719
6 896 096
Retail
11 355 450
19 258
183 024
5 239
18 855
5 712
11 587 538
Public administration
981 052
-
-
-
-
-
981 052
Total due from customers
16 856 463
1 301 811
2 263 529
5 239
364 600
6 431
20 798 073
Gross amount
16 856 541
1 301 811
2 525 913
60 960
364 724
6 431
21 116 380
Impairment losses
(315 184)
(2 136)
(22 335)
(5 885)
(243)
(54)
(345 837)
Net amount
16 541 357
1 299 675
2 503 578
55 075
364 481
6 377
20 770 543
Financial assets at FVOCI –
debt securities
785 190
31 446
577 035
83 031
-
-
1 476 702
Loan commitments and financial
guarantees
3 778 160
1 154 198
640 886
312
108 761
335
5 682 652
An analysis of exposures based on the carrying amounts for the non-
ﬁnancial
sector
i
s shown in the table below.
€ ’000
2025
2024
Non-financial corporations
Agriculture, forestry and fishing
298 912
314 094
Mining and quarrying
119 719
139 480
Manufacturing
1 027 121
1 174 830
Electricity, gas, steam and air conditioning supply
642 186
569 325
Water supply
43 951
54 467
Construction
474 062
467 378
Wholesale and retail trade
1 135 297
1 118 783
Transport and storage
608 290
679 399
Accommodation and food service activities
74 259
71 146
Information and communication
98 565
78 017
Financial and insurance activities*
48 606
36 642
Real estate activities
715 409
749 833
Professional, scientific and technical activities
504 899
504 891
Administrative and support service
609 337
366 038
Public administration and defence, compulsory social security
109
209
Education
21 471
16 820
Human health services and social work activities
70 838
79 329
Arts, entertainment and recreation
14 259
13 119
Other services
418 652
462 296
Gross amount
6 925 942
6 896 096
Impairment losses
(146 748)
(139 148)
Net amount
6 779 194
6 756 948
* ‘Financial and insurance activities’ involves ﬁnancial services, leasing and insurance.
Separate Financial Statements
186
4.1.9.
Internal and external ratings
The overview of the internal rating scales according to the risk proﬁle applicable for the corporate exposures and the
retail exposures from small business,
ﬂat
owners’ associations and public administrations is shown below.
Risk Profile
Description
Very Low
Good quality of assets, strong market penetration, steady activity, proven distinctive managerial skills,
broad debt coverage capacity.
Low
Satisfactory quality and chargeability of assets, market penetration and managerial quality
on the average; well-set solvency, capital structure and debt composition; above average
debt coverage capacity.
Lower-Intermediate
Acceptable quality and chargeability of available assets, even if with a not negligible degree of risk;
well-balanced solvency, capital structure and debt composition with slight liquidity surplus and weaker
debt coverage capacity.
Intermediate
Acceptable quality and chargeability of available assets even if with a significant degree of risk;
vulnerable margin at times, capital structure and debt composition that show worsening signals; low
level of liquidity and short debt coverage margin.
Upper-Intermediate
Still acceptable asset quality even if with possible liquidity stress; high level of gearing; managerial
weakness, little market penetration and positioning; margins and competitiveness under pressure.
High
In addition to riskiness features for Upper–Intermediate profile, there are evident difficulties as well as
problematic debt management.
Very high
Highly vulnerable to non-payment, dependent on favourable conditions, likely to default.
Default
A default is considered to have occurred with regard to a particular obligor when
one or both of the
following events have taken place:
-
the obligor is past due more than 90 days (Days past due methodology) on any material credit
obligation to the Bank, the Parent Company undertaking or any of its subsidiaries;
-
the Bank considers that the obligor is unlikely to pay its credit obligations to the banking group in
full, without recourse by the Bank to actions such as realizing security (if held).
Specialized Lending comprises the rating segments SPV. For Specialized Lending, the Bank uses the Slotting
approach. C
lients are assigned into ﬁve slotting categories based on a qualitative valuation and information about
the risk of default. Risk weights and expected losses
used for the capital requirement calculation are also deﬁned for
each category. Categories are predeﬁned by the Regulation (EU) No 575/2013 on prudential requirements for credit
institutions and investment ﬁrms (‘CRR’) and internally, the categories us
ed are as follows:
Specialized Lending – SPV
–
Strong
–
Good
–
Satisfactory
–
Weak
–
Default
For mortgages and unsecured retail, the retail segment incorporates many individually insigniﬁcant exposures with
various characteristics, therefore the description of ratings correlates with these risk proﬁles.
Risk Profile
Description
Very Low
High level of client’s socio-demographic information and financial discipline.
Low
Above average level of client’s socio-demographic information and financial discipline.
Lower
–
Intermediate
Acceptable level of client’s socio-demographic information and financial discipline.
Intermediate
Acceptable level of client’s socio-demographic information and financial discipline, but there are some
signals of worsening credit quality.
Upper
–
Intermediate
Acceptable level of client’s socio-demographic information and financial discipline, but there
is worsening credit quality.
High
Acceptable level of client’s socio-
demographic information and financial discipline, but there
is negative credit behaviour.
Default
A default is considered to have occurred with regard to a particular mortgage/obligor when either or both
of the two following events have taken place:
-
The obligor is past due more than 90 days (Days past due methodology) on any material credit
obligation to the Bank (absolute threshold is set according to NBS directive);
-
The Bank considers that the obligor is unlikely to pay its credit obligations to the banking group in
full, without recourse by the Bank to actions such as realizing security (if held).
In the segments of the public sector entities, factoring and leasing, the Bank does not assign an internal rating to
the client.
Separate Financial Statements
187
Capital requirement calculation
The Bank generally employs the standardized approach for the calculation of the capital requirements. However, for
the calculation of the credit and counterparty risk capital requirements, the Bank, having received authorisation from
the Supervisory Authority National Bank of Slovakia (’NBS’), uses the Advanced IRB approach for its portfolio of
residential mortgages from July 2012 and for the Corporate segment, Small and Medium size enterprises (SME) and
for Retail Small Business from June 2014. In December 2022, the VUB Group received authorisation to use IRB
approach also for Unsecured retail segment. Slotting approach is employed for portfolio of Specialised lending
exposures. After CCR III implementation FIRB approach is used for Large Corporate segment, and in November 2025
FIRB approach has been approved also for Institutions exposure class. The Bank is also proceeding with the
development of IRB models in accordance with the gradual rollout plan for the advanced approaches presented to
the Supervisory Authority.
The following table shows the quality of the Bank’s credit portfolio in terms of internal ratings:
2025
Gross amount
Impairment losses
Net amount
€ ’000
Stage 1
Stage 2
Stage 3
Stage 1
Stage 2
Stage 3
Financial assets at AC
Due from banks
Very Low
12 258
-
-
-
-
-
12 258
Low
-
-
-
-
-
-
-
Lower–Intermediate
-
-
-
-
-
-
-
Intermediate
-
-
-
-
-
-
-
Upper–Intermediate
-
-
-
-
-
-
-
High
170 331
-
-
-
-
-
170 331
Default
-
-
37 111
-
-
(6 711)
30 400
Unrated
86
-
-
-
-
-
86
182 675
-
37 111
-
-
(6 711)
213 075
Due from customers
Financial corporations
Very Low
490 734
58 631
-
(37)
(6)
-
549 322
Low
245 882
-
-
(131)
-
-
245 751
Lower–Intermediate
52 887
-
-
(156)
-
-
52 731
Intermediate
290 057
44
-
(153)
(339)
-
289 609
Upper–Intermediate
25
60
-
-
(6)
-
79
High
-
-
-
-
-
-
-
Default
-
-
2 549
-
-
(2 314)
235
Unrated
554
-
-
(1)
-
-
553
1 080 139
58 735
2 549
(478)
(351)
(2 314)
1 138 280
Non-financial corporations
Very Low
1 684 660
30 900
-
(851)
(160)
-
1 714 549
Low
1 539 462
1 314
-
(458)
-
-
1 540 318
Lower–Intermediate
1 465 211
243 767
-
(4 301)
(1 907)
-
1 702 770
Intermediate
326 586
107 934
-
(1 265)
(1 896)
-
431 359
Upper–Intermediate
232 589
411 987
-
(7 441)
(48 551)
-
588 584
High
-
-
-
-
-
-
-
Very high
45
1
-
-
-
-
46
Default
(5)
-
134 468
-
-
(73 165)
61 298
Unrated
769
20
-
-
-
-
789
5 249 317
795 923
134 468
(14 316)
(52 514)
(73 165)
6 039 713
Non-financial corporations –
specialised lending
Strong
269 732
4 656
-
(162)
(118)
-
274 108
Good
376 140
23 561
-
(574)
(367)
-
398 760
Satisfactory
36 362
18 668
-
(316)
(782)
-
53 932
Weak
9 470
2 468
-
(365)
(193)
-
11 380
Default
-
-
5 177
-
-
(3 876)
1 301
Unrated
-
-
-
-
-
-
-
691 704
49 353
5 177
(1 417)
(1 460)
(3 876)
739 481
Retail
Very Low
7 063 519
31 908
-
(594)
(317)
-
7 094 516
Low
1 579 134
19 878
-
(278)
(161)
-
1 598 573
Lower–Intermediate
2 101 341
247 195
-
(2 483)
(4 757)
-
2 341 296
Intermediate
226 587
194 553
-
(1 922)
(6 709)
-
412 509
Upper–Intermediate
103 405
148 332
-
(3 310)
(14 422)
-
234 005
High
9 662
117 983
-
(884)
(22 051)
-
104 710
Default
-
-
266 104
-
-
(149 836)
116 268
Unrated
17 647
206
-
-
-
-
17 853
11 101 295
760 055
266 104
(9 471)
(48 417)
(149 836)
11 919 730
(Table continues on the next page)
Separate Financial Statements
188
2025
Gross amount
Impairment losses/Provisions
Net amount
€ ’000
Stage 1
Stage 2
Stage 3
Stage 1
Stage 2
Stage 3
Financial assets at AC
Due from customers
Public administration
Very Low
115 988
3 262
-
(108)
(4)
-
119 138
Low
51 700
2 182
-
(22)
(4)
-
53 856
Lower–Intermediate
-
-
-
-
-
-
-
Intermediate
11 498
2 794
-
(8)
(27)
-
14 257
Upper–Intermediate
93 853
20 150
-
(273)
(437)
-
113 293
High
442
328
-
(17)
(27)
-
726
Default
-
-
-
-
-
-
-
Unrated
1 690 300
93
-
(832)
(6)
-
1 689 555
1 963 781
28 809
-
(1 260)
(505)
-
1 990 825
Total due from customers
20 086 236
1 692 875
408 298
(26 942)
(103 247)
(229 191)
21 828 029
Total financial assets at AC
20 268 911
1 692 875
445 409
(26 942)
(103 247)
(235 902)
22 041 104
Financial assets at FVOCI
– debt securities
Unrated
1 419 309
-
-
(270)
-
-
1 419 039
Loan commitments
and financial guarantees
Due from banks
Very Low
10 987
-
-
(1)
-
-
10 986
Low
-
-
-
-
-
-
-
Lower–Intermediate
-
-
-
-
-
-
-
Intermediate
185
-
-
-
-
-
185
Upper–Intermediate
-
-
-
-
-
-
-
High
207 275
-
-
(7)
-
-
207 268
Default
-
-
-
-
-
-
-
Unrated
1 909
5
-
-
-
-
1 914
220 356
5
-
(8)
-
-
220 353
Due from customers
Financial corporations
Very Low
130 143
6 003
-
(19)
-
-
136 127
Low
73 710
-
-
(27)
-
-
73 683
Lower–Intermediate
6 092
-
-
(25)
-
-
6 067
Intermediate
28 588
505
-
-
(27)
-
29 066
Upper–Intermediate
-
3
-
-
-
-
3
High
-
-
-
-
-
-
-
Default
-
-
-
-
-
-
-
Unrated
167
-
-
-
-
-
167
238 700
6 511
-
(71)
(27)
-
245 113
Non-financial corporations
Very Low
1 631 567
144 342
-
(605)
(25)
-
1 775 279
Low
986 407
70 936
-
(264)
(4)
-
1 057 075
Lower–Intermediate
706 992
120 044
-
(737)
(391)
-
825 908
Intermediate
176 654
83 401
-
(298)
(651)
-
259 106
Upper–Intermediate
45 070
120 314
-
(1 129)
(4 395)
-
159 860
High
-
-
-
-
-
-
-
Very high
9
-
-
-
-
-
9
Default
-
-
20 299
-
-
(10 152)
10 147
Unrated
2 489
400
-
-
-
-
2 889
3 549 188
539 437
20 299
(3 033)
(5 466)
(10 152)
4 090 273
(Table continues on the next page)
Separate Financial Statements
189
2025
Gross amount
Provisions
Net amount
€ ’000
Stage 1
Stage 2
Stage 3
Stage 1
Stage 2
Stage 3
Loan commitments
and financial guarantees
Due from customers
Non-financial corporations –
specialised lending
Strong
160 977
3 669
-
(38)
-
-
164 608
Good
150 071
18 033
-
(94)
(58)
-
167 952
Satisfactory
606
-
-
(2)
-
-
604
Weak
-
-
-
-
-
-
-
Default
-
-
-
-
-
-
-
Unrated
-
-
-
-
-
-
-
311 654
21 702
-
(134)
(58)
-
333 164
Retail
Very Low
285 037
6 152
-
(15)
(18)
-
291 156
Low
100 455
5 196
-
(8)
(3)
-
105 640
Lower–Intermediate
202 106
55 175
-
(61)
(103)
-
257 117
Intermediate
25 623
3 313
-
(35)
(39)
-
28 862
Upper–Intermediate
6 668
4 925
-
(28)
(246)
-
11 319
High
1 096
674
-
(11)
(42)
-
1 717
Default
-
-
3 414
-
-
(185)
3 229
Unrated
211
58
-
-
-
-
269
621 196
75 493
3 414
(158)
(451)
(185)
699 309
Public administration
Very Low
101 795
1 981
-
(28)
-
-
103 748
Low
36 756
2 800
-
(7)
-
-
39 549
Lower–Intermediate
-
-
-
-
-
-
-
Intermediate
8 587
110
-
(3)
-
-
8 694
Upper–Intermediate
20 006
3 067
-
(30)
(8)
-
23 035
High
-
22
-
-
-
-
22
Default
-
-
-
-
-
-
-
Unrated
47 025
20
-
(178)
-
-
46 867
214 169
8 000
-
(246)
(8)
-
221 915
Total due from customers
4 934 907
651 143
23 713
(3 642)
(6 010)
(10 337)
5 589 774
Total financial assets at AC
5 155 263
651 148
23 713
(3 650)
(6 010)
(10 337)
5 810 127
Separate Financial Statements
190
2024
Gross amount
Impairment losses
Net amount
€ ’000
Stage 1
Stage 2
Stage 3
Stage 1
Stage 2
Stage 3
Financial assets at AC
Due from banks
Very Low
80 185
-
-
(3)
-
-
80 182
Low
182 323
-
-
-
-
-
182 323
Lower–Intermediate
-
-
-
-
-
-
-
Intermediate
-
-
-
-
-
-
-
Upper–Intermediate
-
-
-
-
-
-
-
High
-
-
-
-
-
-
-
Default
-
-
55 721
-
-
(5 866)
49 855
Unrated
78
-
-
-
-
-
78
262 586
-
55 721
(3)
-
(5 866)
312 438
Due from customers
Financial corporations
Very Low
994 490
-
-
(114)
-
-
994 376
Low
254 535
-
-
(93)
-
-
254 442
Lower–Intermediate
55 810
17
-
(204)
-
-
55 623
Intermediate
27 261
69
-
(70)
-
-
27 260
Upper–Intermediate
22
-
-
-
-
-
22
High
-
-
-
-
-
-
-
Default
-
-
18
-
-
(7)
11
Unrated
1 165
-
-
-
-
-
1 165
1 333 283
86
18
(481)
-
(7)
1 332 899
Non-financial corporations
Very Low
1 403 057
126 525
-
(618)
(170)
-
1 528 794
Low
1 658 920
419
-
(620)
-
-
1 658 719
Lower–Intermediate
1 286 794
351 756
-
(3 381)
(2 046)
-
1 633 123
Intermediate
303 882
135 601
-
(1 398)
(1 998)
-
436 087
Upper–Intermediate
215 367
398 682
-
(3 460)
(19 337)
-
591 252
High
793
90 135
-
(14)
(16 558)
-
74 356
Very high
-
-
-
-
-
-
-
Default
-
-
120 452
-
-
(56 610)
63 842
Unrated
1 767
27
-
-
-
-
1 794
4 870 580
1 103 145
120 452
(9 491)
(40 109)
(56 610)
5 987 967
Non-financial corporations –
specialised lending
Strong
156 818
2 509
-
(786)
(100)
-
158 441
Good
452 152
19 662
-
(4 081)
(667)
-
467 066
Satisfactory
69 646
27 504
-
(2 148)
(2 253)
-
92 749
Weak
6 973
40 838
-
(679)
(9 657)
-
37 475
Default
-
-
25 817
-
-
(12 567)
13 250
Unrated
-
-
-
-
-
-
-
685 589
90 513
25 817
(7 694)
(12 677)
(12 567)
768 981
Retail
Very Low
6 529 484
61 282
-
(887)
(1 323)
-
6 588 556
Low
1 573 227
33 355
-
(413)
(744)
-
1 605 425
Lower–Intermediate
2 151 716
190 985
-
(3 513)
(5 000)
-
2 334 188
Intermediate
237 602
164 779
-
(2 298)
(10 603)
-
389 480
Upper–Intermediate
92 607
159 434
-
(2 662)
(14 875)
-
234 504
High
14 391
121 386
-
(1 399)
(26 536)
-
107 842
Default
-
-
219 800
-
-
(128 614)
91 186
Unrated
36 932
558
-
(8)
-
-
37 482
10 635 959
731 779
219 800
(11 180)
(59 081)
(128 614)
11 388 663
(Table continues on the next page)
Separate Financial Statements
191
2024
Gross amount
Impairment losses/Provisions
Net amount
€ ’000
Stage 1
Stage 2
Stage 3
Stage 1
Stage 2
Stage 3
Financial assets at AC
Due from customers
Public administration
Very Low
36 606
2 196
-
(18)
(2)
-
38 782
Low
30 551
2 611
-
(14)
(9)
-
33 139
Lower–Intermediate
-
-
-
-
-
-
-
Intermediate
8 015
2 248
-
(6)
(9)
-
10 248
Upper–Intermediate
83 525
9 872
-
(231)
(401)
-
92 765
High
245
901
-
(9)
(77)
-
1 060
Default
-
-
-
-
-
-
-
Unrated
804 135
147
-
(673)
(8)
-
803 601
963 077
17 975
-
(951)
(506)
-
979 595
Total due from customers
18 488 488
1 943 498
366 087
(29 797)
(112 373)
(197 798)
20 458 105
Total financial assets at AC
18 751 074
1 943 498
421 808
(29 800)
(112 373)
(203 664)
20 770 543
Financial assets at FVOCI
– debt securities
Unrated
1 476 701
-
-
(212)
-
-
1 476 489
Loan commitments
and financial guarantees
Due from banks
Very Low
11 954
-
-
(1)
-
-
11 953
Low
-
-
-
-
-
-
-
Lower–Intermediate
209 532
-
-
(5)
-
-
209 527
Intermediate
1 129
-
-
-
-
-
1 129
Upper–Intermediate
-
-
-
-
-
-
-
High
-
-
-
-
-
-
-
Default
-
-
-
-
-
-
-
Unrated
1 612
10
-
-
-
-
1 622
224 227
10
-
(6)
-
-
224 231
Due from customers
Financial corporations
Very Low
64 545
24 391
-
(2)
(27)
-
88 907
Low
39 875
-
-
1
-
-
39 876
Lower–Intermediate
8 728
1
-
(2)
-
-
8 727
Intermediate
24 269
5
-
(11)
-
-
24 263
Upper–Intermediate
-
-
-
-
-
-
-
High
-
-
-
-
-
-
-
Default
-
-
-
-
-
-
-
Unrated
-
-
-
-
-
-
-
137 417
24 397
-
(14)
(27)
-
161 773
Non-financial corporations
Very Low
1 517 600
296 533
-
(174)
(2 664)
-
1 811 295
Low
1 344 403
56 344
-
(220)
(35)
-
1 400 492
Lower–Intermediate
585 227
170 673
-
(573)
(3 236)
-
752 091
Intermediate
156 934
108 164
-
(462)
(2 002)
-
262 634
Upper–Intermediate
33 330
102 399
-
(249)
(5 844)
-
129 636
High
9
7 492
-
-
(216)
-
7 285
Very high
-
-
-
-
-
-
-
Default
-
-
14 251
-
-
(4 327)
9 924
Unrated
2 046
400
-
(2)
-
-
2 444
3 639 549
742 005
14 251
(1 680)
(13 997)
(4 327)
4 375 801
(Table continues on the next page)
Separate Financial Statements
192
2024
Gross amount
Provisions
Net amount
€ ’000
Stage 1
Stage 2
Stage 3
Stage 1
Stage 2
Stage 3
Loan commitments
and financial guarantees
Due from customers
Non-financial corporations –
specialised lending
Strong
25 493
12
-
(92)
-
-
25 413
Good
123 886
23 609
-
(904)
(375)
-
146 216
Satisfactory
4 100
2 091
-
(107)
(116)
-
5 968
Weak
-
-
-
-
-
-
-
Default
-
-
-
-
-
-
-
Unrated
-
-
-
-
-
-
-
153 479
25 712
-
(1 103)
(491)
-
177 597
Retail
Very Low
220 363
6 805
-
(21)
(69)
-
227 078
Low
76 139
3 345
-
(13)
(21)
-
79 450
Lower–Intermediate
184 930
52 962
-
(105)
(244)
-
237 543
Intermediate
29 969
3 504
-
(119)
(186)
-
33 168
Upper–Intermediate
6 392
4 946
-
(84)
(439)
-
10 815
High
1 893
504
-
(78)
(74)
-
2 245
Default
-
-
3 283
-
-
(12)
3 271
Unrated
238
-
-
(7)
-
-
231
519 924
72 066
3 283
(427)
(1 033)
(12)
593 801
Public administration
Very Low
5 162
20 048
-
-
-
-
25 210
Low
32 625
-
-
(6)
-
-
32 619
Lower–Intermediate
-
-
-
-
-
-
-
Intermediate
2 373
-
-
(1)
-
-
2 372
Upper–Intermediate
3 629
129
-
(9)
-
-
3 749
High
-
20
-
-
-
-
20
Default
-
-
-
-
-
-
-
Unrated
62 346
-
-
(37)
-
-
62 309
106 135
20 197
-
(53)
-
-
126 279
Total due from customers
4 556 504
884 377
17 534
(3 277)
(15 548)
(4 339)
5 435 251
Total financial assets at AC
4 780 731
884 387
17 534
(3 283)
(15 548)
(4 339)
5 659 482
For some portfolios, information from external credit reference agencies is also used. The credit quality for ﬁnancial
assets at amortized cost due from banks is in the rating scale from Aa1 to Ba3 (31 December 2024: Aaa to B1). Two
banking counterparties did not have an external credit rating assigned as of the reporting date.
The following table sets out the credit quality of FVOCI debt securities. The analysis is based on Moody‘s ratings.
€ ’000
2025
2024
Financial assets at FVOCI – debt securities
Aaa
222 151
562 291
Aa1
34 298
8 065
Aa2
-
31 446
Aa3
346 667
20 938
A3
530 422
106 309
Baa2
285 771
101 294
Baa3
-
646 358
Gross amount
1 419 309
1 476 701
Impairment losses
(270)
(212)
Net amount
1 419 039
1 476 489
Separate Financial Statements
193
4.1.10.
Sensitivity analysis of impairment losses
In the tables below the Bank shows the sensitivity of ECL calculation to a decrease or increase of PD parameter
by 10%:
Basic
scenario
Decrease PD by 10%
Increase PD by 10%
2025
€ ’000
Impairment
losses (note
11.1, 11.2)
Impairment
losses
Absolute
change
Relative
change
Impairment
losses
Absolute
change
Relative
change
Financial assets at AC
Due from banks
6 711
6 711
-
-
6 711
-
-
Due from customers
Financial corporations
Loans
3 013
3 083
70
2.32%
2 943
(70)
(2.32)%
Overdrafts
2
3
1
50.00%
2
-
-
Factoring
5
5
-
-
5
-
-
Debt securities
123
136
13
10.57%
111
(12)
(9.76)%
3 143
3 227
84
2.67%
3 061
(82)
(2.61)%
Non-financial corporations
Loans
96 291
101 678
5 387
5.59%
90 903
(5 388)
(5.60)%
Mortgages
216
218
2
0.93%
213
(3)
(1.39)%
Overdrafts
40 602
41 682
1 080
2.66%
39 522
(1 080)
(2.66)%
Credit cards
362
375
13
3.59%
349
(13)
(3.59)%
Factoring
1 431
1 525
94
6.57%
1 338
(93)
(6.50)%
Debt securities
843
927
84
9.96%
759
(84)
(9.96)%
Other
7 003
7 314
311
4.44%
6 693
(310)
(4.43)%
146 748
153 719
6 971
4.75%
139 777
(6 971)
(4.75)%
Retail
Loans
136 083
139 017
2 934
2.16%
133 149
(2 934)
(2.16)%
Mortgages
65 064
67 754
2 690
4.13%
62 374
(2 690)
(4.13)%
Overdrafts
4 139
4 213
74
1.79%
4 065
(74)
(1.79)%
Credit cards
1 927
2 011
84
4.36%
1 844
(83)
(4.31)%
Other
511
522
11
2.15%
501
(10)
(1.96)%
207 724
213 517
5 793
2.79%
201 933
(5 791)
(2.79)%
Public administration
Loans
1 498
1 648
150
10.01%
1 349
(149)
(9.95)%
Overdrafts
3
3
-
-
3
-
-
Debt securities
263
290
27
10.27%
237
(26)
(9.89)%
Other
1
1
-
-
-
(1)
(100.00)%
1 765
1 942
177
10.03%
1 589
(176)
(9.97)%
Total due from customers
359 380
372 405
13 025
3.62%
346 360
(13 020)
(3.62)%
Total financial assets at AC
366 091
379 116
13 025
3.56%
353 071
(13 020)
(3.56)%
Financial assets at FVOCI –
debt securities
270
297
27
10.00%
243
(27)
(10.00)%
Separate Financial Statements
194
Basic
scenario
Decrease PD by 10%
Increase PD by 10%
2024
€ ’000
Impairment
losses (note
11.1, 11.2)
Impairment
losses
Absolute
change
Relative
change
Impairment
losses
Absolute
change
Relative
change
Financial assets at AC
Due from banks
5 869
5 869
-
-
5 870
1
0.02%
Due from customers
Financial corporations
Loans
392
354
(38)
(9.69)%
431
39
9.95%
Overdrafts
-
-
-
-
-
-
-
Factoring
-
-
-
-
-
-
-
Debt securities
96
86
(10)
(10.42)%
105
9
9.38%
488
440
(48)
(20.11)%
536
48
9.84%
Non-financial corporations
Loans
102 961
96 732
(6 229)
(6.05)%
109 189
6 228
6.05%
Mortgages
203
199
(4)
(1.97)%
207
4
1.97%
Overdrafts
28 645
28 196
(449)
(1.57)%
29 095
450
1.57%
Credit cards
198
191
(7)
(3.54)%
204
6
3.03%
Factoring
1 315
1 205
(110)
(8.37)%
1 426
111
8.44%
Debt securities
165
149
(16)
(9.70)%
182
17
10.30%
Other
5 661
5 479
(182)
(3.21)%
5 842
181
3.20%
139 148
132 151
(6 997)
(5.03)%
146 145
6 997
5.03%
Retail
Loans
118 807
115 193
(3 614)
(3.04)%
122 421
3 614
3.04%
Mortgages
73 185
69 905
(3 280)
(4.48)%
76 464
3 279
4.48%
Overdrafts
4 279
4 223
(56)
(1.31)%
4 334
55
1.29%
Credit cards
2 065
2 001
(64)
(3.10)%
2 129
64
3.10%
Other
539
526
(13)
(2.41)%
552
13
2.41%
198 875
191 848
(7 027)
(3.53)%
205 900
7 025
3.53%
Public administration
Loans
1 351
1 216
(135)
(9.99)%
1 486
135
9.99%
Overdrafts
2
2
-
-
2
-
-
Debt securities
94
84
(10)
(10.64)%
104
10
10.64%
Other
10
9
(1)
(10.00)%
11
1
10.00%
1 457
1 311
(146)
(10.02)%
1 603
146
10.02%
Total due from customers
339 968
325 750
(14 218)
(4.18)%
354 184
14 216
4.18%
Total financial assets at AC
345 837
331 619
(14 218)
(4.11)%
360 054
14 217
4.11%
Financial assets at FVOCI –
debt securities
212
191
(21)
(9.91)%
233
21
9.91%
Separate Financial Statements
195
4.1.11.
Impact of the possible scenarios on the impairment losses and provisions
The behavior of the macroeconomic model is described by two possible scenarios, which simulate a worsening of
the macroeconomic situation. These scenarios resulted in the increase of expected loss. The simulation was run on
the VUB Group level on the whole Retail segment – mortgages, consumer loans, credit cards, overdrafts,
car
purchase ﬁnancing and former CFH products (Quatro, Slovenská požičovňa, HRL).
For the purposes of the simulation, the bank formulates three scenarios:
–
BASE – the scenario without stressing macroeconomic inputs. The predictions of the macroeconomic variables
are input into the macroeconomic model without any adjustments. Please note that the provisioning values for
December 2025 are not aligned with the ﬁgures used in BASE scenario, as managerial overlay amounts
–
ordinarily included in the year-end totals – were removed solely for the purpose of this analysis;
–
STRESS 10% – the predictions of the macroeconomic variables entering the macroeconomic model are stressed
by 10%;
–
STRESS 30% – the predictions of the macroeconomic variables entering the macroeconomic model are stressed
by 30%.
The expected loss for BASE scenario is at the level of EUR 175 925 ths and the proportion of assets in Stage 2 is at
the level of 6.07%. If the predictions of the macroeconomic variables entering the macroeconomic model are
stressed by 10%, the expected loss would increase to EUR 175 953 ths and the proportion of assets in Stage 2
would stay at the level of 6.07% (negligible increase is not visible due to rounding). A more severe scenario (STRESS
30%) would increase the expected loss to EUR 176 055 ths and the proportion of assets in Stage 2 would increase
to 6.08%.
Scenarios and their impact:
2025
2024
€ ’000
BASE
STRESS 10 %
STRESS 30 %
BASE
STRESS 10 %
STRESS 30 %
Gross exposure
Retail
12 429 757
12 429 757
12 429 757
11 778
469
11 778 469
11 778 469
Expected loss
Retail
175 925
175 953
176 055
178 008
178 592
180 089
Proportion of assets in Stage 2
(in terms of gross exposure)
Retail
6.07%
6.07%
6.08%
5.67%
5.71%
5.89%
4.1.12.
Credit risk of financial derivatives
Credit exposure (or the replacement cost) of derivative ﬁnancial instruments represents the Bank’s credit exposure
from contracts with a positive fair value. This indicates the estimated maximum potential loss in the event that
counterparties fail to
fulﬁl
their obligations. It is usually a small proportion of the notional amounts of the contracts.
The credit exposure of each contract is indicated by the credit equivalent, calculated in accordance with the generally
applicable methodology using the current exposure method. It involves the market value of the contract (only if
positive; otherwise, zero value is taken into account) and a portion of the nominal value,
reﬂecting
the potential
change in market value over the term of the contract. The credit equivalent is established depending on the type of
contract and its maturity. The Bank assesses the credit risk of all ﬁnancial instruments on a daily basis.
With regard to IFRS 13 which contains a clariﬁcation in reference to non
-performance risk in determining the fair
value of over-the-counter derivatives, the Bank uses the bilateral Credit Value Adjustment model (‘bCVA’). It takes
into account the effects of changes in counterparty credit ratings as well as the changes in own credit rating. The
bCVA has two addends, calculated by considering the possibility that both counterparties go bankrupt, known as
the Credit Value Adjustment (‘CVA’) and Debit Value Adjustment (‘DVA’):
–
The CVA (negative) takes into account scenarios whereby the counterparty fails before the Bank that has a
positive exposure to the counterparty. In these scenarios, the Bank suffers a loss equal to the cost of
replacing/closing the derivative contract,
–
The DVA (positive) takes into account scenarios whereby the Bank fails before the counterparty and has a
negative exposure to the counterparty. In these scenarios the Bank achieves a gain equal to the cost of
replacing/closing the derivative contract.
Separate Financial Statements
196
The bCVA depends on the exposure, probability of default and the loss given default of the counterparties. The Bank
is selective in its choice of counterparties and sets limits for transactions with customers. The Bank takes its own as
well as its counterparties’ credit risk into consideration to the extent it believes the market participants would do so.
4.2.
Market risk
Market risk refers to the
potential impact of ﬂuctuations
in market prices – such as interest rates, stock prices, and
exchange rates on the Bank's returns
or the value of its ﬁnancial instruments. The objective of market risk
management is to manage and control market risk exposures within acceptable parameters, while optimizing the
return on risk.
4.2.1.
Management of market risk
The Bank categorizes its exposures to market risk into trading (‘trading book’) and non-trading portfolios (‘banking
book’). Trading portfolios are held by the Trading sub-department while the Sales sub-department include positions
arising from market-making and proprietary position taking. All foreign exchange risk within the Bank is transferred
each day to the Trading sub-department and forms part of the trading portfolio for risk management purposes. The
non-trading portfolios are managed by the sub-department Asset Liability Management (‘ALM‘), and include all
positions which are not intended for trading.
Trading portfolios include derivative ﬁnancial instruments used for both trading and hedging and debt securities
classiﬁed as ﬁnancial asse
ts held for trading. Financial instruments with non-trading purpose are part of the banking
book.
Overall authority for market risk is vested in ALCO. The Risk Management Department is responsible for the
development of detailed risk management policies and for their implementation and day-to-day market risk
monitoring and reporting.
In the normal course of business, the Bank enters into derivative ﬁnancial instrument transactions to hedge its
liquidity, foreign exchange and interest rate risks. The Bank also enters into proprietary derivative ﬁnancial
transactions for the purpose of
generating proﬁts from short
-
term ﬂuctuations in market prices. The Bank operates
a system of market risk and counterparty limits, as these are designed to restrict exposure to movements in market
prices and counterparty concentrations. The Bank also monitors adherence to these limits on a daily basis.
4.2.2.
Exposure to market risk – trading portfolios
The principal tool used to measure and control market risk exposures within the Bank’s trading portfolio is Value at
Risk (‘VaR’). A derivation of VaR is the stress VaR (‘sVaR’), which represents maximal VaR of a selected one-year
period generating the highest value of VaR during a period of at least the last ten years. The VaR of a trading portfolio
is the estimated loss that will arise on the portfolio over a speciﬁed period of time (holding period) from an adverse
market mo
vement with a speciﬁed probability (conﬁdence level). The VaR model used by the Bank is based upon a
99% conﬁdence level and assumes a one
-day holding period.
The VaR and sVaR models used are based on historical simulations. Taking into account market data from the
previous year and in case of sVaR a one-year scenario from at least the last ten years of history and observed
relationships between different markets and prices, the models generate a wide range of plausible future scenarios
for market price movements evaluated in the model. The VaR model was approved by the NBS as a basis for the
calculation of the capital charge for market risk of the trading book.
The Bank uses VaR limits for total market risk in the trading book, foreign exchange risk and interest rate risk. The
overall structure of VaR and sVaR limits is subject to review and approval by ALCO and Intesa Sanpaolo. VaR is
measured on a daily basis. Daily reports of utilisation of VaR and sVaR limits are submitted to the trading unit, the
head of the Division Risk Management and the head of the Department Treasury and ALM. Regular summaries are
submitted to Intesa Sanpaolo and ALCO.
A summary of the VaR and sVaR position of the Bank’s trading portfolios:
2025
2024
€ ‘000
Balance
Avg
Max
Min
Balance
Avg
Max
Min
Foreign currency risk
36
36
98
8
56
58
140
13
Interest rate risk
70
166
358
70
113
200
419
61
Total VaR
75
172
385
70
114
222
458
64
Total sVaR
1 053
1 394
2 292
956
1 240
1 259
1 698
236
Separate Financial Statements
197
4.2.3.
Exposure to interest rate risk in the banking book (IRRBB)
Interest rate risk comprises of the risk that the value of a ﬁnancial instrument will ﬂuctuate due to changes in market
interest rates and the risk that the maturities of interest-earning assets differ from the maturities of interest-bearing
liabilities
used to fund those assets. The length of time for which the interest rate is ﬁxed for a ﬁnancial instrument
therefore indicates the extent to which it is exposed to interest rate risk.
The main risk to which non-
trading portfolios are exposed is the risk of loss from ﬂuctuations in the future cash
ﬂows
and
fair values of ﬁnancial instruments due to a change in market interest rates. Interest rate risk in the banking
book is managed mainly through the monitoring of interest rate gaps. Financial instruments are mapped to repricing
time buckets either by matur
ity for ﬁxed
-
rate instruments, or by next repricing date for ﬂoating rate instruments.
Assets and liabilities that do not have a contractual maturity date are mapped according to internal models based
on behavioural assumptions.
The Risk Management Department is responsible for monitoring and reporting of interest rate gaps at least on
monthly basis. Interest rate risk in the banking book is measured using the shift sensitivity of fair value (change in
present value) and in terms of net interest income sensitivity. These metrics are utilized for baseline, internal stress
and regulatory scenarios.
Baseline scenarios for the shift sensitivity of fair value are deﬁned as the parallel and instantaneous shift of +/
-100
basis points of the yield curve and four non-parallel shifts of the yield curve. Internal stress scenarios measure the
shift sensitivity of fair value through the parallel and instantaneous shift of +/-200 basis points. Six regulatory
scenarios include parallel up, parallel down, steepening, ﬂattening, short rates up ad short rates down scenarios. For
the net interest income sensitivity, the baseline scenario is represented by parallel and instantaneous +/-50 basis
points shock in the yield curve, in a period of the following 12 months. Internal stress scenarios include +/-100 bps,
+/-200 basis points shocks and six regulatory scenarios, mentioned above, are applied as well.
Overall interest rate risk positions in the banking book are managed by the Treasury and ALM Department which
uses different on balance and off-balance sheet instruments to manage the positions arising from the banking book
activities.
Models applied for the interest rate risk in the banking book
calculation
Each ﬁnancial instrument is allocated to the time bucket based on its contractual or behavioural repricing date.
Contractual
This category includes instruments for which the Bank knows exactly when the maturity or next repricing takes place.
This treatment is applied mainly to purchased and issued securities, received loans and term deposits.
Behavioural
These are items for which it is not exactly known when the maturity or next repricing will take place (e.g. current
accounts). There are also items where the maturity or repricing period is known but it can be assumed that they will
behave differently (e.g. prepayments can occur for mortgages and consumer loans). In this case, it is necessary to
make certain assumptions to reﬂect the behavioural characteristics of such items. The
assumptions are based on the
detailed analysis of the Bank’s historical time series data and statistical models.
At 31 December 2025
, the interest margin sensitivity of the banking book on proﬁt or loss in a one
-year time frame,
in the event of a 100 basis points rise in interest rates, was EUR 27 520 thousand (31 December 2024:
EUR 30 446 thousand).
At 31 December 2025
, the interest margin sensitivity of the banking book on proﬁt or loss in a one
-year time frame,
in the event of a 100 basis points decline in interest rates, was EUR (31 940) thousand (31 December 2024:
EUR (35 139) thousand).
At 31 December 2025, the interest rate risk generated by the banking book, measured through shift sensitivity
analysis of plus 100 basis points, reached the value of EUR (34 678) thousand (31 December 2024:
EUR (24 744) thousand).
At 31 December 2025, the interest rate risk generated by the banking book, measured through shift sensitivity
analysis of minus 100 basis points, reached the value of EUR 32 051 thousand (31 December 2024:
EUR 22 299 thousand).
At 31 December 2025, the sensitivity of the FVOCI reserve in equity related to the non-hedged part of the portfolio
to 100 basis points rise in interest rates was EUR (322) thousand (31 December 2024: EUR (331) thousand).
Separate Financial Statements
198
4.2.4.
Currency denominations of assets and liabilities
Foreign exchange rate risk comprises the risk that the value of ﬁnancial assets and ﬁnancial liabilities will ﬂuctuate
due to changes in foreign exchange rates. It is the policy of the Bank to manage its exposure to ﬂuctuations in
exchange rates through regular monitoring and reporting of open foreign exchange positions and the application
of a matrix of position exposure in single currencies and overall position limit.
4.3.
Liquidity risk
Liquidity risk is deﬁned as the risk that the
Bank will not be able to meet its payment obligations due to its inability
to obtain funds on the market (funding liquidity risk) or liquidate its assets (market liquidity risk). Normally, the Bank
can cover cash outﬂows with cash inﬂows, high
-quality liquid assets and its ability to obtain credit.
The Liquidity Risk Management Policy adopted by the Bank outlines the tasks and responsibilities of the various
corporate functions, and the control and management processes to ensure a prudent governance of liquidity risk,
preventing crisis situations.
The internal liquidity risk control and management system is based on the following principles.
–
The existence of an operating structure that works within set limits and early warning thresholds and of a control
structure that is independent from the operating structure.
–
A prudential approach in cash inﬂow and outﬂow projections for all the balance sheet and off
-balance sheet
items, especially those without a contractual maturity.
–
Impact assessment of different scenarios, including stress testing scenarios, on cash inﬂows and outﬂows over
time and on the adequacy of the liquidity reserve.
–
Constant availability of adequate liquidity reserves in relation to the chosen liquidity risk tolerance threshold.
The Bank regularly performs stress testing to evaluate the impact of adverse events on its liquidity position and on
the adequacy of liquidity reserves. The unencumbered high-quality liquid assets are maintained at levels to support
the liquidity position even in case of extraordinary events. The Bank can also obtain short-term funding from the
Parent Company or interbank market to maintain its liquidity position.
The Treasury and ALM Department is responsible for ensuring adherence to the Liquidity Risk Management Policy in
terms of liquidity risk management whereas the Risk Management Department is responsible for reporting and
monitoring of liquidity risk indicators. The Liquidity Risk Management Policy consists of three main areas – Short-
Term Liquidity Risk Management, Structural Liquidity Risk Management and Contingency Liquidity Plan that are
essential components of the Internal Liquidity Adequacy Assessment Process.
The Short-Term Liquidity Risk Management includes a set of parameters, limits and thresholds that enable the
measurement, both under normal and stressed market conditions, of liquidity risk exposure over the short-term
horizon. The main regulatory indicator in this area is the Liquidity Coverage Ratio that enables to monitor that the
Bank maintains an adequate stock of unencumbered high-quality liquid assets to cover its short-term net cash
outﬂows under stressed conditions lasting 30 calendar days.
The Structural Liquidity Risk Management of the Bank incorporates a set of measures and limits designed to control
and manage the risks deriving from the mismatch of the medium to long-term maturities of the assets and liabilities.
The main regulatory indicator used in this area is the Net Stable Funding Ratio (NSFR) that represents the ratio of the
available stable funding to the required stable funding.
The goal of the Contingency Liquidity Plan is to protect the Bank’s liquidity position, verifying compliance on an
ongoing basis with the risk tolerance, through the identiﬁcation and monitoring of the early warning signals and the
deﬁnition of strategies and intervention tools to be implemented in situations of liqui
dity stress.
The liquidity position of the Bank is presented by the Risk Management Department during the ALCO meetings on
monthly basis.
Separate Financial Statements
199
The table below shows an analysis of assets and liabilities (discounted cash ﬂow basis) according to when they are
expected to be recovered or settled:
2025
2024
€ ’000
Less than
12 months
Over
12 months
Total
Less than
12 months
Over
12 months
Total
Assets
Cash and cash
equivalents
2 144 599
-
2 144 599
2 272 661
-
2 272 661
Financial assets at
FVTPL
34 652
131 137
165 789
16 134
175 581
191 715
Derivatives – Hedge
accounting
3 407
85 631
89 038
1 583
73 983
75 566
Financial assets at
FVOCI
32 829
1 386 497
1 419 326
124 097
1 352 617
1 476 714
Financial assets at
AC
Due from banks
340
212 735
213 075
264 064
48 374
312 438
Due from
customers
3 854 209
17 973 820
21 828 029
3 867 563
16 590 542
20 458 105
Fair value changes of
the hedged items in
portfolio hedge of
IRR
-
1 262
1 262
-
775
775
Investments in
subsidiaries, joint
ventures and
associates
-
26 980
26 980
-
28 314
28 314
Property and
equipment
-
105 988
105 988
-
113 844
113 844
Intangible assets
-
100 352
100 352
-
105 077
105 077
Goodwill
-
29 305
29 305
-
29 305
29 305
Current income tax
assets
5 894
-
5 894
-
-
-
Deferred income tax
assets
-
78 860
78 860
-
83 024
83 024
Other assets
44 798
-
44 798
49 192
-
49 192
6 120 728
20 132 567
26 253 295
6 595 294
18 601 436
25 196 730
Liabilities
Financial liabilities at
FVTPL
(6 737)
(47 496)
(54 233)
(13 239)
(65 104)
(78 343)
Derivatives – Hedge
accounting
(15 305)
(85 038)
(100 343)
(14 782)
(158 500)
(173 282)
Financial liabilities
measured at AC
Due to banks
(46 101)
(1 108 107)
(1 154 208)
(58 709)
(772 659)
(831 368)
Due to customers
(2 150 144)
(15 917 308)
(18 067 452)
(2 205 582)
(14 940 890)
(17 146 472)
Lease liabilities
(6 502)
(15 645)
(22 147)
(6 443)
(15 603)
(22 046)
Subordinated debt
(200 386)
(100 000)
(300 386)
(401)
(300 000)
(300 401)
Debt securities
in issue
(1 036 776)
(2 970 446)
(4 007 222)
(751 420)
(3 452 563)
(4 203 983)
Fair value changes of
the hedged items in
portfolio hedge of
IRR
-
5 770
5 770
-
8 193
8 193
Current income tax
liabilities
-
-
-
(43 773)
-
(43 773)
Provisions
-
(27 282)
(27 282)
-
(30 110)
(30 110)
Other liabilities
(123 635)
-
(123 635)
(131 461)
(4 413)
(135 874)
(3 585 586)
(20 265 552)
(23 851 138)
(3 225 810)
(19 731 649)
(22 957 459)
Net position
2 535 142
(132 985)
2 402 157
3 369 484
(1 130 213)
2 239 271
Separate Financial Statements
200
The remaining maturities of assets and liabilities based on contractual undiscounted cash-
ﬂows were as follows:
2025
€ ’000
Up to 3 months
3 months
to 1 year
1 to 5 years
Over 5 years
Not specified
Total
Financial assets
Cash and cash equivalents
2 144 684
-
-
-
2
2 144 686
Financial assets at FVTPL
(excl. Trading derivatives)
80
30 000
82 204
-
-
112 284
Financial assets at FVOCI
4 429
28 942
888 759
511 584
287
1 434 001
Financial assets at AC
Due from banks
-
-
-
194 947
-
194 947
Due from customers
2 403 761
1 388 819
6 135 854
9 410 191
83 535
19 422 160
4 552 954
1 447 761
7 106 817
10 116 722
83 824
23 308 078
Financial liabilities
Financial liabilities at AC
Due to banks
(24 246)
(350)
(302 271)
(750 000)
-
(1 076 867)
Due to customers
(16 738 985)
(1 286 064)
(166 846)
(25 143)
(169)
(18 217 207)
Lease liabilities
(1 246)
(5 323)
(14 640)
(2 125)
-
(23 334)
Subordinated debt
(364)
(200 000)
-
(50 000)
-
(250 364)
Debt securities in issue
(467 965)
(525 132)
(1 995 279)
(1 058 419)
-
(4 046 795)
(17 232 806)
(2 016 869)
(2 479 036)
(1 885 687)
(169)
(23 614 567)
Net position of financial
instruments*
(12 679 852)
(569 108)
4 627 781
8 231 035
83 655
(306 489)
Cash inflows from derivatives
405 695
123 244
77 770
-
-
606 709
Cash outflows from derivatives
(405 942)
(123 026)
(78 163)
-
-
(607 131)
Net position from
derivatives
(247)
218
(393)
-
-
(422)
Net position from loan
commitments and financial
guarantees
(5 830 124)
-
-
-
-
(5 830 124)
* The high negative liquidity gap in the ﬁrst bucket is caused by a huge volume of deposits on demand (without contractual m
aturity) which are
presented under ‘Due to customers’. For the purpose of internal liquidity management monitoring the behavioural
proﬁle of on
-demand deposits
is taken into account based on a statistical model using internal historical data. According to when they are expected to be settled such deposits
are then placed into later buckets (see the previous table).
Separate Financial Statements
201
2024
€ ’000
Up to 3 months
3 months
to 1 year
1 to 5 years
Over 5 years
Not specified
Total
Financial assets
Cash and cash equivalents
2 272 740
-
-
-
-
2 272 740
Financial assets at FVTPL
(excl. Trading derivatives)
6 947
-
106 670
22 190
3 378
139 185
Financial assets at FVOCI
17 090
132 608
733 058
776 914
225
1 659 895
Financial assets at AC
Due from banks
215 896
50 301
-
49 030
-
315 227
Due from customers
2 422 110
2 032 592
8 080 494
11 882 354
75 391
24 492 941
4 934 783
2 215 501
8 920 222
12 730 488
78 994
28 879 988
Financial liabilities
Financial liabilities at AC
Due to banks
(61 952)
(11 826)
(572 376)
(222 887)
-
(869 041)
Due to customers
(15 817 910)
(1 316 380)
(181 369)
(16 305)
(327)
(17 332 291)
Lease liabilities
(1 887)
(4 605)
(14 261)
(2 167)
-
(22 920)
Subordinated debt
(4 267)
(13 843)
(220 674)
(53 403)
-
(292 187)
Debt securities in issue
11 972
(786 459)
(3 076 264)
(720 173)
-
(4 570 924)
(15 874 044)
(2 133 113)
(4 064 944)
(1 014 935)
(327)
(23 087 363)
Net position of financial
instruments*
(10 939 261)
82 388
4 855 278
11 715 553
78 667
5 792 625
Cash inflows from derivatives
400 008
158 379
127 891
-
-
686 278
Cash outflows from derivatives
(401 170)
(157 327)
(127 584)
-
-
(686 081)
Net position from derivatives
(1 162)
1 052
307
-
-
197
Net position from loan
commitments and financial
guarantees
(5 682 652)
-
-
-
-
(5 682 652)
* The high negative liquidity gap in the ﬁrst bucket is caused by a huge volume of deposits on demand (without contractual m
aturity) which are
presented under ‘Due to customers’. For the purpose of internal liquidity management monitoring the behavioural
proﬁle of on
-demand deposits
is taken into account based on a statistical model using internal historical data. According to when they are expected to be settled such deposits
are then placed into later buckets (see the previous table).
Separate Financial Statements
202
4.4.
Operational risk
Operational risk is the risk of loss resulting from inadequate or failed internal processes, people and systems or from
external events. Operational risk includes legal risk and compliance risk, model risk, information and communication
technology risk and
ﬁnancial reporting risk; strategic and reputational risk are not included. Operational risk can
arise from legal and regulatory requirements, non-compliance with generally accepted standards of corporate
behaviour and from all of the Bank’s operations.
4.4.1.
Operational risk management strategies and processes
The Bank, in coordination with Intesa Sanpaolo, has deﬁned the overall operational risk management framework by
setting up a VUB Group policy and organisational process for measuring, managing and controlling operational risk.
The control of operational risk was attributed to the Operational Risk Committee, which identiﬁes risk management
policies. The Supervisory and Management
Boards of the Bank ensures the functionality, efﬁciency and effectiveness
of the risk management and controls system.
The Operational Risk Committee (composed of the heads of the areas of the governance centre (Chief Executive
Ofﬁcer, Deputy Chief Executive Ofﬁcer) and of the business areas more involved in operational risk management
(voting members: CRO, CFO, COO, Head of Compliance and AML Department; permanent invitees without voting
rights: Head of Corporate & SME Division, Head of Retail Division, Head of Risk Management Department, Head of
Legal Department, Head of Human Resources & Organization Department, Head of Information Security sub-
department), has the task of periodically reviewing the VUB Group’s overall operational risk proﬁle, authorising any
corrective actions, coordinating and monitoring the effectiveness of the main mitigation activities and approving the
operational risk transfer strategies. The Bank, in coordination with its parent company, uses a traditional tool for
transferring operational risk through insurance contracts (bank insurance), with the main objective being to mitigate
the impact of unexpected operational losses arising from the risks covered by this insurance.
4.4.2.
Organisational structure of the associated risk management function
For some time, the Bank has had a centralised function within the Risk Management Division for the management
of the Bank’s operational risks. This function is responsible, in coordination with the Parent Company, for the
deﬁnition, implementation and mon
itoring of the methodological and organisational framework, as well as for the
measurement of the risk proﬁle, the veriﬁcation of mitigation effectiveness and reporting to senior Management. In
compliance with current requirements, the individual organisational units participate in the process and each of them
is responsible for the identiﬁcation, assessment, management and mitigation of its operational risks. Speciﬁc ofﬁces
and departments have been identiﬁed within these organisational units to be r
esponsible for Operational Risk
Management. These functions are responsible for the collection and structured census of information relating to
operational events, scenario analyses and evaluation of the level of risk associated with the business environment,
including information and communication technology risk. The Risk Management Division carries out second-level
monitoring of these activities.
4.4.3.
Scope of application and characteristics of the risk measurement and reporting system
Based on the implementation of Basel IV (‘CRR 3‘) effective from 1 January 2025, the Bank began using a new
standardized approach to operational risk, known as the Business Indicator Component (BIC) approach, to calculate
its own funds requirements for operational risk (‘standardized approach based on the business indicator component
BIC‘). At the same time, all previously used approaches, including internal models, have been eliminated.
Operational risks are monitored using an integrated reporting system that provides management with the
information necessary to manage and/or mitigate operational risk. In addition to the management system required
by regulatory requirements, the Bank
has an operational risk management system in place, which is certiﬁed annually
as part of a self-assessment process. The results of this process are submitted to the Operational Risk Committee for
annual veriﬁcation.
Separate Financial Statements
203
5.
Estimated fair value of financial assets and financial liabilities
See accounting policy in note 3.4.7.
The Bank uses the following fair value hierarchy that categorizes into three levels the inputs to valuation techniques
used to measure fair value:
Level 1:inputs represented by quoted prices (unadjusted) in active markets for identical assets or liabilities accessible
by the Bank as at the measurement date;
Level 2:inputs other than quoted prices included in Level 1 that are directly or indirectly observable for the assets or
liabilities to be measured; and
Level 3:Inputs unobservable for the asset or liability.
The highest priority is given to effective market quotes (Level 1) for the valuation of assets and liabilities or for similar
assets and liabilities measured using valuation techniques based on market-observable parameters other than
ﬁnancial instruments quotes (
Level 2) and the lowest priority to unobservable inputs (Level 3). Following this
hierarchy, where available, fair value estimates made by the Bank are based on quoted market prices. However, no
readily available market prices exist for a signiﬁcant portion of the Bank’s ﬁnancial instruments. In circumstances
where the quoted market prices are not readily available, fair value is estimated using discounted cash ﬂow models
or other pricing models as appropriate.
Under Level 2, the principal valuation technique used by the Bank for debt instruments involves the method of
discounting future cash ﬂows. The calculation takes into account the time value of money (risk
-free rate of interest)
and the credit risk expressed in the form of credit spreads applied to the bonds’ yield and representing the risk
premium the investor claims against a risk-
free investment. In the case of derivative ﬁnancial instruments
, the Bank
uses standard fair value calculation models based on the principal net present value using the yield curve to discount
all future cash ﬂows from derivatives for all relevant currencies. The principal input parameters used by the models
comprise interest rate curves, volatility curves, spot and forward prices and the correlation between underlying assets.
Changes in underlying assumptions, including discount rates and estimated future cash ﬂows, signiﬁcantly affect
the estimates. The Bank also considers its own and counterparty’s credit risk.
The valuation technique deﬁned for a ﬁnancial instrument is adopted over time and is modiﬁed only following
signiﬁcant changes in market conditions or the subjective conditions related to the issuer of the ﬁnancial instrument.
The Bank monitors the oc
currence of these changes and accordingly reassesses the classiﬁcation into the fair value
hierarchy. For determining the timing of the transfers between the levels, the Bank uses the end of the reporting
period as the day when the transfer is deemed to have occurred.
In estimating the fair value of the Bank’s ﬁnancial instruments, the following methods and assumptions were used:
Cash and cash equivalents
The carrying values of cash and cash equivalents are deemed to approximate their fair value.
Due from banks
The fair value of due from banks balances with maturities more than one year is estimated using discounted cash
ﬂow analyses, based upon
relevant discount
curve. For maturities up to one year and not signiﬁcant balances, the
carrying amounts of amounts due from banks approximates their fair value. Impairment losses are taken into
consideration when calculating fair values.
Purchased debt securities
The carrying values of cash and cash equivalents are deemed to approximate their fair value.
Due to banks
The carrying amounts of due to banks approximates their fair value. The fair value of due to banks is estimated by
discounting their future expected cash ﬂows using
relevant discount interest rate curve.
Debt securities in issue
The fair value of debt securities issued by the Bank is based on quoted market prices. Where no market prices are
available, the fair value was calculated by discounting future cash ﬂows using the risk
-free interest rate curve adjusted
by credit spreads reﬂecting the credit quality of VUB as the issuer.
Separate Financial Statements
204
Carrying amount
Fair value
2025
€ ’000
Note
At amortised
cost
At fair
value
Total
carrying
amount
Level 1
Level 2
Level 3
Total
fair value
Financial assets
Cash and cash equivalents
7
2 144 599
-
2 144 599
-
2 144 446
-
2 144 446
Financial assets at FVTPL
8
-
165 789
165 789
114 169
51 620
-
165 789
Derivatives – Hedge
accounting
9
-
89 038
89 038
-
89 038
-
89 038
Financial assets at FVOCI
10
-
1 419 326
1 419 326
1 419 148
178
-
1 419 326
Financial assets at AC
11
Due from banks
213 075
-
213 075
-
212 249
-
212 249
Due from customers
21 828 029
-
21 828 029
1 677 807
764 371
21 247 108
23 689 286
24 185 703
1 674 153
25 859 856
3 211 124
3 261 902
21 247 108
27 720 134
Financial liabilities
Financial liabilities at FVTPL
8
-
54 233
54 233
-
54 233
-
54 233
Derivatives – Hedge
accounting
9
-
100 343
100 343
-
100 343
-
100 343
Financial liabilities at AC
11
Due to banks
1 154 208
-
1 154 208
-
1 159 692
-
1 159 692
Due to customers
18 067 452
-
18 067 452
-
18 062 566
-
18 062 566
Lease liabilities
22 147
-
22 147
-
22 147
-
22 147
Subordinated debt
300 386
-
300 386
-
310 655
-
310 655
Debt securities in issue
4 007 222
-
4 007 222
-
4 074 558
-
4 074 558
23 551 415
154 576
23 705 991
-
23 784 194
-
23 784 194
Carrying amount
Fair value
2024
€ ’000
Note
At amortised
cost
At fair
value
Total
carrying
amount
Level 1
Level 2
Level 3
Total
fair value
Financial assets
Cash and cash equivalents
7
2 272 661
-
2 272 661
-
2 272 377
-
2 272 377
Financial assets at FVTPL
8
-
191 715
191 715
122 784
68 931
-
191 715
Derivatives – Hedge
accounting
9
-
75 566
75 566
-
75 566
-
75 566
Financial assets at FVOCI
10
-
1 476 714
1 476 714
1 476 561
153
-
1 476 714
Financial assets at AC
11
Due from banks
312 438
-
312 438
-
311 699
-
311 699
Due from customers
20 458 105
-
20 458 105
777 210
618 820
20 824 774
22 220 804
23 043 204
1 743 995
24 787 199
2 376 555
3 347 546
20 824 774
26 548 875
Financial liabilities
Financial liabilities at FVTPL
8
-
78 343
78 343
-
78 343
-
78 343
Derivatives – Hedge
accounting
9
-
173 282
173 282
-
173 282
-
173 282
Financial liabilities at AC
11
Due to banks
831 368
-
831 368
-
825 127
-
825 127
Due to customers
17 146 472
-
17 146 472
-
17 138 535
-
17 138 535
Lease liabilities
22 046
-
22 046
-
22 046
-
22 046
Subordinated debt
300 401
-
300 401
-
323 560
-
323 560
Debt securities in issue
4 203 983
-
4 203 983
-
4 244 278
-
4 244 278
22 504 270
251 625
22 755 895
-
22 805 171
-
22 805 171
There were no other transfers of ﬁnancial instrume
nts among the levels during 2025 and 2024.
Separate Financial Statements
205
6.
Segment reporting
The Bank reports ﬁnancial and descriptive information about its operating segments in the ﬁnancial statements. An
operating segment is a component of the Bank that engages in business activities from which it may earn revenues
and incur expenses (including revenues and expenses relating to transactions with other components of the Bank),
whose operating results are regularly reviewed by the Bank’s management to make decisions about resources to be
allocated to the segment and to assess its performance, an
d for which separate ﬁnancial information is available.
The Bank operates in three operating segments – Retail Banking, Corporate Banking and Central Treasury. Each
segment is exposed to different risks and differs in the nature of its services, business processes and types of
customers for its products and services.
For all segments the Bank reports a measure of segment assets and liabilities and income and expense items, a
reconciliation of total reportable segment revenues, total proﬁt or loss, total assets, liabilities and other amounts
disclosed for reportable se
gments to corresponding amounts in the ﬁnancial statements.
Most of the transactions of the Bank are related to the Slovak market. However, the Group operates also on the
Czech market via a foreign subsidiary in Prague performing activities especially in corporate banking and Central
Treasury.
Operating segments pay and receive interest to and from the Central Treasury on an arm’s length basis in order to
reﬂect the costs of funding.
Retail Banking includes loans, deposits and other transactions and balances with households, sole traders and small
business segment.
Corporate Banking comprises SME, the Corporate Customer Desk (‘CCD’), Municipalities and Public Sector Entities.
SME includes complex loan structures, deposits and other transactions and balances with SME (company revenue
up to EUR 50 million; if revenue information is not available, bank account turnover is used). The CCD includes
complex loan structures, deposits and other transactions and balances with large corporate customers (company
revenue over EUR 50 million).
Central Treasury undertakes the Bank’s funding, issues of debt securities as well as trading book.
The Bank reported within Other a Central Governance Centre that manages the Bank’s premises, equity investments
and own equity funds as well as Risk Management that operates the workout loan portfolio. Unclassiﬁed items are
also reported within this column.
Separate Financial Statements
206
2025
€ ’000
Retail
banking
Corporate
banking
Central
Treasury
Total reportable
segments
Other
Total
External revenue
Interest and similar income
475 380
321 431
136 290
933 101
5 503
938 604
Interest and similar expense
(56 447)
(120 691)
(155 942)
(333 080)
(17 489)
(350 569)
Inter-segment revenue
(111 151)
(45 945)
108 500
(48 596)
48 596
-
Net interest income
307 782
154 795
88 848
551 425
36 610
588 035
Net fee and commission income
(note 25)
161 379
44 998
1 262
207 639
(3 771)
203 868
Dividend income
-
-
-
-
-
-
Net trading result
6 165
7 949
10 633
24 747
-
24 747
Other operating income
-
-
-
-
1 847
1 847
Other operating expense
(12 281)
(2 261)
-
(14 542)
(5 788)
(20 330)
Salaries and employee benefit
(65 763)
(14 730)
(898)
(81 391)
(80 971)
(162 362)
Other administrative expenses*
-
-
-
-
(95 658)
(95 658)
Amortisation
(4 425)
(335)
(14)
(4 774)
(19 233)
(24 007)
Depreciation
(1 845)
(27)
-
(1 872)
(9 364)
(11 236)
Profit before provisions,
impairment and tax
391 012
190 389
99 831
681 232
(176 328)
504 904
Net modification gain/(loss)
(20 000)
-
-
(20 000)
56
(19 944)
Provisions*
-
-
-
-
55
55
Impairment losses
and provisions
for loan commitments
and financial guarantees
(46 274)
(14 580)
(901)
(61 755)
(1 333)
(63 088)
Net gain
/(loss) arising
from the derecognition
of financial assets
at amortised cost
1 348
5 902
-
7 250
(2)
7 248
Profit before tax
326 086
181 711
98 930
606 727
(177 552)
429 175
Segment assets
12 362 100
7 887 262
5 370 613
25 619 975
633 320
26 253 295
Segment liabilities
11 242 709
7 276 603
4 964 743
23 484 055
367 083
23 851 138
* The Bank does not allocate these items to individual segments.
2024
€ ’000
Retail
banking
Corporate
banking
Central
Treasury
Total reportable
segments
Other
Total
External revenue
Interest and similar income
390 335
378 785
246 316
1 015 436
113
1 015 549
Interest and similar expense
(60 261)
(182 503)
(177 182)
(419 946)
(21 939)
(441 885)
Inter-segment revenue
30 257
(25 826)
(78 790)
(74 359)
74 359
-
Net interest income
360 331
170 456
(9 656)
521 131
52 533
573 664
Net fee and commission income
(note 25)
137 516
40 385
962
178 863
(1 865)
176 998
Dividend income
-
-
-
-
3 318
3 318
Net trading result
6 233
7 987
3 411
17 631
-
17 631
Other operating income
-
-
-
-
2 134
2 134
Other operating expense
(10 296)
(1 423)
-
(11 719)
(5 584)
(17 303)
Salaries and employee benefit
(63 217)
(13 253)
(850)
(77 320)
(82 752)
(160 072)
Other administrative expenses*
-
-
-
-
(91 597)
(91 597)
Amortisation
(9 492)
(1 114)
(10)
(10 616)
(20 034)
(30 650)
Depreciation
(2 142)
(81)
(3)
(2 226)
(9 538)
(11 764)
Profit before provisions,
impairment and tax
418 933
202 957
(6 146)
615 744
(153 385)
462 359
Net modification gain/(loss)
-
-
-
-
158
158
Provisions*
-
-
-
-
(67)
(67)
Impairment losses
and provisions
for loan commitments
and financial guarantees
(21 350)
(15 524)
(700)
(37 574)
(2 127)
(39 701)
Net gain/(loss) arising
from the derecognition
of financial assets
at amortised cost
693
(589)
-
104
(51)
53
Profit before tax
398 276
186 844
(6 846)
578 274
(155 472)
422 802
Segment assets
11 777 023
8 027 330
4 754 345
24 558 698
638 032
25 196 730
Segment liabilities
10 740 460
7 423 716
4 347 123
22 511 299
446 160
22 957 459
* The Bank does not allocate these items to individual segments
Separate Financial Statements
207
7.
Cash and cash equivalents
‘Cash and cash equivalents’ comprise the following balances:
€ ’000
2025
2024
Cash in hand
287 605
257 319
Balances at central banks
Compulsory minimum reserves
163 204
154 506
Term deposits with maturity up to 90 days
831 407
841 791
Loans and advances
with contractual maturity up to 90 days
825 233
990 078
Impairment losses
(8)
(10)
1 819 836
1 986 365
Due from other banks
Current accounts
37 158
28 977
Total cash and cash equivalents
2 144 599
2 272 661
8.
Financial assets and financial liabilities at fair value through profit or loss
€ ’000
2025
2024
Financial assets held for trading
Trading derivatives
50 612
66 101
Government debt securities of European Union countries
113 636
122 204
164 248
188 305
Non-trading financial assets
at fair value through profit or loss
Equity instruments
1 541
3 410
Financial liabilities held for trading
Trading derivatives
54 233
78 343
Equity instruments classiﬁed as ‘Non
-
trading ﬁnancial assets at fair value through proﬁt or loss‘ comprise shares of
Intesa Sanpaolo S.p.A. in the amount of EUR 533 thousand (31 December 2024: EUR 580 thousand) and form part
of the Group’s incentive plan introduced by the Parent Company in line with the applicable EU capital remuneration
rules (CRD V and, from 2026, CRD VI). The Bank did not elect the option to present these instruments at ‘Financial
assets at fair value through other comprehensive income‘.
Separate Financial Statements
208
2025
2024
€ ’000
Assets
Liabilities
Assets
Liabilities
Trading derivatives – Fair values
Interest rate instruments
Forwards and swaps
45 417
45 285
55 656
59 461
Options
52
50
127
118
45 469
45 335
55 783
59 579
Foreign currency instruments
Forwards and swaps
3 763
4 318
9 271
9 298
Options
571
574
1 044
1 061
4 334
4 892
10 315
10 359
Equity and commodity instruments
Equity options
456
3 659
-
8 402
Commodity forwards and swaps
353
347
3
3
809
4 006
3
8 405
Total trading derivatives – fair values
50 612
54 233
66 101
78 343
2025
2024
€ ’000
Assets
Liabilities
Assets
Liabilities
Trading derivatives – Notional values
Interest rate instruments
Forwards and swaps
2 020 453
2 020 453
3 580 043
3 580 043
Options
292 080
292 080
209 281
209 281
2 312 533
2 312 533
3 789 324
3 789 324
Foreign currency instruments
Forwards and swaps
468 485
469 191
589 378
588 697
Options
80 634
80 634
67 543
67 543
549 119
549 825
656 921
656 240
Equity and commodity instruments
Equity options
718
38 747
-
38 029
Commodity forwards and swaps
3 840
3 840
296
296
4 558
42 587
296
38 325
Total trading derivatives – notional values
2 866 210
2 904 945
4 446 541
4 483 889
9.
Derivatives – Hedge accounting
2025
2024
€ ’000
Assets
Liabilities
Assets
Liabilities
Cash flow hedges of interest rate risk
-
557
-
216
Fair value hedges of interest rate,
foreign currency and inflation risk
89 038
99 786
75 566
173 066
89 038
100 343
75 566
173 282
9.1.
Cash ﬂow hedge related to
foreign currency risk
At 31 December 2025 the Bank used three currency forwards to hedge the currency risk of an expected future
transaction when transferring the economic result of branch Prague in the amount of
CZK
527 439 thousand
(31 December 2024:
CZK
541 886 thousand). The maturity of this hedging instrument is 14 January 2026. Due to
the nature of the business, hedging inefﬁciency is not expected.
Assets
Liabilities
Assets
Liabilities
2025
€ ’000
Fair value
Fair value
Notional value
Notional value
Change in
fair value used
for calculating
hedge
ineffectiveness
Ineffectiveness
recognised in
profit or loss
Micro hedges
Foreign currency instruments
Forwards and swaps
Cash flow hedge
in foreign currency
-
557
21 200
21 762
(594)
-
Separate Financial Statements
209
Assets
Liabilities
Assets
Liabilities
2024
€ ’000
Fair value
Fair value
Notional value
Notional value
Change in
fair value used
for calculating
hedge
ineffectiveness
Ineffectiveness
recognised in
profit or loss
Micro hedges
Foreign currency instruments
Forwards and swaps
Cash flow hedge
in foreign currency
-
216
21 300
21 516
-
-
9.2.
Fair value hedges related to
interest rate, foreign currency and inﬂation risk
as of date of preparation of the
ﬁnancial statements
Assets
Liabilities
Assets
Liabilities
2025
€ ’000
Fair value
Fair value
Notional value
Notional value
Change in
fair value used
for calculating
hedge
ineffectiveness
Ineffectiveness
recognised in
profit or loss
Micro hedges
Interest rate instruments
Forwards and swaps
Hedge of debt securities
at FVOCI
40 899
34 247
1 596 011
1 596 011
(2 133)
-
Hedge of corporate loans
-
2 006
143 707
143 707
(3 363)
34
Hedge of loans received
from other banks
-
1 203
50 000
50 000
1 252
16
Hedge of covered bonds
10 791
15 984
3 718 094
3 718 094
(3 301)
-
Hedge of debt securities at AC
20 656
6 428
1 681 670
1 681 670
43 800
-
Foreign currency instruments
Forwards and swaps
Hedge of corporate loans
7 998
-
166 070
157 277
(1 056)
-
Hedge of debt securities at AC
7 801
9 781
438 384
436 974
1 431
-
Macro hedges
Interest rate instruments
Forwards and swaps
Hedge of mortgage loans
880
29 102
2 083 000
2 083 000
13 228
329
Hedge of debt securities at AC
-
-
-
-
-
-
Hedge of current accounts
13
1 035
111 000
111 000
1 098
(98)
Separate Financial Statements
210
Assets
Liabilities
Assets
Liabilities
2024
€ ’000
Fair value
Fair value
Notional value
Notional value
Change in
fair value used
for calculating
hedge
ineffectiveness
Ineffectiveness
recognised in
profit or loss
Micro hedges
Interest rate instruments
Forwards and swaps
Hedge of debt securities
at FVOCI
49 745
37 729
1 645 800
1 645 800
(29 418)
-
Hedge of corporate loans
5 008
2 051
303 604
303 604
(5 631)
4
Hedge of loans received
from other banks
-
2 587
50 000
50 000
1 661
15
Hedge of covered bonds
20 493
49 944
3 594 900
3 594 900
36 874
-
Hedge of debt securities at AC
320
21 561
787 600
787 600
(13 154)
1
Foreign currency instruments
Forwards and swaps
Hedge of corporate loans
-
9 379
166 248
176 765
(1 362)
-
Hedge of debt securities at AC
-
15 391
297 248
308 215
(629)
(7)
Macro hedges
Interest rate instruments
Forwards and swaps
Hedge of mortgage loans
-
32 004
964 000
964 000
(21 475)
(427)
Hedge of debt securities at AC
-
-
-
-
-
-
Hedge of current accounts
-
2 420
112 500
112 500
3 189
(2)
Separate Financial Statements
211
The amounts relating to items designated as hedged items were as follows:
2025
€ ’000
Line item in SOFP
Carrying
amount
Accumulated
amount of fair
value
adjustments
included in
carrying amount
Change in fair
value
used for
calculating
hedge
ineffectiveness
Fair value
adjustment
after
termination of
hedging
relationship
Micro hedges
Financial assets at FVOCI
Debt securities at FVOCI
1 336 364
-
2 133
144
Financial assets at AC
Loans and advances
from other banks
Due from banks
-
-
-
-
Corporate loans
Due from customers
309 778
2
4 453
(240)
Debt securities at AC
Due from customers
2 194 013
(23 716)
(45 231)
-
Financial liabilities at AC
Loans received
from other banks
Due to banks
50 000
(887)
1 236
-
Covered bonds*
Debt securities in issue
3 696 372
(16 796)
(3 301)
(47 887)
Macro hedges
Financial assets at AC
Mortgage loans
Due from customers
2 083 000
4 504
(12 899)
(3 242)
Financial liabilities at AC
Current accounts
Due to customers
111 000
(1 387)
1 196
(4 383)
* Interest rate risk hedging of covered bonds is sometimes closed before the original maturity of the interest rate swap. The reason is that the
Interest rate risk position of the Bank changed in a way which required more ﬁxed
-rate liabilities. S
ince the originally ﬁxed
-rate covered bonds
that
were in the past swapped into ﬂoat rate, these swaps were terminated
early in order to achieve the required interest risk position of the
Bank.
2024
€ ’000
Line item in SOFP
Carrying
amount
Accumulated
amount of fair
value
adjustments
included in
carrying amount
Change in fair
value
used for
calculating
hedge
ineffectiveness
Fair value
adjustment
after
termination of
hedging
relationship
Micro hedges
Financial assets at FVOCI
Debt securities at FVOCI
1 351 153
-
29 418
155
Financial assets at AC
Loans and advances
from other banks
Due from banks
-
-
-
71
Corporate loans
Due from customers
480 369
(10 787)
6 997
(287)
Debt securities at AC
Due from customers
1 095 369
21 837
13 777
-
Financial liabilities at AC
Loans received
from other banks
Due to banks
50 000
(2 123)
1 646
-
Covered bonds*
Debt securities in issue
3 364 009
(75 660)
36 874
-
Macro hedges
Financial assets at AC
Mortgage loans
Due from customers
964 000
17 944
21 048
(17 169)
Financial liabilities at AC
Current accounts
Due to customers
112 500
(2 582)
3 191
(5 611)
* Interest rate risk hedging of covered bonds is sometimes closed before the original maturity of the interest rate swap. The reason is that the
Interest rate risk position of the Bank changed in a way which required more ﬁxed
-rate liabilities. S
ince the originally ﬁxed
-rate covered bonds
that
were in the past swapped into ﬂoat rate, these swaps were terminated
early in order to achieve the required interest risk position of the
Bank.
Separate Financial Statements
212
Maturity of notional values of hedging instruments designated as fair value hedges and their average interest rates:
2025
2024
€ ’000
Less
than 1 year
1 to 5 years
More
than 5 years
Less
than 1 year
1 to 5 years
More
than 5 years
Interest rate instruments
Forwards and swaps
Hedge of debt securities
at FVOCI
20 630
1 059 681
515 700
8 000
647 500
734 300
3.29%
1.62%
2.29%
(0.47)%
0.79%
1.82%
Hedge of corporate loans
47 448
96 259
-
71 471
232 133
-
3.66%
3.16%
-
3.71%
2.61%
-
Hedge of debt securities
at AC
31 770
50 000
1 599 900
-
50 000
737 600
0.98%
2.16%
2.61%
-
2.16%
2.67%
Hedge of mortgage loans
-
2 083 000
-
-
964 000
-
-
2.59%
-
-
2.71%
-
Hedge of loans received
from other banks
50 000
-
-
-
50 000
-
(0.26)%
-
-
-
(0.26)%
-
Hedge of current accounts
49 500
31 500
30 000
27 000
85 500
-
0.64%
0.72%
2.32%
0,56%
0.68%
-
Hedge of covered bonds
1 600 000
1 065 000
1 053 094
2 160 000
600 000
634 900
0.87%
1.41%
1.89%
2.98%
(0.28)%
1.06%
Foreign currency instruments
Forwards and swaps
Hedge of corporate loans
-
166 070
-
95 140
81 625
-
-
3.85%
-
-
-
-
Hedge of debt securities
at AC
76 456
361 928
-
44 211
264 005
-
5.60%
4.78%
-
2.63%
-
-
10.
Financial assets at fair value through other comprehensive income
€ ’000
2025
2024
Government debt securities of European Union countries
1 304 164
1 086 730
of which Italian government debt securities
164 140
101 279
Bank debt securities
114 875
389 759
Equity instruments
Intesa Sanpaolo S.p.A.
109
72
S.W.I.F.T.
178
153
Total equity instruments
287
225
Total financial assets at fair value through other
comprehensive income
1 419 326
1 476 714
At 31 December 2025, the debt securities in the total nominal amount of EUR 60 000 thousand were pledged by
the Bank to secure collateralized transactions (31 December 2024: EUR 592 100 thousand). These debt securities
were pledged in favour of the ECB within the pool of assets which can be immediately used as collateral for received
funds needed for liquidity management purposes.
Separate Financial Statements
213
11.
Financial assets and financial liabilities at amortized cost
11.1.
Due from banks
€ ’000
Note
2025
2024
Loans and advances
with contractual maturity over 90 days
to central banks
86
78
to other banks
37 289
108 092
37 375
108 170
Cash collateral
182 411
210 137
Impairment losses
21
(6 711)
(5 869)
213 075
312 438
11.2.
Due from customers
2025
2024
€ ’000
Gross
amount
Impairment
losses
(note 21)
Carrying
amount
Gross
amount
Impairment
losses
(note 21)
Carrying
amount
Financial corporations
Loans
923 545
(3 013)
920 532
938 521
(392)
938 129
Overdrafts
46
(2)
44
55
-
55
Credit cards
24
-
24
18
-
18
Factoring
10 082
(5)
10 077
-
-
-
Debt securities
207 695
(123)
207 572
393 568
(96)
393 472
Other
-
-
-
1 165
-
1 165
Leasing
31
-
31
60
-
60
1 141 423
(3 143)
1 138 280
1 333 387
(488)
1 332 899
Non-financial corporations
Loans
5 146 668
(96 291)
5 050 377
5 436 735
(102 961)
5 333 774
Mortgages
5 397
(216)
5 181
7 645
(203)
7 442
Overdrafts
939 015
(40 602)
898 413
898 495
(28 645)
869 850
Credit cards
5 551
(362)
5 189
2 385
(198)
2 187
Factoring
127 890
(1 431)
126 459
129 888
(1 315)
128 573
Debt securities
558 984
(843)
558 141
229 856
(165)
229 691
Other
-
-
-
-
-
-
Leasing
142 437
(7 003)
135 434
191 092
(5 661)
185 431
6 925 942
(146 748)
6 779 194
6 896 096
(139 148)
6 756 948
Retail
Loans
1 552 489
(136 083)
1 416 406
1 507 892
(118 807)
1 389 085
Mortgages
10 399 712
(65 064)
10 334 648
9 898 719
(73 185)
9 825 534
Overdrafts
74 596
(4 139)
70 457
75 747
(4 279)
71 468
Credit cards
94 477
(1 927)
92 550
94 722
(2 065)
92 657
Factoring
1
-
1
47
-
47
Other
-
-
-
-
-
-
Leasing
6 179
(511)
5 668
10 411
(539)
9 872
12 127 454
(207 724)
11 919 730
11 587 538
(198 875)
11 388 663
Public administration
Loans
342 269
(1 498)
340 771
197 656
(1 351)
196 305
Overdrafts
2 501
(3)
2 498
1 085
(2)
1 083
Credit cards
33
-
33
26
-
26
Factoring
-
-
-
-
-
-
Debt securities
1 646 957
(263)
1 646 694
781 068
(94)
780 974
Other
-
-
-
-
-
-
Leasing
830
(1)
829
1 217
(10)
1 207
1 992 590
(1 765)
1 990 825
981 052
(1 457)
979 595
Total due from customers
22 187 409
(359 380)
21 828 029
20 798 073
(339 968)
20 458 105
Separate Financial Statements
214
At 31 December 2025, the 20 largest corporate customers represented a total carrying amount of EUR 1 473
838 thousand (31 December 2024: EUR 1 535 973 thousand), respectively 6.75% (31 December 2024: 7.51%) of
the total loan portfolio.
At 31 December 2025, the debt securities in the total nominal amount of EUR 598 900 thousand were pledged by
the Bank to secure collateralized transactions (31 December 2024: EUR 169 300 thousand). These debt securities
were pledged in favour of the ECB within the pool of assets which can be immediately used as collateral for received
funds needed for liquidity management purposes.
The following table sets out a maturity analysis of lease receivables, showing the undiscounted lease payments to
be received after the reporting date.
€ ’000
2025
2024
Up to one year
61 721
77 643
One to two years
41 720
56 178
Two to three years
27 283
39 030
Three to four years
15 216
23 763
Four to five years
8 199
12 220
Over five years
6 839
10 442
160 978
219 276
Unearned future finance income on finance leases
(11 532)
(16 496)
Impairment losses
(7 515)
(6 210)
141 931
196 570
11.3.
Due to banks
€ ’000
2025
2024
Due to central banks
Current accounts
812
874
Due to other banks
Current accounts
15 963
51 764
Term deposits
6 627
6 941
Loans received from other banks
1 107 896
773 234
Revaluation of fair value hedged loans received
(887)
(2 123)
Cash collateral received
23 772
660
Other deposits
25
18
1 153 396
830 494
Total due to banks
1 154 208
831 368
‘Loans received from other banks‘ are classiﬁed in full as long
-
term, with contractual maturities exceeding ﬁve years.
One loan, with a nominal value of EUR 50 000 thousand, is due in 2026.
The breakdown of ‘Loans received from other banks’ according to the counterparty is presented below:
€ ’000
2025
2024
Intesa Sanpaolo S.p.A.
951 083
651 199
European Investment Bank
156 813
121 080
European Bank for Reconstruction and Development
-
955
1 107 896
773 234
Separate Financial Statements
215
11.4.
Due to customers
€ ’000
2025
2024
Current accounts
10 696 139
10 171 799
Term deposits
6 545 698
6 144 503
Government and municipal deposits
639 721
626 051
Savings accounts
80 481
95 038
Other deposits
105 413
109 081
18 067 452
17 146 472
11.5.
Subordinated debt
The balance of the subordinated debt as of 31 December 2025 consisted of two loans from INTESA SANPAOLO SPA
with a total nominal value of EUR 100 000 thousand with maturities in 2033 and 2032 and interest rates of 5.298%
and 5.542% (31 December 2024: 6.289% and 5.995%) and one loan from Intesa Sanpaolo Holding International
in the nominal value of EUR 200 000 thousand with maturity in 2026 and an interest rate of 5.320% (31 December
2024: 6.124%).
In accordance with the loan agreement, the loan may be used as an unsecured liability to pay the bank's debts and
may not be repaid before all claims of the bank's unsubordinated creditors have been paid.
11.6.
Debt securities in issue
€ ’000
2025
2024
Covered bonds
1 274 833
915 634
Covered bonds subject to fair value hedges
2 797 073
3 364 009
4 071 906
4 279 643
Revaluation of fair value hedged covered bonds
(16 796)
(26 877)
Unamortized part of revaluation related to terminated
fair value hedges
(47 888)
(48 783)
4 007 222
4 203 983
The repayment of covered bonds is funded by the mortgage loans denominated in EUR provided to customers of
the Bank (note 11.2.) and debt securities in FVOCI portfolio (note 10).
11.7.
Changes in ﬁnancial liabilities
The disclosure of changes arising from cash ﬂows and non
-
cash changes in liabilities arising from ﬁnancing activities:
2025
€ ’000
Loans received
from other banks
(including
revaluation
Lease liabilities
Subordinated
debt
Covered bonds
1 January
771 111
22 046
300 401
4 203 983
Cash flow
Proceeds
595 000
-
-
500 000
Repayments
(260 200)
(7 416)
-
(716 597)
Non-cash changes
Accruals
2 334
-
(15)
30 812
Revaluation
(1 236)
-
-
(10 976)
Other
-
7 517
-
-
31 December
1 107 009
22 147
300 386
4 007 222
Separate Financial Statements
216
2024
€ ’000
Loans received
from other banks
(including
revaluation
Lease liabilities
Subordinated
debt
Covered bonds
1 January
780 595
18 577
300 487
4 436 314
Cash flow
Proceeds
100 000
-
-
500 000
Repayments
(107 304)
(7 957)
-
(788 000)
Non-cash changes
Accruals
57
-
(86)
10 054
Revaluation
(1 646)
-
-
45 615
Other
-
11 426
-
-
31 December
771 111
22 046
300 401
4 203 983
12.
Fair value changes of the hedged items in portfolio hedge of interest rate risk
€ ’000
2025
2024
Financial assets at AC
Due from customers
Retail
Mortgages
1 262
775
Financial liabilities at AC
Due to customers
(5 770)
(8 193)
13.
Investments in subsidiaries, joint ventures and associates
2025
€ ’000
Share
Cost
Impairment
losses
Carrying
amount
VUB Generali d. s. s., a.s. (‘VUB Generali‘)
55.26%
25 195
-
25 195
VUB Operating Leasing, a.s. (‘VUB Operating Leasing‘)
100.00%
3 500
(3 500)
-
Monilogi, s.r.o. (‘Monilogi‘)
33 00%
2 549
(767)
1 782
Slovak Banking Credit Bureau, s. r. o. (‘SBCB‘)
33.33%
3
-
3
31 247
(4 267)
26 980
2024
€ ’000
Share
Cost
Impairment
losses
Carrying
amount
VUB Generali d. s. s., a.s. (‘VUB Generali‘)
55.26%
25 195
-
25 195
VUB Operating Leasing, a.s. (‘VUB Operating Leasing‘)
100.00%
3 500
(2 166)
1 334
Monilogi, s.r.o. (‘Monilogi‘)
33.00%
2 549
(767)
1 782
Slovak Banking Credit Bureau, s. r. o. (‘SBCB‘)
33.33%
3
-
3
31 247
(2 933)
28 314
VUB Generali and VUB Operating Leasing are subsidiaries of the Bank incorporated in the Slovak Republic. Monilogi
is the joint venture of the Bank incorporated in the Slovak Republic. SBCB is the associate of the Bank incorporated
in the Slovak Republic.
14.
Property and equipment and non-current assets classified as held for sale
2025
2024
€ ’000
Owned
Right-of-use
Total
Owned
Right-of-use
Total
Buildings and land
68 569
17 683
86 252
71 535
18 651
90 186
Equipment
4 799
-
4 799
4 464
-
4 464
Other tangibles
1 484
4 087
5 571
1 099
3 045
4 144
Assets under construction
9 366
-
9 366
15 050
-
15 050
84 218
21 770
105 988
92 148
21 696
113 844
Separate Financial Statements
217
2025
€ ’000
Buildings
and land
Equipment
Other
tangibles
Assets under
construction
Total
Revaluation
At 1 January
123 843
31 732
23 313
15 050
193 938
Transfer to other assets
(9 039)
-
-
-
(9 039)
Additions
9 173
-
4 494
5 038
18 705
Disposals
(9 904)
(3 133)
(2 586)
-
(15 623)
Transfers
8 160
1 750
812
(10 722)
-
Exchange differences
44
4
1
-
49
At 31 December
122 277
30 353
26 034
9 366
188 030
Accumulated depreciation
At 1 January
(33 642)
(27 268)
(19 169)
-
(80 079)
Transfer to other assets
3 607
-
-
-
3 607
Depreciation for the year
(8 233)
(1 387)
(1 616)
-
(11 236)
Disposals
2 264
3 105
323
-
5 692
Exchange differences
(21)
(4)
(1)
-
(26)
At 31 December
(36 025)
(25 554)
(20 463)
-
(82 042)
Impairment losses (note 21)
At 1 January
(15)
-
-
-
(15)
Release
15
-
-
-
15
At 31 December
-
-
-
-
-
Carrying amount
At 1 January
90 186
4 464
4 144
15 050
113 844
At 31 December
86 252
4 799
5 571
9 366
105 988
2024
€ ’000
Buildings
and land
Equipment
Other
tangibles
Assets under
construction
Total
Revaluation
At 1 January
116 694
33 626
23 396
11 258
184 974
Transfer to other assets
-
-
-
-
-
Additions
9 687
-
1 783
5 701
17 171
Disposals
(4 011)
(2 256)
(1 919)
-
(8 186)
Transfers
1 492
364
53
(1 909)
-
Exchange differences
(19)
(2)
-
-
(21)
At 31 December
123 843
31 732
23 313
15 050
193 938
Accumulated depreciation
At 1 January
(26 197)
(28 332)
(19 658)
-
(74 187)
Transfer to other assets
-
-
-
-
-
Depreciation for the year
(9 157)
(1 192)
(1 415)
-
(11 764)
Disposals
1 707
2 254
1 904
-
5 865
Exchange differences
5
2
-
-
7
At 31 December
(33 642)
(27 268)
(19 169)
-
(80 079)
Impairment losses (note 21)
At 1 January
(94)
-
-
-
(94)
Release
79
-
-
-
79
At 31 December
(15)
-
-
-
(15)
Carrying amount
At 1 January
90 403
5 294
3 738
11 258
110 693
At 31 December
90 186
4 464
4 144
15 050
113 844
Separate Financial Statements
218
Of which right-of-use assets:
2025
2024
€ ’000
Buildings
and land
Other
tangibles
Total
Buildings
and land
Other
tangibles
Total
Cost
At 1 January
46 818
5 107
51 925
39 389
3 865
43 254
Additions
9 173
4 494
13 667
9 687
1 783
11 470
Disposals
(6 197)
(1 565)
(7 762)
(2 239)
(541)
(2 780)
Exchange differences
44
1
45
(19)
-
(19)
At 31 December
49 838
8 037
57 875
46 818
5 107
51 925
Accumulated depreciation
At 1 January
(28 167)
(2 062)
(30 229)
(23 528)
(1 504)
(25 032)
Depreciation for the year
(6 211)
(1 189)
(7 400)
(6 210)
(1 084)
(7 294)
Disposals
2 244
(698)
1 546
1 566
526
2 092
Exchange differences
(21)
(1)
(22)
5
-
5
At 31 December
(32 155)
(3 950)
(36 105)
(28 167)
(2 062)
(30 229)
Carrying amount
At 1 January
18 651
3 045
21 696
15 861
2 361
18 222
At 31 December
17 683
4 087
21 770
18 651
3 045
21 696
In 2025 the Bank reviewed the carrying amount of its property and equipment. An impairment test was carried out
to determine the recoverable amount. As a result of the impairment test, the Bank recognized release of impairment
loss in the amount of EUR 15 thousand (31 December 2024: release of impairment loss in amount of EUR 79
thousand).
If ‘Buildings and land’ were measured using the cost model, the carrying amounts would be, as follows:
€ ’000
2025
2024
Cost
101 679
96 829
Accumulated depreciation
(55 266)
(53 032)
Impairment losses
(15)
(15)
46 398
43 782
At 31 December 2025, the gross book value of fully depreciated tangible assets that are still used by the Bank
amounted to EUR 47 094 thousand (31 December 2024: EUR 49 434 thousand).
The Bank’s insurance program covers all standard risks to tangible and intangible assets (theft, robbery, natural
hazards, vandalism and other damages).
Separate Financial Statements
219
15.
Intangible assets
2025
€ ’000
Software
Other
intangible
assets
Assets under
development
Total
Cost
At 1 January
385 126
10 729
30 435
426 290
Additions
-
-
19 280
19 280
Transfers
13 392
-
(13 392)
-
Exchange differences
37
1
-
38
At 31 December
398 555
10 730
36 323
445 608
Accumulated amortisation
At 1 January
(310 700)
(10 513)
-
(321 213)
Depreciation for the year
(23 997)
(10)
-
(24 007)
Exchange differences
(35)
(1)
-
(36)
At 31 December
(334 732)
(10 524)
-
(345 256)
Impairment losses (note 21)
At 1 January
-
-
-
-
At 31 December
-
-
-
-
Carrying amount
At 1 January
74 426
216
30 435
105 077
At 31 December
63 823
206
36 323
100 352
2024
€ ’000
Software
Other
intangible
assets
Assets under
development
Total
Cost
At 1 January
357 983
10 730
34 035
402 748
Additions
-
-
23 561
23 561
Transfers
27 161
-
(27 161)
-
Exchange differences
(18)
(1)
-
(19)
At 31 December
385 126
10 729
30 435
426 290
Accumulated amortisation
At 1 January
(280 077)
(10 504)
-
(290 581)
Depreciation for the year
(30 640)
(10)
-
(30 650)
Exchange differences
17
1
-
18
At 31 December
(310 700)
(10 513)
-
(321 213)
Impairment losses (note 21)
At 1 January
-
-
-
-
At 31 December
-
-
-
-
Carrying amount
At 1 January
77 906
226
34 035
112 167
At 31 December
74 426
216
30 435
105 077
The assets under development mainly include the development of new software applications and the costs of
technical evaluation of software that have not yet been put into use.
At 31 December 2025, the gross book value of fully amortized intangible assets that are still used by the Bank
amounted to EUR 214 868 thousand (31 December 2024: EUR 204 761 thousand).
Separate Financial Statements
220
16.
Goodwill
€ ’000
2025
2024
Retail Banking
18 871
18 871
Corporate Banking
10 434
10 434
29 305
29 305
The Bank
has identiﬁed three cash
-generating units – Retail Banking, Corporate Banking and Central Treasury, which
also represent operating segments used in ‘Segment reporting’ (note 6).
Goodwill allocated to Retail Banking in the amount of EUR 18 871 thousand arose in 2005 on the acquisition of
Consumer Finance Holding, a.s. and was merged into the Bank in 2018.
Goodwill allocated to Corporate Banking related to the VUB Leasing, a.s. and includes both goodwill related to
purchase of the majority (70%) shareholding in the amount of EUR 7 304 thousand in 2007 and goodwill arising
from the purchase of the remaining 30% shareholding in the amount of EUR 3 130 thousand in 2010. This goodwill
was merged into the Bank in 2022.
No impairment losses were created during 2025 and 2024.
17.
Deferred income tax assets and liabilities
Deferred income taxes are calculated on all temporary differences using a tax rate of 24% (31 December 2024: 24%)
as follows:
2025
€ ’000
1 January
Profit/(loss)
Equity
Exchange rate
differences
31 December
Derivative financial instruments –
CF Hedge
52
-
82
-
134
Financial assets at FVOCI
6 022
-
(6 580)
-
(558)
Financial assets at AC
Due from banks
1 393
202
-
-
1 595
Due from customers
64 701
5 083
-
-
69 784
Property and equipment
(14 164)
(1 666)
-
-
(15 830)
Intangible assets
1 333
(1 067)
-
-
266
Other assets
7
1 784
-
-
1 791
Financial liabilities at AC
Lease liabilities
5 249
43
-
-
5 292
Provisions
5 359
(790)
-
-
4 569
Other liabilities
17 484
(189)
-
-
17 295
Other
(4 412)
(17)
(1 066)
17
(5 478)
83 024
3 383
(7 564)
17
78 860
2024
€ ’000
1 January
Profit/(loss)
Equity
Exchange rate
differences
31 December
Derivative financial instruments
–
CF Hedge
52
-
45
-
7
Financial assets at FVOCI
6 022
-
1 061
-
4 961
Financial assets at AC
Due from banks
1 393
321
-
-
1 072
Due from customers
64 701
1 582
-
-
63 119
Property and equipment
(14 164)
(1 614)
(655)
-
(11 895)
Intangible assets
1 333
(759)
-
-
2 092
Other assets
7
-
-
-
7
Financial liabilities at AC
Lease liabilities
5 249
1 367
-
-
3 882
Provisions
5 359
2 177
-
-
3 182
Other liabilities
17 484
4 290
-
-
13 194
Other
(4 412)
(1 636)
-
-
(2 776)
83 024
5 728
451
-
76 845
Separate Financial Statements
221
18.
Other assets
€ ’000
Note
2025
2024
Operating receivables and advances
26 807
34 342
Prepayments and accrued income
10 827
10 993
Leashold improvement
7 568
-
Settlement of operations with financial instruments
1 453
623
Other tax receivables
1 148
6 139
Inventories
427
519
Other
332
160
Impairment losses
21
(3 764)
(3 584)
44 798
49 192
19.
Provisions
€ ’000
Note
2025
2024
Provisions for loan commitments and financial
guarantees
21
19 997
23 170
Litigation
23.2
6 885
6 940
Restructuring provision
400
-
27 282
30 110
2025
€ ’000
Note
1 January
Net creation/
(release)
Use
Exchange
difference
31 December
Litigation
23.2
6 940
(53)
(2)
-
6 885
Restructuring provision
29
-
400
-
-
400
6 940
347
(2)
-
7 285
2024
€ ’000
Note
1 January
Net creation/
(release)
Use
Exchange
difference
31 December
Litigation
23.2
6 872
85
(18)
1
6 940
Restructuring provision
29
-
-
-
-
-
6 872
85
(18)
1
6 940
20.
Other liabilities
€ ’000
2025
2024
Various creditors
53 020
63 192
Settlement with employees
38 073
36 593
VAT payable and other tax payables
6 626
5 764
Severance and Jubilee benefits
4 862
4 413
Accruals and deferred income
4 039
7 377
Settlement of operations with financial instruments
2 492
2 490
Share remuneration scheme
533
580
Investment certificates
455
466
Other
13 535
14 999
123 635
135 874
At 31 December 2025 and 31 December 2024 there were no overdue balances within ‘Other liabilities’.
Separate Financial Statements
222
The movements in social fund liability presented within ‘Settlement with employees’ were as follows:
2025
€ ’000
1 January
Creation
(note 29)
Use
31 December
Social fund
810
2 735
(2 719)
826
2024
€ ’000
1 January
Creation
(note 29)
Use
31 December
Social fund
781
3 155
(3 126)
810
21.
Movements in impairment losses and provisions for loan commitments and
financial guarantees
2025
€ ’000
Note
1 January
Net creation/
(release)
Assets
Written off/
sold
Exchange
difference
Other
31 December
Financial assets at FVOCI
212
106
(48)
-
-
270
Financial assets at AC
11
Due from banks
5 869
839
-
3
-
6 711
Due from customers
339 968
65 499
(44 825)
(1 262)
-
359 380
Impairment losses according
to IFRS 9
346 049
66 444
(44 873)
(1 259)
-
366 361
Loan commitments and financial
guarantees
19
23 170
(4 642)
-
1 469
-
19 997
Impairment losses and provisions
according to IFRS 9
369 219
61 802
(44 873)
210
-
386 358
Investments in subsidiaries, joint
ventures and associates
2 933
1 334
-
-
-
4 267
Property and equipment and
non–
current assets classified as held for
sale
14
15
-
(15)
-
-
-
Other assets
18
-
-
-
-
-
-
Total impairment losses and
provisions for loan commitments and
financial guarantees
372 167
63 136
(44 888)
210
-
390 625
2024
€ ’000
Note
1 January
Net creation/
(release)
Assets
Written off/
sold
Exchange
difference
Other
31 December
Financial assets at FVOCI
232
(20)
-
-
-
212
Financial assets at AC
11
Due from banks
5 109
761
-
(1)
-
5 869
Due from customers
372 018
31 948
(62 117)
(1 881)
-
339 968
Impairment losses according
to IFRS 9
377 359
32 689
(62 117)
(1 882)
-
346 049
Loan commitments and financial
guarantees
19
16 888
4 884
-
1 398
-
23 170
Impairment losses and provisions
according to IFRS 9
394 247
37 573
(62 117)
(484)
-
369 219
Investments in subsidiaries, joint
ventures and associates
-
2 933
-
-
-
2 933
Property and equipment and non–
current assets classified as held for
sale
14
94
(79)
-
-
-
15
Other assets
18
3 807
(726)
-
503
-
3 584
Total impairment losses and
provisions for loan commitments and
financial guarantees
398 148
39 701
(62 117)
19
-
375 751
Separate Financial Statements
223
22.
Equity
€ ’000
2025
2024
Share capital – authorised, issued and fully paid
80 additional ordinary shares of EUR 1 million, not traded
80 000
80 000
89 ordinary shares of EUR 3 319 391.89 each, not traded
295 426
295 426
4 078 108 ordinary shares of EUR 33.20 each, not traded
135 393
135 393
510 819
510 819
Share premium
13 719
13 719
Reserves
127 291
107 111
Other capital funds
8 464
8 464
Retained earnings (excluding net profit for the year)
1 473 288
1 347 227
2 133 581
1 987 340
The registered share capital of the Bank amounts to EUR 510 819 063.81 and was created by the contribution of
the founder designated in the deed of foundation as of the day of its establishment.
The registered share capital is divided into 4 078 108 book-entered registered shares, each having the nominal value
of EUR 33,20, 89 book-entered registered shares, each having the nominal value of EUR 3 319 391.89 and 80 book-
entered registered shares, each having the nominal value of EUR 1 000 000.00.
In accordance with the law and Articles of Association of the Bank, the Bank is obliged to contribute at least 10%
of its annual net proﬁt to the ‘Legal reserve fund’ until it reaches 20% of the share capital. Usage of the ‘Legal
reserve fund’ is restricted by the law. The fund can be used for the coverage of the losses of the Bank.
€ ’000
2025
2024
Net profit for the year attributable to shareholders
268 576
251 931
22.1.
Regulatory capital management
The primary objectives of the Bank´s capital management are to ensure that the Bank complies with externally
imposed capital requirements and that the Bank maintains strong credit ratings and healthy capital ratios in order to
support its business and to maximise shareholders’ value.
The Bank manages its capital structure and adjusts it in the light of changes in economic conditions and the risk its
activities entail. In order to maintain or adjust the capital structure, the Bank may adjust the amount of dividend
payment to shareholders, return capital to shareholders, issue capital securities or other capital instruments, classiﬁed
as Additional Tier 1, or Tier2. No changes have been made in the objectives, policies and processes in the previous
year.
The Bank’s regulatory capital position was determined based on the rules for capital adequacy calculation set by the
CRR Regulation:
€ ’000
2025
2024
Tier 1 capital
Share capital
510 819
510 819
Share premium
13 719
13 719
Retained earnings*
1 473 288
1 347 227
Profit or loss eligible
80 573
125 966
Legal reserve fund
102 164
102 164
Other capital funds
8 464
8 464
Accumulated other comprehensive income
25 127
4 947
(
-) Value adjustments due to the requirements for prudent
valuation
(143)
(264)
Less goodwill and intangible assets
(105 031)
(95 955)
(-) Insufficient coverage for non-performing exposures
(4 594)
(2 449)
2 104 386
2 014 638
Tier 2 capital
IRB excess of provisions over expected losses eligible
44 507
42 850
Subordinated debt
139 094
179 305
183 600
222 155
Total regulatory capital
2 287 986
2 236 793
* Excluding net proﬁt for the period/year, in approval and other capital funds.
Separate Financial Statements
224
€ ’000
2025
2024
Retained earnings
1 741 864
1 599 158
Net profit for the year
(268 576)
(251 931)
1 473 288
1 347 227
2025
2024
€ ’000
Required
Required
Tier 1 capital
2 104 386
830 383
2 014 638
898 221
Tier 2 capital
183 600
183 600
222 154
222 154
Total regulatory capital
2 287 986
830 383
2 236 792
898 221
Total Risk Weighted Assets
10 379 785
10 379 785
11 227 768
11 227 768
CET 1 capital ratio
20.27%
12.09%
17.94%
12.09%
Total capital ratio
22.04%
16.25%
19.92%
16.25%
Regulatory capital consists of Tier 1 capital, which comprises share capital, share premium, retained earnings,
accumulated other comprehensive income, foreign currency translation and reserves. The deducted amounts in Tier
1 capital are goodwill, intangible assets
, prudential ﬁlters, insufﬁcient coverage for non
-performing exposures and
IRB shortfall, if negative. The other component of regulatory capital is Tier 2 capital, which includes subordinated
long-term debt and IRB excess of provisions over expected losses.
Own Funds, risk-weighted assets and the capital ratios as of 31 December
2025 were calculated in accordance with the
harmonised rules and regulations for banks and investment companies contained in Directive (EU) 2019/878 (‘CRD V’)
and in the CRR Regulation of 31 May 2024 (EU) 2024/1623, which transpose the banking supervision standard
s defined
by the Basel Committee (the Basel 3 Framework) to European Union laws.
Following the Supervisory Review and Evaluation Process (‘SREP’), the ECB annually makes a ﬁnal decision on the
capital requirement that the Bank must comply with on sub-consolidated and individual level. Starting from 1 January
2025
, the overall capital requirement the Bank has to meet in terms of Common Equity Tier 1 ratio is 11.09%. This
is the result:
–
The SREP requirement comprising a minimum Pillar 1 capital requirement of 4.5% and an additional Pillar 2
capital requirement of 0.84%, made up entirely of Common Equity Tier 1;
–
Additional requirements, made up entirely of Common Equity Tier 1, relating to a Capital Conservation Buffer
of 2.5%, an Other Systemically Important Institutions Buffer (‘O-SII Buffer’) of 1.75% and a Countercyclical
buffer (‘CCyB Buffer’) of 1.5%.
CRD V establishes the obligation for the designated national authorities to activate an operational framework for
the deﬁnition of the ratio of the countercyclical capital buffer (‘CCyB’). The ratio is subject to review on a quarterly
basis. Based on the analysis of the reference indicators, the National Bank of Slovakia decided to set the
countercyclical buffer (relating to the exposures towards Slovak counterparties).
Countercyclical buffer, which has been increased after COVID-19 pandemic period back to 1.5%, valid from 1
August 2023 back, remains effective. P2R composition based on CRD V rules is set to 75% Tier 1, out of which 75%
should represent CET 1 (56.25% of P2R). These changes represent from 1 August 2023 capital requirement (without
Pillar 2 Capital Guidance) for CET 1 of 11.09% and capital requirement for Tier 1 of 12.88%.
The Overall Capital Requirement was at VUB Group level, as of 31 December 202
5
set at 16.
25
% and consists of:
–
Capital requirement for Pillar 1 (8%),
–
Capital requirement for Pillar 2 (P2R 1.5% and Pillar 2 Capital Guidance 1%),
–
Capital requirement for a combined buffer (5.75%), consisting of Capital Conservation Buffer of 2.5%, Other
Systemically Important Institutions Buffer of 1.75% and a Countercyclical Buffer 1.5%.
ECB set the P2G to 1% since 1 January 2024, with no change in 2025. Therefore the Overall Capital Requirement
in force is 16.25% (13.88% for Tier 1 capital ratio and 12.09% for CET1 capital ratio, including the Pillar 2
Guidance).
Since November 2014, the Bank has been under the supervision of the European Central Bank.
Internally, within its Risk Appetite framework, the VUB Group has set internal limits for both OCR and CET1, managing
the regulatory capital requirements additionally with an internal management buffer.
Separate Financial Statements
225
The prudential treatment of software assets
The Bank has adopted prudential treatment of software assets based on the Final Report ’Draft Regulatory Technical
Standards on the prudential treatment of software assets under Article 36 of Regulation (EU) 575/2013 (CRR)
’,
EBA/RTS/2020/07, regarding an updated version of the Capital Requirements Regulation 2019/876 and Directive
2019/878 (CRR II/CRD V) published in June 2019 concerning the modiﬁed version of article 36(1)b (CRR II) with
regard to own funds requirements for institutions. The Bank has adopted the prudential amortization approach to
software assets for the calculation of CET1 at individual and consolidated level starting from December 2020 based
on EBA/RTS/ 2020/07 methodology, which is in line with ISP Group Approach. The prudential amortization allows
the banks not to deduct from CET1 software assets that are prudentially valued (i.e. when the value of software
assets is not negatively affected by status of resolution, insolvency or liquidation of the Bank). The residual portion
of the carrying amount of software is risk-weighted (100%), in accordance with the current CRR provisions. This
approach has also been established by Commission delegated Regulation (EU) 2020/2176 of 12 November 2020
amending Delegated Regulation (EU) 241/2014 as regards the deduction of software assets from Common Equity
Tier 1 items.
22.1.1.
Implementation of Basel IV
Basel IV implementation relevant for VUB is executed via update of EU Capital Requirements Regulation (‘CRR 3’).
The key changes in CRR 3 include:
–
Credit Risk: Introduction of a new standardized approach for credit risk (SA-CR), which includes changes to the
treatment of almost all exposures classes, with biggest changes probably for the exposures secured by
immovable property. Also, IRB approach includes some changes (notably decrease in the senior debt LGD).
–
Market Risk: A revised market risk framework to better capture the risks associated with trading activities.
–
Operational Risk: Implementation of a new standardized approach for operational risk, known as the Business
Indicator Component (BIC) approach, and removal of all internal models.
–
Credit Valuation Adjustment (CVA) Risk: Redeﬁnition of the CVA risk charge to better reﬂect the risk of
counterparty credit risk.
–
Output Floor: Introduction of an output ﬂoor to ensure that banks’ risk
-weighted assets (RWAs) calculated using
internal models do not fall below a certain percentage of RWAs calculated using standardized approaches.
–
Environmental, Social, and Governance (ESG) Risks: Integration of ESG risks into the regulatory framework,
requiring banks to manage and disclose their ESG risks.
–
Disclosures: Enhanced disclosure requirements to improve transparency and market discipline.
CRR 3 was published in the Ofﬁcial Journal of the European Union on June 19, 2024, and entered into force 20 days
later. The majority of the CRR 3 rules became applicable from 1 January 2025. However, Market Risk framework
changes have been postponed by two years by the Commission Delegated Regulation 2025/1496, and will be
applicable from 1 January 2027.
23.
Off-balance sheet items
23.1.
Issued guarantees and commitments and undrawn credit facilities
€ ’000
2025
2024
Issued guarantees
1 184 736
1 152 905
Commitments and undrawn credit facilities
4 645 388
4 529 747
of which revocable
1 403 946
1 441 389
5 830 124
5 682 652
Issued guarantees represent irrevocable assurances that the Bank will make payments in the event that a borrower
cannot meet its obligations to third parties. These assurances carry the same credit risk as loans and therefore the
Bank recognises provisions for these instruments (note 19).
The primary purpose of commitments to extend credit is to ensure that funds are available to the customer as
required. Commitments and undrawn credit facilities represent undrawn portions of commitments, credit facilities
and approved overdraft loans.
Separate Financial Statements
226
23.2.
Legal proceedings
In the normal course of business, the Bank is subject to a variety of legal actions. The Bank conducted a review of
legal proceedings outstanding against it as of 31 December 2025. Pursuant to this review, management has recorded
total provisions of €6,885 thousand (31 December 2024: €6,940 thousand) in respect of such legal proceedings
(note 19). The Bank will continue to defend its position in respect of each of these legal proceedings.
In addition to the legal proceedings covered by provisions, there are contingent liabilities arising from legal
proceedings in the total amount of €26,800 thousand, as at 31 December 2025 (31 December 2024: €29,717
thousand). This amount represents existing legal proceedings against the Bank that will most probably not result in
any payments due by the Bank.
23.3.
Tax Legislation
Given that several areas of Slovak tax legislation permit more than one interpretation, there is a possibility that the
tax authorities may take a different view on certain transactions carried out within the Bank and determine a tax
treatment that differs from the approach applied by the Bank.
The tax authorities have not audited the tax periods from 2020 to 2024, and therefore there is a risk of additional
tax being imposed.
The management of the Bank
is not aware of any facts that could lead to signiﬁcant costs in the future. Tax periods
that have not yet been audited by the tax authorities may be subject to tax audits retroactively up to 2020.
Separate Financial Statements
227
24.
Net interest income
€ ’000
2025
2024
Interest and similar income
Financial assets at FVTPL
4 388
3 335
Financial assets at FVOCI
36 724
31 118
Financial assets at AC
Due from banks
55 481
116 749
Due from customers
840 851
782 592
Derivatives – Hedge accounting
1 160
81 755
938 604
1 015 549
Interest and similar expense
Financial liabilities at AC
Due to banks
(41 102)
(44 985)
Due to customers and Subordinated debt
(191 301)
(257 296)
Lease liabilities
(421)
(319)
Debt securities in issue
(85 650)
(74 874)
Derivatives – Hedge accounting
(32 070)
(64 368)
Interest expense on assets
(25)
(43)
(350 569)
(441 885)
Total net interest income
588 035
573 664
€ ’000
2025
2024
Interest and similar income
Total interest income calculated
using the effective interest method
927 308
1 012 214
Other interest income
– interest income
on finance leases
6 908
-
Other interest income
– interest income
on financial assets at FVTPL
4 388
3 335
938 604
1 015 549
€ ’000
2025
2024
Net interest and similar income
Financial assets at FVOCI
36 724
31 118
Financial assets at AC
889 399
899 298
926 123
930 416
Financial liabilities at AC
(318 053)
(377 155)
Interest income on impaired loans and advances to customers for 2025 amounted to EUR 20 143 thousand
(2024: EUR 16 978 thousand).
Separate Financial Statements
228
25.
Net fee and commission income
2025
€ ’000
Retail Banking
Corporate
Banking
Central Treasury
Other
Total
Fee and commission income
Current accounts
47 985
3 420
-
11
51 416
Cards
42 480
1 167
-
53
43 700
Indirect deposits
39 109
36
-
-
39 145
Insurance
25 843
649
-
1
26 493
Payments and cash management
13 692
12 266
-
1
25 959
Loans
13 393
9 282
-
38
22 713
Trade finance
25
7 035
1 775
17
8 852
Structured finance
-
5 601
-
-
5 601
Factoring
49
2 190
-
-
2 239
Other
517
6 124
1 974
-
8 615
183 093
47 770
3 749
121
234 733
Fee and commission expense
Cards
(18 352)
(35)
-
-
(18 387)
Payments and cash management
(2 567)
(9 188)
-
-
(11 755)
Current accounts
-
-
(585)
(604)
(1 189)
Insurance
(661)
-
-
-
(661)
Factoring
(6)
(576)
-
-
(582)
Trade finance
-
-
-
(193)
(193)
Loans
(51)
-
-
(49)
(100)
Structured finance
-
-
-
-
-
Other
(77)
114
(1 902)
(3 046)
(4 911)
(21 714)
(9 685)
(2 487)
(3 892)
(37 778)
Net fee and commission income
under IFRS 15
161 379
38 085
1 262
(3 771)
196 955
Income from guarantees under IFRS 9
-
6 913
-
-
6 913
Total net fee and commission income
161 379
44 998
1 262
(3 771)
203 868
2024
€ ’000
Retail Banking
Corporate
Banking
Central Treasury
Other
Total
Fee and commission income
Current accounts
43 777
3 361
-
11
47 149
Cards
42 357
1 012
-
40
43 409
Indirect deposits
33 902
32
-
-
33 934
Insurance
18 737
547
-
1
19 285
Payments and cash management
16 066
13 123
-
1
29 190
Loans
7 260
9 324
-
(16)
16 568
Trade finance
20
7 081
1 578
-
8 679
Structured finance
-
1 934
-
-
1 934
Factoring
-
2 018
-
-
2 018
Other
495
5 897
1 258
-
7 650
162 614
44 329
2 836
37
209 816
Fee and commission expense
Cards
(20 714)
(106)
-
-
(20 820)
Payments and cash management
(2 684)
(9 113)
-
-
(11 797)
Current accounts
-
-
(600)
(670)
(1 270)
Insurance
(570)
-
-
-
(570)
Factoring
-
(475)
-
-
(475)
Trade finance
-
(168)
-
-
(168)
Loans
(74)
(19)
-
-
(93)
Structured finance
-
(19)
-
-
(19)
Other
(1 056)
(914)
(1 274)
(1 232)
(4 476)
(25 098)
(10 814)
(1 874)
(1 902)
(39 688)
Net fee and commission income
under IFRS 15
137 516
33 515
962
(1 865)
170 128
Income from guarantees under IFRS 9
-
6 870
-
-
6 870
Total net fee and commission income
137 516
40 385
962
(1 865)
176 998
Separate Financial Statements
229
26.
Net trading result
€ ’000
2025
2024
Cross currency swaps
29 935
(13 750)
Customer foreign exchange margins
10 154
10 238
Equity derivatives
5 202
698
Interest rate derivatives
1 535
1 704
Financial assets held for trading – debt securities
1 044
1 720
Non-trading financial assets measured at FVTPL
392
780
Net result from hedging transactions
281
(416)
Dividends from equity shares measured at FVTPL
43
69
Dividends from equity shares measured at FVOCI
32
19
Other derivatives
24
1
Financial assets measured at FVOCI
(4 606)
(364)
Foreign currency derivatives and transactions
(19 289)
16 932
24 747
17 631
27.
Other operating income
€ ’000
2025
2024
Financial revenues
357
226
Net profit from sale of fixed assets
125
217
Services
-
7
Other
1 365
1 684
1 847
2 134
28.
Other operating expenses
€ ’000
2025
2024
Costs of product support – credit cards
(3 378)
(2 607)
Contribution to the Deposit Protection Fund
(1 725)
(1 614)
Depreciation of leasehold improvements
(1 172)
-
Court fees and expenses and out-of-court settlements
(488)
(496)
Net release of impairment losses to other assets
(310)
-
Other damages
(158)
(574)
Other
(13 099)
(12 012)
(20 330)
(17 303)
Separate Financial Statements
230
29.
Salaries and employee benefits
€ ’000
Note
2025
2024
Remuneration
(112 377)
(113 145)
Social security costs
(46 401)
(43 772)
Social fund
(2 735)
(3 155)
Severance and Jubilee benefits
(449)
-
Termination benefit
19
(400)
-
(162 362)
(160 072)
The Bank does not have any pension arrangements separate from the pension system established by law, which
requires mandatory contributions of a certain percentage of gross salaries to the state-owned social insurance and
privately owned pension funds. These contributions are recognized in the year when salaries are earned by
employees. No further liabilities are arising for the Bank in terms of the payment of pensions to employees in the
future.
30.
Other administrative expenses
€ ’000
2025
2024
Third parties' services
(25 345)
(24 849)
Information technologies systems maintenance
(17 844)
(17 085)
Advertising and sponsorship
(6 631)
(6 670)
Archives and documents
(5 010)
(4 888)
Maintenance and repairs
(4 797)
(4 874)
Transport
(4 736)
(4 196)
Rental of buildings and related expenses
(3 930)
(4 027)
Indirect personnel costs and compensation
(3 226)
(3 916)
Energy costs
(2 982)
(3 463)
Electronic data processing system leasing
(2 660)
(2 336)
Value added tax and other taxes
(2 554)
(451)
Telephone and telecommunication costs
(2 508)
(2 363)
Forms and office supplies
(2 405)
(2 485)
Cleaning of premises
(1 480)
(1 431)
Security
(1 095)
(1 226)
Cost of legal services
(1 090)
(573)
Consultations and other fees*
(1 065)
(775)
Other rentals
(1 003)
(1 121)
Insurance
(748)
(899)
Postage costs
(737)
(388)
Information and research
(222)
(234)
Other expenses
(4 898)
(4 561)
Reinvoicing
1 308
1 214
(95 658)
(91 597)
* ‘Consulting and other fees’ include remuneration for the statutory audit and ﬁnancial statements of EUR 5
14 thousand (2024: EUR 394
thousand). The price also includes the fee for the audit of the annual group reporting, ancillary fees, the audit of the cons
olidated ﬁnancial
statements as well as the audit of the VUB Prague branch, VUB Operating Leasing and VUB Generali. Additionally, the remuneration for the audit
in sustainability reporting to EUR 118 thousand (2024: EUR 160 thousand), including ancillary fees. Other audit-related services and non-audit
services performed by the statutory auditor related to li
mited accounting review of interim statutory ﬁnancial statements and report packages,
audit of prudential and business regulatory statements as required by Slovak legislation of the extended auditor's report for the National Bank of
Slovakia, the recommen
ded list in connection with the veriﬁcation of proﬁt at the end of 2024 for the ECB, the recommended list in connection
with the issues of covered bonds and were amounted to EUR 174 thousand. (2024: EUR 261 thousand). All amounts shown here are without
VAT.
Separate Financial Statements
231
31.
Income tax expense and special levy
€ ’000
Note
2025
2024
Current income tax
(94 098)
(79 782)
Special levy on business in regulated sectors
(69 884)
(96 817)
Deferred income tax
17
3 383
5 728
(160 599)
(170 871)
The effective tax rate differs from the statutory tax rate in 2025 and in 2024
. The reconciliation of the Bank’s proﬁt
before tax with the actual corporate income tax is as follows:
€ ’000
2025
2024
Profit before tax
429 175
422 802
Theoretical tax calculated at the tax rate 24%
(101 921)
(88 788)
Tax impact
Non-taxable income
75
3 406
Impact of the special 16% CIT rate on government bond income
6 120
-
Tax non-deductible expenses
(2 120)
(1 530)
Impairment allowances and provisions, net
2 452
7 859
Additional tax of prior years
1 292
(815)
Creation of allowances for uncertain realization of deferred tax receivables
3 387
5 814
Income tax expense
(160 599)
(170 871)
of which Special levy on business in regulated sectors
(69 884)
(96 817)
Effective tax for the year
37.42%
40.41%
without Special levy on business in regulated sectors
25.25%
22.72%
32.
Related parties
Related parties are those counterparties that represent:
–
The deﬁnition of related parties includes the following persons or companies:
–
Key management personnel (
‘
KMP
’), i.e., members of the Board of Directors of VUB, who have the authority
and responsibility for planning, directing, and controlling the activities of VUB, including close family members;
–
Subsidiaries that are directly controlled by VUB, i.e., VUB Generali and VUB Operating Leasing;
–
Joint ventures that are under the joint control of VUB and other companies, i.e., Monilogi;
–
Associates in which VUB has signiﬁcant inﬂuence and which are neither subsidiaries nor joint ventures, i.e.,
SBCB;
–
ISP, i.e., the parent company of VUB, which holds a 100% share in the equity of VUB;
–
ISP Group companies, i.e., companies that are controlled by ISP directly or indirectly, ISP has signiﬁcant or
substantial inﬂuence over them, or they are under joint control (excluding entities under the control or signiﬁcant
inﬂuence of the VUB Group,
which are reported separately).
In considering each possible related party relationship, attention is directed to the substance of the relationship, and
not merely the legal form. The stated transactions have been made under arms-length commercial and banking
conditions.
In 2025
, the remuneration and other beneﬁts provided to members of the Management Board were
EUR 2 881 thousand (2024: EUR 2 864 thousand) and to members of the Supervisory Board EUR 82 thousand (2024:
EUR 83 thousand).
Separate Financial Statements
232
As at 31 December 2025, the outstanding balances with related parties comprised:
2025
€ ’000
KMP
Subsidiaries
Associates
Intesa
Sanpaolo
ISP Group
companies
Total
Assets
Cash and cash equivalents
-
-
-
24 569
673
25 242
Financial assets at FVTPL
Financial assets held
for trading
-
-
-
42 409
27
42 436
Non
-trading financial assets
at FVTPL
-
-
-
533
-
533
Derivatives – Hedge accounting
-
-
-
70 358
-
70 358
Financial assets at FVOCI
-
-
-
109
-
109
Financial assets at AC
Due from other banks
-
-
-
170 331
-
170 331
Due from customers
1 588
8 190
-
-
86 673
96 451
Property and equipment
-
32
-
-
-
32
Other assets
-
-
-
49
5 119
5 168
1 588
8 222
-
308 358
92 492
410 660
Liabilities
Financial liabilities at FVTPL
Financial liabilities
held for trading
-
-
-
43 869
-
43 869
Derivatives – Hedge accounting
-
-
-
75 619
-
75 619
Financial liabilities at AC
Due to banks
-
-
-
982 091
1 845
983 936
Due to customers
987
30
91
-
3 626
4 734
Leasing liability
-
65
-
-
-
65
Subordinated debt
-
-
-
100 090
200 296
300 386
Provisions
-
-
-
7
-
7
Other liabilities
533
101
-
2 959
924
4 517
1 520
196
91
1 204 635
206 691
1 413 133
As at 31 December 2024, the outstanding balances with related parties comprised:
2024
€ ’000
KMP
Subsidiaries
Associates
Intesa
Sanpaolo
ISP Group
companies
Total
Assets
Cash and cash equivalents
-
-
-
23 431
534
23 965
Financial assets at FVTPL
Financial assets held
for trading
-
-
-
47 651
-
47 651
Non-trading financial assets
at FVTPL
-
-
-
580
-
580
Derivatives – Hedge accounting
-
-
-
75 566
-
75 566
Financial assets at FVOCI
-
-
-
72
-
72
Financial assets at AC
Due from other banks
-
-
-
180 377
-
180 377
Due from customers
2 322
13 752
-
-
86 670
102 744
Property and equipment
-
896
-
-
-
896
Other assets
-
57
-
97
7 316
7 470
2 322
14 705
-
327 774
94 520
439 321
Liabilities
Financial liabilities at FVTPL
Financial liabilities
held for trading
-
-
-
59 452
8
59 460
Derivatives – Hedge accounting
-
-
-
148 296
-
148 296
Financial liabilities at AC
Due to banks
-
-
-
698 492
1 710
700 202
Due to customers
1 164
32
90
-
6 354
7 640
Leasing liability
-
915
-
-
-
915
Subordinated debt
-
-
-
100 095
200 306
300 401
Provisions
-
-
-
5
-
5
Other liabilities
580
211
-
2 871
60
3 722
1 744
1 158
90
1 009 211
208 438
1 220 641
Separate Financial Statements
233
As at 31 December 2025, the outstanding off-balance sheet balances with related parties comprised:
2025
€ ’000
KMP
Subsidiaries
Associates
Intesa
Sanpaolo
ISP Group
companies
Total
Commitments and undrawn
credit facilities
242
4 838
-
185 422
8
190 510
Issued guarantees
-
-
-
20 537
1 315
21 852
Received guarantees
-
-
-
1 600
1 000
2 600
Derivative transactions (notional
amount – receivable)
-
-
-
11 142 968
10 549
11 153 517
Derivative transactions (notional
amount – payable)
-
-
-
11 142 222
10 514
11 152 736
As at 31 December 2024, the outstanding off-balance sheet balances with related parties comprised:
2024
€ ’000
KMP
Subsidiaries
Associates
Intesa
Sanpaolo
ISP Group
companies
Total
Commitments and undrawn
credit facilities
47
8 289
-
178 089
8
186 433
Issued guarantees
-
-
-
25 505
5 937
31 442
Received guarantees
-
-
-
1 600
1 000
2 600
Derivative transactions
(notional amount – receivable)
-
-
-
10 976 570
17 370
10 993 940
Derivative transactions
(notional amount – payable)
-
-
-
10 976 409
17 375
10 993 784
For the year ended 31 December 2025, the outstanding balances with related parties comprised:
2025
€ ’000
KMP
Subsidiaries
Associates
Intesa
Sanpaolo
ISP Group
companies
Total
Income and expense
Interest and similar income
43
269
-
4 508
3 080
7 900
Interest and similar expense
(18)
(4)
-
(37 818)
(11 268)
(49 108)
Fee and commission income
1
4
2
636
33 001
33 644
Fee and commission expense
-
-
-
(140)
(9)
(149)
Dividend income
-
-
-
-
-
-
Net trading result
-
-
-
41 538
1 217
42 755
Other operating income
-
120
-
650
126
896
Other operating expenses
-
-
-
(60)
-
(60)
Other administrative expenses
-
(203)
-
(6 837)
(13 417)
(20 457)
Depreciation
-
(238)
-
-
-
(238)
Impairment losses and
provisions for loan
commitments and financial
guarantees
-
-
-
(5)
-
(5)
26
(52)
2
2 472
12 730
15 178
For the year ended 31 December 2024, the outstanding balances with related parties comprised:
2024
€ ’000
KMP
Subsidiaries
Associates
Intesa
Sanpaolo
ISP Group
companies
Total
Income and expense
Interest and similar income
60
703
-
5 387
2 456
8 606
Interest and similar expense
(31)
(33)
-
(38 361)
(13 300)
(51 725)
Fee and commission income
1
4
2
119
30 315
30 441
Fee and commission expense
-
-
-
(134)
(6)
(140)
Dividend income
-
3 318
-
-
-
3 318
Net trading result
-
4 100
-
(38 816)
(521)
(35 237)
Other operating income
-
49
-
769
125
943
Other operating expenses
-
-
-
-
-
-
Other administrative expenses
-
97
-
(6 730)
(12 992)
(19 625)
Depreciation
-
(507)
-
-
-
(507)
Impairment losses and
provisions for loan
commitments and financial
guarantees
-
2
-
1
-
3
30
7 733
2
(77 765)
6 077
(63 923)
Separate Financial Statements
234
33.
Events after the end of the reporting period
From 31 December 2025
, up to the date when these ﬁnancial statements were
authorized for issue, there were no
further events identiﬁed that would require adjustments to or disclosure in these ﬁnancial statements.
These ﬁnancial statements were authorized for issue by the
Management Board on 3
0
March 2026
. These
ﬁnancial
statements will be published and
available at the registered ofﬁce of the Bank.
Jozef Kausich
Chairman of the Management Board
Darina Kmeťová
Member of the Management Board
235
Profit distribution
The Management Board will propose the following 2025
proﬁt distribution:
€ ’000
Dividends to shareholders
188 003
Retained earnings
80 573
268 576
236
Consolidated Sustainability Report
Consolidated Sustainability Report drawn up in accordance with reporting standards applied pursuant to the Act
on Accounting, which implements Directive (EU) on corporate sustainable reporting (CSRD) and Directive on annual
financial statements, consolidated financial statements and related report and in accordance with the specifications
adopted in EU Taxonomy for the year ended 31 December 2025.
237
Contents
Consolidated Sustainability Report 2025
.......................................................................................................................
238
Independent Auditor’s report
........................................................................................................................................
239
General Information
..............................................................................................................................................
244
ESRS 2 – General disclosures
..................................................................................................................................
244
Environmental information
....................................................................................................................................
278
Reporting in accordance with the EU Taxonomy (EU Regulation 2020/852)
.............................................................
278
ESRS E1 – Climate Change
.....................................................................................................................................
281
ESRS E2 – Pollution
................................................................................................................................................
298
ESRS E3 – Water and marine resources
...................................................................................................................
300
ESRS E4 – Biodiversity and ecosystems
....................................................................................................................
302
ESRS E5 – Resource use and circular economy
........................................................................................................
304
Social Information
................................................................................................................................................
308
ESRS S1 – Own Workforce
.....................................................................................................................................
308
ESRS S3 – Affected Communities
...........................................................................................................................
336
ESRS S4 – Consumers and end-users
......................................................................................................................
341
Governance Information
.......................................................................................................................................
355
ESRS G1 – Business Conduct
..................................................................................................................................
355
Disclosure requirements in ESRS
....................................................................................................................................
365
List of datapoints in cross-cutting and topical standards that derive from other EU legislation
........................................
371
Annexes
.......................................................................................................................................................................
374
Annex – Taxonomy templates
.......................................................................................................................................
375
238
Consolidated Sustainability Report 2025
The undersigned Jozef Kausich, in his capacity as the Chief Executive Ofﬁcer and Chairman of the Management
Board, and Darina Kmeťová, in her capacity as Chief Financial Ofﬁcer and Member of the Management Board, certify
that the Consolidated sustainability report, included in the Annual report, has been prepared:
–
In accordance with the reporting standards applied pursuant to the Amendment to the Act on Accounting
105/2024 of 1 June 2024, which implements Directive (EU) 2022/2464 on corporate sustainable reporting
(‘CSRD’) and Directive (EU) 2013/34 on annual ﬁnancial statements, consolidated ﬁnancial statements and
related reports;
–
With the speciﬁcations adopted pursuant to Article 8(4) of Regulation (EU) 2020/852 (EU Taxonomy).
8 April 2026
Jozef Kausich
Chief Executive Ofﬁcer
and Chairman of the Board of Directors VUB, a.s.
Darina Kmeťová
Chief Financial Ofﬁcer
and Member of the Board of Directors VUB, a.s.
Spoločnosť zo skupiny Ernst & Young Global Limited
Ernst & Young Slovakia, spol. s r.o., IČO: 35 840 463,
zapísaná v Obchodnom registri Mestského súdu Bratislava III
, oddiel: Sro, vložka číslo: 27004/B a v zozname audítorov vedenom
Slovenskou komorou audítorov pod č. 257.
Ernst & Young Slovakia, spol. s. r.o.
Žižkova 9
811 02 Bratislava
Slovenská republika
Tel:
+421 2 3333 9111
www.ey.com/sk
Independent auditor´s limited assurance report
on Consolidated Sustainability statement
To the Shareholders, Supervisory Board, Board of Directors and to the Audit Committee of
Všeobecná
úverová banka, a.s.
We have conducted a limited assurance engagement on the Consolidated Sustainability Statement of
Všeobecná
úverová banka, a.s.
(hereafter the “Company”)
and its subsidiaries (hereafter the “Group”)
including the information incorporated in the Consolidated Sustainability Statement by reference, as
disclosed in section Sustainability Report for year 2025
(the “
Consolidated
Sustainability Statement”)
as
at 31 December 2025 and for the year then ended.
Identification of Applicable Criteria
The Consolidated Sustainability Statement was prepared by the Company in order to satisfy the
requirements of § 20g) of the Slovak Act No. 431/2002 Coll. on Accounting, as amended (hereafter the
“Act
on
Accounting”)
, which implementsArticle 29a of Directive 2013/34/EU of the European Parliament
and of the Council, including:
•
Compliance with the European Sustainability Reporting Standards (ESRS), as set out in
Commission Delegated Regulation (EU) 2023/2772 of 31 July 2023 supplementing Directive
2013/34/EU of the European Parliament and of the Council as regards sustainability reporting
standards (the ‘ESRS’),
including that the process carried out by the Group to identify the
information reported in the Consolidated
Sustainability Statement (the “Process”) is in
accordance with the description set out in note ESRS 2 IRO-1;
•
Compliance of the disclosures in subsection
“
Environmental information
–
Reporting in
accordance with the EU Taxonomy
“
within the environmental section of the Consolidated
Sustainability Statement with Article
8 of EU Regulation 2020/852 (the “Taxonomy Regulation”).
Inherent Limitations in Preparing the Consolidated Sustainability Statement
As further detailed in the consolidated sustainability reporting, section BP-2: Disclosures related to
specific circumstances, there are inherent limitations associated with the calculation or assessment of
sustainability-related matters in accordance with the applicable criteria.
In reporting forward-looking information in accordance with ESRS, the Board of Directors (hereafter the
“
management of the Company
”)
is required to prepare the forward-looking information on the basis of
disclosed assumptions about events that may occur in the future and possible future actions by the
Group. The actual outcome is likely to be different since anticipated events frequently do not occur as
expected.
In determining the disclosures in the Consolidated Sustainability Statement, management of the
Company interprets undefined legal and other terms. Undefined legal and other terms may be
interpreted differently, including the compliance of their interpretation with applicable law ,and,
accordingly, are subject to uncertainty.
As a result of the criteria used, the nature of Consolidated Sustainability Statement, and the fact that
there is still a lack of experience with the long-term application of binding regulations, their standard
application, and the procedures for their publication, various measurement methods are used in practice
THIS IS A TRANSLATION OF THE ORIGINAL SLOVAK REPORT
that are acceptable but may lead to differences between individual companies. The methodology and
its development affect not only the comparability of sustainability information published by different
companies but also the year-on-year comparability of information within the same company.
Responsibilities of the Company’s Board of Directors, Supervisory Board and Audit Committee for the
Consolidated Sustainability Statement
The management of the Company is responsible for designing and implementing a process to identify
the information reported in the Consolidated Sustainability Statement in accordance with the ESRS and
for disclosing this process in note ESRS 2 IRO-1 of the Consolidated Sustainability Statement. This
responsibility includes:
•
Understanding the context in which the
Group’s
activities and business relationships take place
and developing an understanding of its affected stakeholders;
•
The identification of the actual and potential impacts (both negative and positive) related to
sustainability matters, as well as risks and opportunities that affect, or could reasonably be
expected to affect, the Group
’s financial position, financial performance, cash flows, access to
finance or cost of capital over the short-, medium-, or long-term;
•
The assessment of the materiality of the identified impacts, risks and opportunities related to
sustainability matters by selecting and applying appropriate thresholds;
•
Making assumptions that are reasonable in the circumstances.
The management of the Company is further responsible for the preparation of the Consolidated
Sustainability Statement, in accordance with § 20g) of the Act on Accounting , which implements Article
29a of Directive 2013/34/EU of the European Parliament and of the Council, including:
•
Compliance with the ESRS;
•
Preparing the disclosures in subsection
“
Environmental information
–
Reporting in accordance
with the EU Taxonomy
“
within the environmental section of the Consolidated Sustainability
Statement, in compliance with Article 8 of EU Regulation 2020/852;
•
Designing, implementing and maintaining such internal controls that management determines
are necessary to enable the preparation of the Consolidated Sustainability Statement that is
free from material misstatement, whether due to fraud or error;
•
The selection and application of appropriate sustainability reporting methods and making
assumptions and estimates about individual sustainability disclosures that are reasonable in the
circumstances.
Those
charged with governance are responsible for overseeing the Group’s process for preparing the
Consolidated Sustainability Statement.
Auditor’s Responsibility
We conducted our limited assurance engagement in accordance with the International Standard on
Assurance Engagements (ISAE) 3000 (Revised), Assurance Engagements Other than Audits or
Reviews of Historical Financial Information, issued by the International Auditing and Assurance
Standards Board (hereafter “ISAE 3000 (Revised)”)
.
THIS IS A TRANSLATION OF THE ORIGINAL SLOVAK REPORT
Our responsibility is to plan and perform the assurance engagement to obtain limited assurance about
whether the Consolidated Sustainability Statement is free from material misstatement, whether due to
fraud or error, and to issue a limited assurance report that includes our conclusion. Misstatements can
arise from fraud or error and are considered material if, individually or in the aggregate, they could
reasonably be expected to influence decisions of users taken on the basis of the Consolidated
Sustainability Statement as a whole.
As part of a limited assurance engagement in accordance with ISAE 3000 (Revised) we exercise
professional judgement and maintain professional skepticism throughout the engagement.
Our responsibilities in respect of the Consolidated Sustainability Statement, in relation to the Process,
include:
•
Obtaining an understanding of the Process but not for the purpose of providing a conclusion on
the effectiveness of the Process, including the outcome of the Process; and
•
Assessing, whether identified information complies with the ESRS disclosure requirements; and
•
Designing and performing procedures to evaluate whether the Process is consistent with the
Group
’s description of its Process, as disclosed in note ESRS 2 IRO
-1.
Our other responsibilities in respect of the Consolidated Sustainability Statement include:
•
Obtaining an understanding of the Group
’s control environment, processes and information
systems relevant to the preparation of the Consolidated Sustainability Statement but not for the
purpose of evaluating the design of particular control activities, obtaining evidence about their
implementation or testing their operating effectiveness;
•
Identifying disclosures where material misstatements are likely to arise, whether due to fraud or
error; and
•
Designing and performing procedures responsive to disclosures in the Consolidated
Sustainability Statement where material misstatements are likely to arise. The risk of not
detecting a material misstatement resulting from fraud is higher than for one resulting from error,
as fraud may involve collusion, forgery, intentional omissions, misrepresentations, or the
override of internal control.
Our Independence and Quality Management
We are independent of the Group in accordance with the provisions of Act No. 423/2015 Coll. on
Statutory Audit and on amendments and supplements to the Act on Accounting No. 431/2002 Coll. on
Accounting, as amended, relating to independence
and ethics, including the Auditor’s Code of Ethics,
which are relevant to our limited assurance engagement on the Consolidated Sustainability Statement,
and we have fulfilled the other ethical requirements of these provisions.
We applied International Standard on Quality Management (ISQM) 1, Quality Management for Firms
that Perform Audits or Reviews of Financial Statements, or Other Assurance or Related Services
Engagements, and accordingly maintain a comprehensive system of quality control including
documented policies and procedures regarding compliance with ethical requirements, professional
standards and applicable legal and regulatory requirements.
Summary of Work Performed
THIS IS A TRANSLATION OF THE ORIGINAL SLOVAK REPORT
A limited assurance engagement involves performing procedures to obtain evidence about the
Consolidated Sustainability Statement. The procedures in a limited assurance engagement vary in
nature and timing from, and are less in extent than for, a reasonable assurance engagement.
Consequently, the level of assurance obtained in a limited assurance engagement is substantially lower
than the assurance that would have been obtained had a reasonable assurance engagement been
performed.
The nature, timing and extent of procedures selected depend on professional judgement, including the
identification of disclosures where material misstatements are likely to arise, whether due to fraud or
error, in the Consolidated Sustainability Statement.
In conducting our limited assurance engagement, with respect to the Process, we:
•
Obtained an understanding of the Process by:
•
Performing inquiries to understand the sources of the information used by management
(e.g., stakeholder engagement, business plans and strategy documents);
•
Reviewing the Group
’s internal documentation of its Process;
•
Evaluated whether the evidence obtained from our procedures about the Process implemented
by the Group was consistent with the description of the Process set out in note ESRS 2
IRO-1.
In conducting our limited assurance engagement, with respect to the Consolidated Sustainability
Statement, we:
•
Obtained an understanding of the Group
’s reporting processes relevant to the preparation of its
Consolidated Sustainability Statement by:
•
Performing inquiries to understand the Group
’s control environment, processes and
information systems relevant to the preparation of the Consolidated Sustainability
Statement; but not for the purpose of providing the conclusion on the effectiveness of
the Group's internal control environment.
•
Evaluated whether material information identified by the Process to identify the information
reported in the Consolidated Sustainability Statement is included in the Consolidated
Sustainability Statement;
•
Evaluated whether the structure and the presentation of the Consolidated Sustainability
Statement is in accordance with the ESRS;
•
Performed inquires of relevant personnel and analytical procedures on selected disclosures in
the Consolidated Sustainability Statement;
•
Performed substantive assurance procedures based on a sample basis on selected disclosures
in the Consolidated Sustainability Statement;
•
Where applicable, compared the information presented in the Consolidated Sustainability
Statement with the corresponding information disclosed in the financial statements;
•
Obtained evidence on the methods for developing material estimates and forward-looking
information and on how these methods were applied;
•
Obtained an understanding of the process to identify taxonomy-eligible and taxonomy-aligned
economic activities and the corresponding disclosures in the Consolidated Sustainability
Statement.
THIS IS A TRANSLATION OF THE ORIGINAL SLOVAK REPORT
We believe that the evidence we have obtained is sufficient and appropriate to provide a basis for our
conclusion.
Limited Assurance Conclusion
Based on the procedures we have performed and the evidence we have obtained, nothing has come to
our attention that causes us to believe that the Consolidated Sustainability Statement is not prepared,
in all material respects, in accordance with § 20g) of the Act on Accounting , which implements Article
29a of Directive 2013/34/EU of the European Parliament and of the Council, including:
•
Compliance with the European Sustainability Reporting Standards (ESRS), including that the
process carried out by the Group to identify the information reported in the Consolidated
Sustainability Statement is in accordance with the description set out in note ESRS 2 IRO-1;
•
Compliance of the disclosures in subsection
“
Environmental information
–
Reporting in
accordance with the EU Taxonomy
”
in accordance with the EU Taxonomy within the
environmental section of the Consolidated Sustainability Statement with Article 8 of EU
Regulation 2020/852.
8 April 2026
Bratislava, Slovak Republic
Ing. Marek Mikolaj, statutory auditor
UDVA Licence for sustainability assurance No. 116
Ernst & Young Slovakia, spol. s r.o.
UDVA Licence for sustainability assurance No. 25
244
General Information
ESRS 2 – General disclosures
Basis for preparation and methodology
Reporting principles
The VUB Group (‘the Group’) has prepared the Consolidated Sustainability Report (hereinafter also referred to as
‘Sustainability Report ’ or ‘Report’) pursuant to the Amendment to the Act on Accounting 105/2024 of 1 June 2024,
which implements Directive (EU) 2022/2464 on corporate sustainability reporting (‘CSRD’) into the national law, and
in compliance with the European Sustainability Reporting Standards (‘ESRS’), set forth in the Commission Delegated
Regulation (EU) 2023/2772. For the purpose of this Report, an explicit difference is made between the VUB Group
and the ISP Group (Intesa Sanpaolo Group), which the VUB Group is part of and consolidated in a separate
sustainability statement.
The Chief Financial Ofﬁcer and CEO certify in a statement that the Sustainability Report, within the Annual Report
covering ﬁscal year 2025 (ending 31st December 2025), complies with the aforementioned legislative requirements
including Article 8(4) of Regulation (EU) 2020/852 (Taxonomy Regulation) as requested, representing a separate part
of the Environmental information of this Report. This Report has undergone a limited assurance by the appointed
auditing ﬁrm Ernst & Young Slovakia, spol. s r. o., also conducts the ﬁnancial audit of the ﬁnancial statements and
provides its conclusions on compliance.
The Sustainability Report outlines the VUB Group’s sustainability considerations, focusing on the impact on people
and the environment, business risks, and related opportunities. Its ambition is to present clear and transparent
information on sustainability performance, enabling stakeholders to make well-informed decisions and assess the
Group's commitment to environmental and social responsibility. This is the second report issued by the VUB Group
in accordance with the CSRD, as well as EU Taxonomy regulation.
The ﬁnal Consolidated Sustainability Report was approved by the Management Board and Supervisory Board in April
2026.
Corporate reporting perimeter
The scope of consolidation of the Consolidated Sustainability Report includes 3 legal entities – VUB Bank, VUB
Operating Leasing and VUB Generali, which coincides with the scope of the Consolidated Financial Statements for
the ﬁscal year 2025.
For 2025, pursuant to Art. 19a(9)/29a(8) of EU Directive 2013/34/EU, which regulates the rules for exemption from
the preparation of sustainability reporting at the individual level, it should be noted that the subsidiaries VUB
Operating Leasing and VUB Generali are exempt, as they meet the criteria established for the exemption.
Perimeter of activities subject to reporting
The VUB Group extended the scope of materiality assessment of impacts, risks and opportunities and resulting
reported disclosures to cover the upstream and downstream value chain, encompassing three macro-key areas:
Scope Area
Description
Own Operations
Internal physical operations and activities directly controlled by the VUB Group.
Upstream Value Chain
All operational processes related to the supply chain, including procurement practices and associated
reputational risks.
Downstream Value Chain
All business activities and supporting processes, including commercial relationships with clients and
counterparties, and financing/investment portfolios managed by the Group.
Reporting on own operations includes policies, actions, targets (where applicable) and metrics related to material
sustainability matters. In addition to the disclosures required by the ESRS standards for each topic, the VUB Group
has identiﬁed entity-speciﬁc disclosures areas not fully covered by the ESRS standards but essential for providing a
comprehensive view of the VUB Group's sustainability impacts, risks and opportunities made available to all
stakeholders. Entity-speciﬁc disclosures have been identiﬁed and prepared in accordance with the principles
described in Appendix A of ESRS 1; their location within this Report is indicated in the ‘Disclosure requirements in
ESRS’ section at the end of the Report.
With reference to the value chain, the VUB Group disclosed both qualitative elements relating to the policies, actions
and targets (where applicable) it deﬁnes for managing and monitoring material sustainability matters in the upstream
or downstream value chain, and quantitative data on greenhouse gas emissions (‘GHG emissions’) and on entity-
ESRS 2 – General disclosures
245
speciﬁc portfolio metrics.
In accordance with the transitional provisions set out in ESRS 1, the VUB Group acknowledges that, during the ﬁrst
years of reporting under the ESRS, full upstream and downstream value chain information may not be available.
Throughout the reporting period, the VUB Group made extensive efforts to obtain relevant data from its value chain,
including leveraging information reported by its largest counterparties, particularly those already publishing
CSRD
‑
aligned sustainability statements.
Despite these efforts, certain value chain data remained limited or unavailable, largely due to the evolving reporting
capabilities of external stakeholders. In line with the transitional measures, the VUB Group therefore relied on
information available in
‑
house, such as internally collected data and publicly accessible disclosures, when preparing
value chain
‑
related information on policies, actions and targets in accordance with ESRS 2 and other applicable ESRS
standards.
The VUB Group continues to develop and enhance its processes for collecting, validating and integrating value chain
information, and has established plans to progressively expand the scope and quality of its upstream and
downstream data in line with future ESRS requirements.
No speciﬁc information has been omitted because it is the subject of intellectual property, know-how, the results of
innovation or because it is classiﬁed as sensitive.
No option to omit disclosure of impending developments or matters in the course of negotiation has been used by
the Group.
Time horizons
Consistently with the ESRS, the VUB Group deﬁnes:
Scenario Type
Reference Time Horizon
Short-term
1 year
Medium-term
Up to 5 years
Long-term
More than 5 years
For management purposes, the Group applies these deﬁnitions to integrate existing strategic guidelines and
managerial controls. In particular, the medium-term deﬁnition is aligned with the evolution of the ISP Group Business
Plan, which also includes the VUB Group, while the long-term deﬁnition is aligned with the commitments deriving
from the ISP Group's adherence to the principles of achieving Net Zero emissions targets by 2050.
Use of estimates
Value chain
In this report, the VUB Group used estimates and indirect sources for the disclosure of the standard ESRS E1 –
Climate Change, section metrics for value chain:
–
Scope 3 indirect GHG emissions
1
(disclosure requirement E1-6 relating to the upstream and downstream value
chain). Scope 3 GHG emissions are deﬁned as indirect greenhouse gas emissions generated along the company's
value chain from activities not directly owned or controlled (e.g. waste disposal by third party companies);
–
quantiﬁcation of the physical risk of exposures in the portfolio (information obligation E1-9 relating to the
downstream value chain).
2
The VUB Group's ability to gather comprehensive information on its upstream and downstream value chain may
vary due to factors like contractual nature, counterparty size, and control over transactions outside its consolidation
scope. Gathering data is particularly difﬁcult when value chain actors are not bound by sustainability reporting
mandates.
In accordance with ESRS 1, the VUB Group has undertaken reasonable efforts to collect quantitative data related to
its value chain, resorting to estimates based on veriﬁable information, including sector averages and other proxies,
when direct data collection was unfeasible.
The data sources and estimation methods applied to calculate proxy values reﬂect the variety of cases and
counterparties involved. In general, the preparation of these estimates was based on two main frameworks
represented by:
–
GHG Protocol for calculating Scope 3 emissions1 across the value chain;
–
PCAF (Partnership for Carbon Accounting Financials) for Scope 3 emissions linked to ﬁnanced emissions from
1
For further information on Scope 3 Emissions, please see the standard ESRS E1 – Climate Change, section Metrics on GHG emissions.
2
The Group applies transitional provisions that allow for the gradual introduction of the E1-9 disclosure obligation and only reports in this report
the equivalent information that is also included in the ‘Pillar 3’ disclosure.
ESRS 2 – General disclosures
246
mortgage lending, sovereign debt and non-ﬁnancial corporations within the banking book. According to this
framework, a score of 4 (2024: 4) for mortgage lending and 1 (2024: 1) for sovereign debt is assigned to this
calculation according to the data quality measurement guide.
In all cases, decisions on proxy usage were made at the individual exposure or asset level based on the availability of
the most speciﬁc data which helped to increase the accuracy. In the case of Green Asset ratio, when no sufﬁcient
data are available the exposure is not marked as EU taxonomy aligned.
Scope 3 estimates beyond the VUB Group were provided by the ISP Group where relevant. Adherence to nationally
and internationally established calculation standards as well as sector-speciﬁc approaches also helped minimize data
inaccuracies.
The Group is actively working to enhance data precision by tackling the biggest source of measurement uncertainty
– unavailability of primary data, by engaging directly with counterparties (portfolio companies and suppliers) and
specialized environmental data providers, applying a proportionality- and risk-based approach aligned with the
revised CSRD framework. Looking ahead, given the reduced scope and phased applicability of CSRD reporting
obligations, the Group anticipates a gradual and possibly uneven increase in the availability of reported data,
primarily from counterparties remaining within scope, and expanding direct data collection from counterparties in
ﬁnancing and due diligence processes – for instance, via ESG Questionnaires developed by the Slovak Banking
Association, assessment of EU taxonomy alignment at the transaction level where decision-relevant, and
continuation in collection of EPC certiﬁcates. The Group is also committed to reﬁning the proxy methodologies used
for data estimation, acknowledging that material data gaps will persist, advancing both internally within the ISP
Group and in the ﬁnance sector.
In particular, to identify exposures subject to physical risk related to climate change, the VUB Group uses an external
tool for mapping and measuring risks at the individual property level. This is achieved through mapping of physical
risks through the use of long-term climate scenarios and subsequent declination of climatological forecasts using
high-granularity grids with calculation of the speciﬁc indicators of each risk.
Secondly, the VUB Group uses the highly granular Synthetic Physical Risk Indicator (SPRI) to assess risk levels for each
location. This calculation is based on the geo-location of the headquarters and production sites, as well as the speciﬁc
buildings used as collateral properties, with the consequent identiﬁcation and subsequent attribution of the level of
associated risk. Following the assignment of the SPRI, the decision whether or not an exposure is subject to climate-
related events related to physical risk is based on two criteria: the maturity of the exposure and the evolution of the
severity of the estimated physical risk indicator.
Own operations
With reference to own operations, the VUB Group also used estimates for the calculation of other metrics such as
E1-5 (energy consumption).
For further information on calculation methodologies, please refer to the standard ESRS E1 – Climate change,
sections Metrics on energy consumption.
Metrics were validated by the auditor of the Consolidated Sustainability Report. No metrics have been subjected to
assurance by other external bodies.
All provided metrics are presented with precise names and description.
When currency is used in the metric it is aligned with the currency of the ﬁnancial statement.
Comparative data
This Consolidated Sustainability Report of the VUB Group is the second to be prepared in accordance with CSRD.
Changes compared to the previous year (2024) are described below, as well as in the relevant sections where the
values are presented.
S1-14
Metrics related to health and safety
A more accurate calculation of worked hours was used for 2025. Based on actual hours worked, considering vacation
and paid leave. The year 2024 was recalculated using the updated, more accurate worked-hours calculation.
S1-16 Metrics related to equal pay and remuneration
–
Gender pay gap
The ﬁgures were updated to improve data quality and ensure a more accurate comparison with FY 2025.
–
Annual total remuneration ratio
The calculation method was updated so that both years use the same methodology, which deﬁnes the remuneration
ESRS 2 – General disclosures
247
ratio strictly as the highest
‑
paid individual’s annual remuneration divided by the median remuneration of all
employees.
S1 – Entity speciﬁc
Number for employees which completed mandatory trainings adjusted to represent all training completed via LEA
platform and VUB Academia.
E1-5 Metrics on energy consumption
Change of reporting methodology for 2025: In connection with the purchase of renewable electricity under
guarantees of origin (GO), the remaining electricity consumed in leased premises (buildings and ATMs), where VUB
Group has no operational control over the supply of electricity or information on the energy mix, is reported as
electricity from fossil fuels in accordance with the GHG Protocol.
E1-6 Gross Scopes 1, 2, 3 and Total GHG emissions
Change of reporting methodology for 2025: Due to changes in the methodology of calculation of energy
consumption, GHG emissions were recalculated as well. The values were recalculated for 2024. For more information
related to the changes of the methodology refer to Metrics on energy consumption section.
E1-6 Percentage of GHG Scope 3 calculated using primary data
–
Housing loans
Compared to the previous year, the bank expanded the available data through digitalization, which allowed for
more accurate calculations. At the same time, it used a new calculation model for collaterals for which it did not
have information on the energy classes of the properties. In these cases, it applied proxy data on the energy efﬁciency
of the collaterals based on the primary energy factor and the total energy need.
Statement on due diligence
The VUB Group has identiﬁed due diligence processes that enable it to identify and manage negative impacts arising
from its own operations or from the upstream and downstream value chain. The due diligence activities conducted
by the VUB Group are incorporated into the existing strategy and business model. In the event of identiﬁcation of
negative impacts, the VUB Group assesses and takes adequate actions to manage and mitigate such impacts, also
through its products and business relationships.
In the following table the main elements of the due diligence described in this Report are represented:
Core elements of due diligence
Paragraphs of the Consolidated Sustainability Report
Embedding due diligence in governance, strategy and business
model
General information: Strategy, business model and value chain
General information: Governance structure
General information: Double materiality assessment
Engaging with affected stakeholders in all key steps of the due
diligence
General information: Double materiality assessment
Identifying and assessing adverse impacts
General information: Double materiality assessment
Materiality process on impacts, risks and opportunities: E1
Taking actions to address those adverse impacts
E1 Climate Change: Strategy to combat climate change at portfolio
level
Tracking the effectiveness of these efforts and communicating
E1 Climate Change: GHG emissions reduction targets
With reference to the ESRS E1 – Climate Change, the VUB Group has not yet established measurable quantitative
targets for monitoring identiﬁed and assessed negative impacts within its own operations and downstream value
chain. However, through the policies and actions adopted, and described in the following chapters of this Report, it
has tools for managing the relevant impacts.
Strategy, business model and value chain
Strategy
The VUB Group recognizes that its employees are its most valuable asset and a key driver of future success. As of
31st December 2025, the workforce is primarily based in Slovakia, with 3,419 (2024: 3606) employees, and in the
Czech Republic, with 31 (2024: 31) employees. The Group pursues fostering the growth and satisfaction of its
employees through continuous investments in talent and skills development, ensuring that they remain central to
the Group's progress.
ESRS 2 – General disclosures
248
–
The VUB Group integrates sustainability considerations into its overall business strategy, aiming to act as a local
market leader in sustainable ﬁnance by offering a broad range of sustainability
‑
supporting products tailored to
the needs of our customers. In the reporting period, 36.6% of new retail loans and 20% of new corporate loans
were classiﬁed as sustainable, reﬂecting the increasing relevance of these products within our core business
activities. Our strategic focus is to continuously expand and enhance our sustainable offering, ensuring
alignment with our long
‑
term sustainability objectives. In the reporting period, we fulﬁlled our sustainability
ambitions primarily through the following goals: Support to address social needs: Helping the elderly, children,
disadvantaged groups, addressing material and educational poverty, social and community integration through
the social pillar of the VUB Foundation and its partnerships;
–
Contribution to ﬁnancial inclusion: Provision of social credit to vulnerable groups who may lack access to
traditional ﬁnancial channels, this includes, for example, mortgage offerings tailored to young people and
consumer loans designed to assist speciﬁc categories of parents;
–
Supporting knowledge and awareness: Providing support to awareness raising among clients and potential
clients, educational, and knowledge exchange projects and events which result in wider socioeconomic beneﬁts:
o
Via partnerships with associations in the ﬁeld of sustainable buildings and their energy efﬁciency
(e.g. Buildings For Future, Slovak Green Building Council);
o
Via support to initiatives and research in the ﬁeld of sustainable urban planning, climate change
adaptation of cities, and green infrastructure (e.g. Institute for Passive Houses, International Climate
Adaptation Institute, Manifest2020);
o
Via projects and partnerships in the ﬁeld of circular economy, waste reduction, and sustainable
procurement (e.g. Circular Slovakia, Sustainable e-shop project with VISA and Heureka);
o
Via support to environmental practices in the ﬁeld of sustainable agriculture and food production
(e.g. Living Farm project of Environmentalist association BROZ);
o
Via environmental education and support for innovation for children and young people (For Better
Future of Earth, Lifbee Academy);
–
Commitment to cultural development: Via the VUB Foundation and partnerships, the Group aims to enhance
the regions by protecting and promoting the artistic and cultural heritage of the country by individual grant
programmes and awards;
–
Promotion of innovation: Targeted actions both within the Group and by supporting companies through
acceleration and innovation projects, revamping of IT infrastructure, and improving both its digital channels and
physical branches;
–
Promotion of sustainable practices: Pursuit of the ISP Group's climate strategy and commitment to Net Zero by
reduction of carbon footprint and promotion of energy efﬁciency and the use of renewable energy within the
own operations, renovation of branches and properties to align with sustainability objectives, implementation
of green procurement practices including environmental and social criteria, training of own workforce to
enhance their sustainability knowledge and skills; the Group also aims to reduce emissions associated with its
products and services, including loan portfolio;
–
Improvement of ESG Governance maturity: Focus on proper management of new risks and transparent
reporting; the Group is gradually adopting an advanced risk management approach, emphasizing the
identiﬁcation, measurement, monitoring, control, and mitigation of ESG risks;
–
Supporting clients in green transition: A central pillar of this strategy is to address the signiﬁcant future ﬁnancing
needs associated with the green transition by expanding green ﬁnancing to help individuals and companies
move toward more sustainable practices. This is achieved through incentivized solutions with favourable pricing
and conditions, tailored advisory services, sustainable investment opportunities, and by strengthening the
ESG
‑
focused offering within asset management.
The VUB Group's commitment to sustainability goals is reinforced by its product and service portfolio, contributing
to common goals of the ISP Group and pursuit of emission reductions. The support for green transition is therefore
extended across all types of customers:
–
Retail and SME/corporate customers through sustainable credit offers;
–
In the ﬁeld of asset management, through pursuit of provision of sustainable investment opportunities via
Eurizon and VUB Generali DSS.
For retail clients in Slovakia, for the achievement of the identiﬁed objectives of the Strategy, a particular focus is
placed on facilitating the VUB Group sustainable housing practices through the provision of mortgages and loans
speciﬁcally designed to ﬁnance the renovation and improvement of real estate assets, which are considered the
biggest single source of GHG emissions.
As part of its commitment to sustainable credit provision, the VUB Group Strategy also prioritizes the circular
economy among other environmental objectives. It supports businesses in Slovakia, the Czech Republic, and beyond
by promoting and ﬁnancing this model through the VUB TERRA product line. This product line is available to
corporate clients, including municipalities, to facilitate the transition to a more sustainable economy. VUB TERRA
ESRS 2 – General disclosures
249
product line also covers support of social objectives (e.g. when voluntary work or charitable donations are realized)
and governance objectives (e.g. through commitment to development of corporate programs to increase care for
employees). The range of ﬁnancial products and services is constantly evolving and diversiﬁed based on market
research and feedback received from customers and other stakeholders (i.e. non-government organizations) and by
adapting the proposal to their needs and preferences.
Details about these activities are discussed further with their objectives in the following chapters under the speciﬁc
ESRS standards.
Business model
The VUB Group has adopted a business model that combines sustainable revenue generation focused on interest
revenues and growth in fees and service revenues, high efﬁciency and a low risk proﬁle.
The VUB Group's activities contribute to the creation of value for customers and include the main processes of
banking and ﬁnancial services delivery:
Activity Area
Description
Management of Financial
Resources
Management of customer deposits, capital, and market-raised funds to ensure liquidity and capital
adequacy.
Provision of Financial Services
Delivery of core banking products: accounts, loans, mortgages, advisory, private and corporate banking.
Service Distribution
Management
Management of physical and digital service channels (branches, mobile/online banking, ATMs), with focus
on digital efficiency.
Marketing and Sales
Promotional and branding strategies, customer acquisition, personalised product offers (loans, cards,
insurance, investment funds).
After-sales Services
Ongoing customer support, relationship management via branches, personal bankers, and digital
interfaces.
The VUB Group's activities are divided into the following Business Units and subsidiaries:
Business Unit
Focus Area
Retail Business Unit
Banking services for individuals and small businesses, including private banking.
Corporate Business
Unit
Medium/long-term partner for companies, institutions, and public sector; operates in Slovakia and Czech Republic.
Services: corporate, investment, structured finance.
Treasury Business
Unit
Liquidity (ALM) and trading operations for financial markets.
Workout Business
Unit
Management and consolidation of non-performing loans.
Governance Business
Unit
Oversees unallocated items (e.g. fixed assets, equity), and internal governance functions.
Based on the comparison with main peers (e.g. ﬁnancial statements, disclosures) and data regularly published by the
National Bank of Slovakia, the VUB Group is the market leader in lending to corporate clients, while in the retail
segment, the Group is number two. Also, with respect to mortgages, VUB occupies second position. VUB has
developed a strong base in the corporate banking area especially towards small-medium size companies and big
national and international companies operating in the Czech and Slovak markets.
Overall, the Group offers primarily:
1.
Different types of loans (mortgage, consumer loans, instalment sales and ﬁnancial leasing);
2.
Deposits (retail and corporate) and payment management;
3.
Electronic banking solutions;
4.
Business advisory services;
5.
Corporate ﬁnancing;
6.
Investment services;
7.
Insurance intermediation.
Via VUB Generali, DSS subsidiary pension savings are provided, while VUB Operating Leasing provides operative
leasing services. Being a member of the ISP Group, it is also a privileged partner of Italian companies and international
corporations providing assistance in investments, commercial and ﬁnancial transactions in Slovakia and the Czech
Republic.
The VUB Group provides its products and services through a wide network of business locations across Slovakia and
Czech Republic, including 121 retail branches, 30 corporate branches (2024: 123 retail, 30 corporate) designed to
serve small and medium-sized businesses, including the corporate branch in Prague.
The VUB Group's most signiﬁcant customer categories are:
–
Retail customers: individuals, households, small businesses (approximately 1.2 million retail customers);
–
Corporate customers: companies with more complex ﬁnancial needs, including both SME & Corporate Customer
Desk Divisions, public sector and institutions (approximately 113 thousand corporate customers).
ESRS 2 – General disclosures
250
VUB Bank is the second-largest bank in Slovakia by assets, holding a market share of approximately 20%, with a
similar distribution across all sectors. The market is covered across all customer segments.
These customer groups and market activities are directly reﬂected in the total revenue reported in the Consolidated
statement of proﬁt or loss on page 42 of the Annual Report, which captures the income generated across all
segments and business locations.
The governance areas contribute to the efﬁciency and quality of business activities, ensuring that the VUB Group
has the necessary resources to operate successfully in the following areas:
–
Corporate governance: includes all direction, management and control activities, strategic planning, risk
management and compliance. The VUB Group invests in a solid control and risk management structure in
compliance with current regulations and to minimize operational risks;
–
Human resources management: includes the hiring, training and development of personnel, with a focus on
digital skills and the ability to manage an increasingly demanding customer base. The VUB Group places great
importance on corporate welfare, continuous training and initiatives aimed at the well-being of the VUB Group's
people improving their satisfaction and loyalty;
–
Technological development: includes innovation and the implementation of new technologies, with investments
in digital platforms, artiﬁcial intelligence, robotic process automation and advanced data analysis tools and
methods. The VUB Group is accelerating its digitalization process to improve operational efﬁciency and customer
experience;
–
Procurement: involves the purchase of goods and services necessary for the VUB Group’s operations, including
technology, software, external consultancy and property management. This support ensures that the VUB Group
has the tools and resources needed to operate effectively.
The VUB Group obtains the ﬁnancial resources needed for the provision of its products and services through a
combination of internal and external sources. The main ways in which the VUB Group raises funding and capital are:
–
Customer deposits: These represent the primary source of liquidity, in the form of current accounts and term
deposits from Retail and Corporate customers;
–
Short-term funding: This largely consists of repo operations funding on wholesale markets;
–
Medium/long-term funding: This mainly consists of own issues on wholesale markets;
–
Interbank loans: These represent loans from other banks in the interbank market;
–
Financing from the European Central Bank (ECB): Forms of reﬁnancing by the ECB that the VUB Bank can resort
to in particular circumstances. These loans are granted at relatively low interest rates, especially in periods of
economic crisis or to stimulate the economy;
–
Equity capital: Differs from other forms of ﬁnancing and constitutes an essential component for the ﬁnancial
solidity and ﬁnancing capacity of the VUB Group, since it offers security against possible losses and reassures
creditors and investors of the solvency of the institution.
The VUB Group is not active in the following sectors: fossil fuels, chemical manufacturing, controversial weapons,
tobacco cultivation or production.
Furthermore, with reference to the exposures in the Group's portfolios, speciﬁc internal regulations are in place to
enforce stringent exclusion criteria for counterparties active in ESG-sensitive business sectors, including:
–
The coal mining, and oil & gas sectors, where stricter rules aim at phasing out exposure for coal mining, for
which the VUB Group has formalized its own rules for credit operations and Guidelines for the Governance of
environmental, social and governance (ESG) risks (for more details see standard ESRS E1 – Climate change,
section Policies related to climate change mitigation and adaptation);
–
The production and trade in arms sector, for which the Intesa Sanpaolo Group has equipped itself with
Guidelines governing transactions with subjects active in the armaments sector, which formulate the express
prohibition of carrying out any type of banking and/or ﬁnancing activity connected with the production and/or
marketing of controversial and/or banned weapons by international treaties, such as: nuclear, biological and
chemical weapons; cluster and fragmentation bombs; weapons containing depleted uranium; anti-personnel
landmines.
ESRS 2 – General disclosures
251
Value chain
The VUB Group's value chain consists of a set of activities broken down into interconnected processes, as detailed
below.
Regarding the upstream value chain, the main expenditure categories subject to centralized (at Parent Company
level) and decentralized (at the VUB Group level) procurement include:
Category
Products and Services Included
Information and communication
technology
Computer hardware, maintenance thereof and system licenses.
Real estate
Rent, furniture and furnishings, building maintenance and cleaning contracts.
Advertising and other public relations
expenses
Internal and multimedia communication services, entertainment events and sponsorship of sports,
or non-profit organisations.
Physical security
Installation of security systems, purchase of safes, alarm units and purchase of surveillance
equipment, security and surveillance services.
Office equipment
Purchase of office equipment and machines, IT consumables, stationery and office supplies,
purchase of audiovisual equipment.
Insurance
Employee benefits insurance, property insurance and general liability insurance.
With reference to the downstream value chain, the VUB Group distribution model is based on a multi-channel
approach, which combines the physical network of branches with advanced digital tools to streamline provision of
ﬁnancial and non-ﬁnancial services. In particular, the distribution model is structured as follows:
Channel
Description
Network of
Branches
The VUB Group has a vast network of branches primarily across Slovakia, which allows it to reach a diversified clientele.
The physical presence allows the Bank to offer personalized services and specialized advice on site. The branches are
structured to respond to different types of customers, such as Retail (individuals, Magnifica – devoted to affluent clients
and personal financial services and small businesses), Corporate (SME companies).
Digital Branch
Allows clients to access the Bank's services and products through voice interactions. It provides information via email or
chat as well. Non-clients of the Bank are provided with general information. The digital branch offers a wide range of
services related to accounts, payment cards, or electronic banking services. Through the digital branch, clients also have
access to a wide portfolio of remotely sold products such as deposit, loan products or investments. Customers can
handle their requests conveniently from home or any location, eliminating the need for a physical branch visit.
Internet and
Mobile Banking
These tools allow customers to manage banking transactions such as wire transfers, payments, account monitoring, and
investments, directly from their computer or smartphone. These services are designed for those who want autonomy in
managing their finances.
Partnership &
Service
Integration
The distribution model is completed with a series of strategic partnerships that expand VUB Group's offering. Thanks to
these collaborations, the Bank can offer a complete range of financial solutions, from the simplest to more complex
products for a sophisticated clientele.
Through the aforementioned channels, the VUB Group serves a diversiﬁed customer base, which includes private
individuals, families, SMEs, large corporations, municipalities and institutions. For private customers and families, the
VUB Group offers a wide range of products and services, ranging from current accounts to loans, mortgages, to
savings and investment solutions. SMEs are supported through specialized ﬁnancial services, such as ﬁnancing,
consulting and payment instruments. Large corporations and institutions, on the other hand, beneﬁt from a
comprehensive corporate banking offer, investment services, treasury management and solutions for international
trade, consolidating the role of VUB as a reference partner in every economic sector.
Performance
The VUB Group's solid performance enables the creation of growing and sustainable value for all stakeholders.
During the reporting year 2025, the Group generated a net proﬁt of EUR 270.1 million, thanks to which the Group's
shareholders accrued EUR 126 million in cash dividends, of which a large share went directly to the families and
foundations.
Staff expenses amount to EUR 164 million. In 2025, the public sector beneﬁted from 166.3 million in taxes (income
tax and special bank levy), down by 6.7 million compared to 2024. Medium- and long-term loans amounting to EUR
21.8 billion were disbursed to households and businesses. In 2025 the VUB Group served 1.23 million consumer
customers (households and sole traders) and 139.7 thousand companies.
2025
2024
Staff expenses amount (mil. EUR)
164
162
income tax and special bank levy (min. EUR)
166.3
172.9
Medium- and long-term loans (mil. EUR)
21.8
20.8
No. of customers served (households and sole traders) (mil.)
1.23
1.2
No. of customers served (companies) (mil.)
139.7
112.8
As regards the main results in the ESG sphere, the VUB Group maintained a high commitment to the green transition
through the disbursement of EUR 599.2 million in new environmentally sustainable loans to individuals and 187.4
ESRS 2 – General disclosures
252
million to corporate clients. The Bank provided additional support by providing EUR 182.7 million in new socially
sustainable loans to individuals and EUR 240.8 million in new loans to corporate clients across other sustainable
categories. In addition, the improvement of the ESG asset management product offering continued, and the sales
of funds, that meet the characteristics of environmental, social and sustainable objectives classiﬁed according to
Articles 8 and 9 of the SFDR reached 38% of total gross sales.
Finally, the VUB Bank has been recognized as the Top Employer Slovakia 2025
3
.
Double materiality assessment
Methodology and rationale
The VUB Group has conducted a reassessment of the main relevant sustainability matters, taking into account the
impacts, both positive and negative, actual or potential, deriving from its activities on the economy, the environment,
and people. The assessment of impacts includes the effects on human rights, and particular attention is given to
impacts that may signiﬁcantly inﬂuence stakeholder perception. In addition, the risks and opportunities that have,
or are expected to have, material ﬁnancial effects on the VUB Group are assessed. The outcomes of this practice are
vital not only for sustainability reporting but also for guiding the Group’s strategy on issues important to the business
and its stakeholders.
The double materiality assessment conducted by the VUB Group in 2025 is based on the ESRS requirements, EFRAG
implementation guidance, as well as relevant technical clariﬁcations provided by the regulator, and is fully aligned
with the ISP Group methodological approach to guarantee consistency and quality of outcomes at Group level.
In 2025, the assessment was re-evaluated and more closely aligned with the double materiality assessment of the
parent company, while retaining sufﬁcient ﬂexibility to reﬂect VUB-speciﬁc business characteristics and to support
independent decision-making where relevant. The principles, processes, and methodological guidelines governing
the development of CSRD reporting, including the double materiality assessment, are deﬁned within the Bank’s
internal documentation, in particular in the Guidelines for the Preparation of Consolidated Sustainability Reporting
pursuant to the Amendment to the Act on Accounting No. 105/2024 Coll. of 1 June 2024.
The approach set out by the ESRS integrates the concept of double materiality, which considers both the impacts of
the VUB Group’s activities (impact materiality) and the related ﬁnancial implications (ﬁnancial materiality).
Speciﬁcally:
Materiality Type
Perspective
Description
Impact Materiality
Inside-Out
Impacts: VUB Group's impacts associated with its own operations and the
relevant value chain in its entirety – upstream and downstream, including
both positive and negative, current and potential impacts
Financial Materiality
Outside-In
Sustainability matters that generate:
Risks: Affect or may affect the Group’s development, financial position,
economic performance, cash flows, access to finance, or cost of capital in the
short, medium, or long term
Opportunities: Have, or are expected to have, significant financial influence
for the Group in the short, medium, or long term
The VUB Group applied both dimensions in order to identify and assess material impacts, risks and opportunities,
also referred to as material IROs, which served as the basis for the selection of disclosures published in this Report.
The VUB Group conducted the double materiality assessment, considering and enhancing the peculiarities of the
business lines and geographies in which it operates and in which the counterparties with which the Group has
business relationships operate. The type of suppliers and counterparties is yet another element considered in the
analysis and assessment phase.
The identiﬁcation of IROs followed a phased approach, including:
–
Mapping of the VUB Group's stakeholders; extending the list compared to the previous disclosure
–
Context analysis aimed at mapping of the actual and potential positive and negative impacts on the economy,
the environment and people, including human rights, generated by the activities of the Group, as well as the
risks and opportunities generated by the external environment, based on the analysis of various sources,
primarily:
o
Commitments, projects and activities carried out by the Group in the ESG ﬁeld, including business
strategy, strategic projects, as well as speciﬁc ESG initiatives and policies;
o
National and international regulation in ESG context;
o
Documentation relevant to the sector in which the Bank operates;
3
Top Employers Institute.
ESRS 2 – General disclosures
253
o
Public documents of the national and international scientiﬁc and professional studies, reports, and
publications;
o
Public registries and databases;
–
Identiﬁcation of the IROs with reference to Topics listed in the regulation to be further investigated because of
its potential relevance for the VUB Group.
–
The assessment of such IROs was then carried out through:
–
An internal assessment, involving the relevant specialists across the bank, based on criteria aligned with the ESRS
reporting standards and consistent with the Group’s current risk management process. According to these
criteria, the identiﬁed thresholds exclude materiality for IROs where either the probability or the
signiﬁcance/magnitude is considered not relevant.
–
The stakeholder engagement, i.e. the involvement of views, expectations and opinions of the VUB Group's
stakeholders collected through various activities;
–
The identiﬁcation of sustainability matters material to the Group on the basis of the aggregation of the material
outcomes of the IROs deriving from an internal assessment and stakeholder engagement activities;
–
Validation of the list of material sustainability matters and IROs with top management and the Parent Company.
The material sustainability matters and IROs were then mapped onto topical standards with their respective disclosure
requirements (‘DRs’), including datapoints, in order to provide prescribed information to the extent that the Group
assessed such information to be material to meet the objectives of such DRs and datapoints. Additional entity-speciﬁc
disclosures were provided which were assessed as signiﬁcant to complement the understanding of the stakeholders
and general users of the Report.
Compared to the 2024 reporting period, several improvements and rationalisations were implemented, including
alignment, where applicable, with the parent company’s process and approach.
The main changes are:
IROs aggregation
–
alignment of IROs with parent company;
–
relevance of IROs (e.g. if an IRO is similar or the same as industry standard or legal requirements);
–
aggregation (similar topics are now described under single IRO);
–
IROs were reevaluated based on peer review or other relevant information (e.g. some Risks are currently difﬁcult
to measure).
Integration of severity priority over probability within the materiality calculation:
–
Ensures that serious human-rights risks are never ignored because they seem ‘unlikely’.
The re-evaluation of IROs with the integrated ‘severity priority’ did not trigger any new materiality within the existing
package of IROs.
The approach towards double materiality assessment will be updated annually and reviewed based on business and
regulatory changes.
Engaging with the VUB Group's stakeholders
Based on the ESRS and related implementation guidance, the acquirement of the interests and views of stakeholders
during the process of double materiality assessment can build upon the regular dialogue, while addressing
stakeholders speciﬁcally for the purpose of sustainability reporting is possible. Next to this combined approach, the
VUB Group built also on the principles of behaviour in relation to individual categories of stakeholders set in the
Group Code of Ethics (listening and dialogue, transparency, equality and inclusion). The VUB Group considers
stakeholder engagement a fundamental aspect of responsible business conduct, maintaining an ongoing dialogue
to assess risks, identify opportunities, and strengthen trust with those impacted by its operations.
In 2025, the stakeholder engagement process was further expanded and formalised.
An expanded questionnaire was developed covering all topics under the CSRD/ESRS framework.
External stakeholders were engaged through an online questionnaire covering all ESRS Standards. (S1 – Own
Operations was developed independently in the employee questionnaire).
Internal stakeholders (employees of the VUB Group) were engaged through a dedicated online questionnaire focused
speciﬁcally on S1 – Own Operations. In addition, an internal feedback questionnaire was conducted to review the
2024 reporting period and gather insights on areas for improvement in the 2025 reporting period.
The VUB Group also presented the 2024 sustainability report to employee union representatives. During this
presentation, the report was explained in detail, and the representatives were informed about their opportunity to
provide feedback during each iteration of the reporting process.
ESRS 2 – General disclosures
254
To support the robustness and comparability of the DMA results, benchmarking exercises were conducted. A local
benchmark was performed based on reports presented by sector peers and the parent company. Speciﬁc data points
were also benchmarked against a broader international pool of companies. Furthermore, benchmarking based on
ﬁrst-wave CSRD/ESRS disclosures was carried out to review DMA results within the banking sector as well as within
a larger cohort of ﬁrst wave reporting companies.
Through this structured engagement and benchmarking approach, stakeholder input was incorporated into the
reporting process.
In this context, the presented stakeholder map outlines the VUB Group's stakeholders, aligned with the ISP Group
approach. VUB regularly engages with these stakeholders by different means in order to identify and monitor their
needs and perspectives in relation to the areas of impact, risk and opportunity that they consider priorities.
Category
Stakeholders
Employees
VUB Group Employees
Trade Unions
Clients
Retail and household customers
Entrepreneurs
Small and medium-sized enterprises
Large Companies
Developers
Consumer associations
Public authorities
Municipalities
Professional associations
Shareholders
Investors
Parent company
Institutional Investors
Multinational organizations
Suppliers
Small- and large-scale suppliers
Intermediaries
Environment
Environmental organizations
Future generations
Scientific community
Community
Industry associations
Regulators
Tertiary sector
National and international public institutions
Media
During the execution of the double materiality assessment, the VUB Group used the following stakeholder
engagement approach:
–
Involvement of the VUB Group's dedicated internal structures that maintain a constant and continuous dialogue
with the stakeholders concerned, in the context of mapping and assessing the relevance of impacts, risks and
opportunities;
–
Direct involvement of speciﬁc stakeholders, through dedicated workshops, interviews and questionnaires.
Stakeholder categories, represented in the map above, were engaged to identify and assess the relevance of IROs
associated with sustainability matters closest to their experience, knowledge and sensitivity. This enabled
stakeholders to deepen their understanding of the VUB Group's processes and strategies related to the sustainability
issues most relevant to them, while also sharing their own perspectives.
The results of the stakeholder engagement process are systematically analysed by the ESG Department and
integrated into the double materiality assessment (DMA), ensuring that stakeholder perspectives are duly reﬂected
in the identiﬁcation and evaluation of impacts, risks, and opportunities.
Additionally for 2025, the total response rate was extended to new subgroups (e.g. the parent company, non-
governmental organizations, scientiﬁc community and trade unions).
ESRS 2 – General disclosures
255
The following table shows the stakeholder engagement activities included as part of the double materiality
assessment, divided by individual categories, for the collection of related inputs/feedback:
Category
Stakeholders
Listening Mode
Summary of topics covered
Employees
VUB Group
employees
Interviews with internal HR structures
Participation in the survey aimed at
listening to the opinions and needs of
the ISP Group's employees through
the provision of internal climate
survey questionnaires and questions
on sustainability issues (2.465
employees of VUB Group
participated)
VUB Employee Survey
Assessment of the perception of the ISP and Group's
image from the customers' point of view, based on
individual professional experiences.
Attention and care for employment levels in restructuring
processes.
Recruitment of young people.
Assessment of variables related to staff development (e.g.
sense of pride and belonging, appreciation of merit,
autonomy and economic rewards).
Talent development and retention.
Evaluation of training and professional development
opportunities offered by the ISP and the VUB Group.
Employee well-being (flexibility and work-life balance,
relations with colleagues and managers).
Job satisfaction of the ISP and VUB Group's employees.
Assessment of the transparency and objectivity of
performance appraisal systems.
Assessment and knowledge of ISP and VUB Group policies
(e.g. Diversity and Inclusion).
Assessment of customer satisfaction on aspects such as
reliability, transparency and clarity of ISP and VUB Group
procedures
ISP and VUB Group ESG initiatives and products.
Customers
Retail customers
Execution of a dedicated survey
devoted to the sustainability topics on
a representative sample of population
of Slovak republic and involvement of
the Retail banking Division in DMA
process
Importance of sustainability activities of companies in
these areas:
Environmental Conservation
Sustainable Practices
Education and Community Support
Energy and Emissions
Corporate Responsibility and Investment
Corporate
customers
Execution of a dedicated
questionnaire survey ‘ESG Pulse
Check’ among 780 SME and
Corporate customers and involvement
of the Corporate and SME Division in
DMA process
Topics surveyed
General interest in ESG:
Relevance of ESG issues for your business model.
Production of sustainability reports.
Methods of offsetting carbon emissions.
Relevance of specific areas for business:
Importance of areas like renewable energy, energy
efficiency, pollution prevention, biodiversity preservation,
green mobility, and more.
Interest in Environmental issues:
Relevance of energy transition, zero-emissions mobility,
biodiversity protection, and green building investments.
Interest in investing in renewable energy solutions, zero-
emissions mobility projects, biodiversity preservation, and
green building retrofitting.
Interest in Social and Governance issues:
Interest in social/community activities and sustainable
governance practices.
Services needed to support the transition to a sustainable
business model.
Other
Stakeholders
Trade unions
Industry
associations
Clients
(Developers)
Tertiary sector
Intermediaries
Suppliers
Institutional
Investors
Multinational
organizations
Execution of a dedicated
questionnaire survey and involvement
of the internal functions responsible
for contact with these stakeholders in
DMA process
Importance of the sustainability sub-sub-topics and
subtopics for the stakeholder.
Expectations of the stakeholder from the VUB Group in
each sub-sub-topic of ESRS standards.
ESRS 2 – General disclosures
256
As the primary outcome, the stakeholder engagement enriched the Group's internal assessment. Speciﬁcally, the
dialogue has:
–
Conﬁrmed material matters: stakeholder feedback has helped to validate some of the VUB Group's internally
identiﬁed material sustainability matters, reinforcing its focus on key areas like climate change, social inclusion,
and ethical business practices;
–
Provided new insights: stakeholder input offered new perspectives on existing matters;
–
reﬁned topic relevance: stakeholder input helped prioritize matters, but eventually did not lead to override or
change of evaluation;
–
Strengthened double materiality: integrated stakeholder insights and internal assessment resulted in a more
robust double materiality assessment, informing decision-making and strategic planning.
Because the VUB Group adopts the strategic and business approach from the ISP Group, the Parent Company is the
most critical stakeholder concerning the inﬂuence over these. However, another great inﬂuence comes from the
VUB Group employees taking part in regular surveys, and institutional investors due to ﬁnancial incentives. While
the other key stakeholders may not be engaging with the VUB Group at the level of its Strategy and business
planning, their interests and views provide a valuable input to both of them, as well as to policies and decision-
making processes, to prevent or address signiﬁcant material impacts, that may occur towards such stakeholders.
Employee feedback directly informs human resources policies, leading to initiatives that enhance workplace
satisfaction, well-being, and professional development. Regular interactions with affected communities guide the
VUB Group’s investment decisions, ensuring that ﬁnancial support is directed toward projects with the highest social
and environmental impact. Consumer engagement helps reﬁne customer protection policies, privacy and security,
promoting ethical banking practices and responsible ﬁnancial services. The Group gathers insights through surveys
and market research to reﬁne product offerings and improve digital banking experiences.
The administrative, management, and supervisory bodies receive the views and interests of affected stakeholders on
the VUB Group’s sustainability-related impacts through a multifaceted approach. The VUB Group conducts surveys
targeted at selected clients to gather insights into its sustainability-related impacts. These surveys are designed to
capture detailed feedback on how the VUB Group’s operations inﬂuence environmental and social dimensions. The
VUB Group also actively organizes and participates in events focused on sustainability. During these events, the VUB
Group facilitates dialogues with both employees and clients to understand their perspectives and concerns related
to sustainability. In addition, the VUB Group evaluates ESG opinions from the relevant rating agencies, available
certiﬁcations, and maintains an ongoing dialogue with the ﬁnancial regulator. The feedback obtained through these
initiatives is highly valued and is used to inform decision-making processes at all levels of governance.
Context analysis
For the purpose of mapping IROs, the VUB Group analysed the context in which it deﬁnes and implements its
business activities and relationships. In particular, the following elements were taken into consideration:
–
External documentary sources for the purpose of conducting an analysis of the reference context including
documents and frameworks in the ﬁeld of Human Rights (UN Guiding Principles on Business and Human Rights,
the Proposal for a Directive of the European Parliament and of the Council on corporate sustainability due
diligence and amending Directive (EU) 2019/1937 (i.e. the CSDDD, Directive (EU) 2024/1760 of the European
Parliament and of the Council of 13 June 2024 on corporate sustainability due diligence) and additional
reference regulations referred to in the ESRS Standards (EU Regulation 2019/2088 – ‘SFDR’, Regulation (EU) No.
575/2013 – ‘Pillar III’, Regulation (EU) 2016/1011 – ‘Benchmark Regulation’, Regulation (EU) 2021/1119 – ‘EU
Climate Law’), Omnibus Simpliﬁcation Package (2025) & Stop
‑
the
‑
Clock Directive (2025);
–
External documentary sources for the purpose of conducting an analysis of current trends in the banking and
insurance sector, including the Supervisory Expectations of the European Central Bank, the Recommendations
of the Task Force on Climate-related Financial Disclosures, Principles for Responsible Banking, the accounting
standards (IFRS) for ﬁnancial reporting related to sustainability, EBA Guidelines on the management of
Environmental, Social and Governance (ESG) risks;
–
Detailed scan of scientiﬁc and professional studies, reports, and publications both national and international;
–
Internal documentary sources, including the updated Business Strategy, the Code of Ethics, Parent Company
guidelines and Business Plan, public commitments, Consolidated Sustainability Reports prepared in accordance
with the CSRD, the Consolidated Non-Financial Statements published by the ISP Group on a consolidated basis
over the previous years (with the VUB Group contributing, but being exempt from separate reporting), the
Financial Statements, communications from top management and company policies, also in order to identify
how impacts relate to the company's strategy and model;
–
detailed analyses (benchmarks) carried out on the disclosure of the main players in the banking and other sectors,
in relation to the material topics, the relevant stakeholders and the methods adopted for the representation of
the relevant outcomes (Sustainability Report according to CSRD and further public documentation of other
ESRS 2 – General disclosures
257
national and international ﬁnancial and non-ﬁnancial groups), in order to ensure full transparency and
compliance of the Group with respect to the market practice and expectations;
–
Feedback/input deriving from the involvement of the Group's stakeholders.
Consistently with the regulatory requirements, the double materiality assessment was performed at the perimeter
of own operations and for the upstream and downstream value chain.
Identiﬁcation of impacts, risks and opportunities
The analysis conducted led to the identiﬁcation of the Group's possible IROs for each ESRS standard, at the perimeter
of its own operations and value chain. Impact materiality and ﬁnancial materiality are interconnected and
methodologically were conducted concurrently.
The VUB Group's impacts on people or the environment are identiﬁed in consideration of the speciﬁcs of the VUB
Group's operating and business model, management decisions made to address these impacts and based on internal
assessment and due diligence processes. Impacts on the VUB Group other than sustainability matters in the external
context may give rise to risks and opportunities.
Risks and opportunities are identiﬁed from the impacts, dependencies and sustainability issues that have or could
have ﬁnancial effects on the VUB Group. By way of example:
–
Financing / investing in sectors/countries that are not very virtuous from an ESG perspective could lead to Credit,
Market Risk deriving from the high concentration in high-risk territories/environments with respect to the
sustainability matter under investigation;
–
The establishment of ESG initiatives, donations, programmes, ESG safeguards by the VUB Group could
contribute to the improvement of the VUB Group's brand reputation and/or the increase of stakeholders' trust;
–
The deﬁnition of speciﬁc ESG criteria, investment and/or ﬁnancing strategies could contribute to the expansion
of the product range through alignment with sustainability objectives.
Assessment of the materiality of IROs
The materiality assessment of IROs was conducted through an internal assessment based on criteria aligned with the
ESRS, shared and consolidated through interviews with the Group's internal operating structures and, as depicted
above, through a stakeholder engagement process.
The methodology used has been formalized in internal documentation.
For the purposes of assessing and prioritizing impacts on people and the environment, the internal assessment was
carried out on the basis of the criteria described below, with each parameter evaluated on a scale from 1 to 5, where
1 represents the lowest value and 5 represents the highest value.
Parameter
Definition
Score = 1
Score = 5
Scale
Magnitude of the impact
Very Low
Very High
Scope
Spatial extent or spread of the impact
Highly
Localised
Global
Irremediable
Character
Degree to which the impact can be avoided or reversed (particularly for
negative impacts)
Very Low
Very High
Likelihood
Probability of the impact occurring (for potential impacts)
Very Unlikely
Extremely
Likely
This year, a formal Severity measure was introduced to strengthen impact assessment.
Severity combines Scale, Scope and Irremediability and reﬂects how serious the consequences would be. It is
calculated as the average of these three factors, resulting in a score from 1 (low) to 5 (very high).
–
For actual impacts, Severity determines materiality.
–
For potential impacts, it is multiplied by Probability to estimate risk.
In line with ESRS 1 §45 and GRI 2021, Severity takes precedence over Likelihood. High Severity can trigger materiality
automatically, while Severity ≤ 3 results in ‘not material’, regardless of Probability.
The impact assessment activity was carried out considering the Group's business speciﬁcities. In particular, with
reference to the downstream value chain, the sectors in which the counterparties most exposed to a risk of adverse
impact were identiﬁed for each sustainability matter.
ESRS 2 – General disclosures
258
The materiality of the impacts is given by exceeding a certain threshold of signiﬁcance, calculated as the average of
the scores attributed to the metrics of scale, scope and irremediable nature. In particular, the materiality of:
Impact Type
Nature
Determination Method
Actual impact
Positive
Average of the ratings attributed to the metrics of scale and scope
Actual impact
Negative
Average of the ratings attributed to the metrics of scale, scope and irremediable character
Potential impact
Positive
Product of the likelihood and the average of the scores attributed to scale and scope
Potential impact
Negative
Product of the likelihood and the average of the scores attributed to scale, scope and irremediable character
In the case of potential negative impacts on human rights, the severity of the impact (scale, scope and irremediable
character) takes on greater importance than likelihood.
Severity combines Scale, Scope and Irremediability and reﬂects how serious the consequences would be. It is
calculated as the average of these three factors, resulting in a score from 1 (low) to 5 (very high).
–
For actual impacts, Severity determines materiality.
–
For potential impacts, it is multiplied by Probability to estimate risk.
The individual impacts identiﬁed by the Group are assigned a score based on the criteria described above, where the
highest score represents the greatest beneﬁt generated in the case of positive impacts, or the greatest harm
generated in the case of negative impacts.
Following the assessment carried out, the VUB Group has signiﬁcant impacts, as speciﬁed and illustrated in the
chapters dedicated to each individual ESRS standard, both through direct activities (own operations perimeter) and
through business relationships (upstream and downstream value chain perimeter).
In particular, with reference to the perimeters of own operations and upstream value chain, the relevant impacts
affect people or the environment as a result of the initiatives implemented or planned (with reference to positive
impacts) and the negative effects arising from operations (with reference to negative impacts). On the other hand,
with reference to the downstream value chain perimeter, this impact is determined by the exposure of the ﬁnancing
and investment portfolio to sectors or countries that may in turn impact people and/or the environment.
Each of the impacts, risks and opportunities was assessed on the basis of qualitative and quantitative information,
also considering what emerged from the context analysis and the stakeholder engagement process.
In the case of using a quantitative approach, the process involved the identiﬁcation of accounting/reporting data,
i.e. ﬁnancial/accounting information (e.g. costs, revenues, assets) deriving from the VUB Group's main ﬁnancial
statements; data used in consolidated internal processes, underlying the production of external or internal reporting
(e.g. risk data, projections); and data of managerial nature derived from consolidated processes.
In particular:
–
Risks were assessed in compliance and alignment with the Group's current risk management process, using,
where possible, analyses and metrics already existing within the Group (e.g. analysis of the materiality of
environmental, social and governance risks compared to traditional, prudential risks in the ﬁnancial sector);
–
Opportunities were assessed on the basis of safeguards, policies, targets deﬁned by the VUB Group, as well as
the possibility of expanding the reference clientele through the development of products aligned with
sustainability objectives. The indicators deﬁned in the VUB Group's budget document and business plan were
valued (e.g. budget allocated and dedicated to the provision of virtuous products from an ESG point of view).
In the case of the qualitative approach, the assessment of relevance was conducted on the basis of analyses aimed
at enhancing the internal initiatives, policies and strategies prepared by the VUB Group, including, by way of
example, what was formalised in the Intesa Sanpaolo Group 2022-2025 Business Plan.
For the purposes of the assessment of ﬁnancial materiality, the current ﬁnancial effects of the VUB Group's material
risks and opportunities have been assessed, consistently with the relevant regulations, considering exposures in terms
of assets and possible ﬁnancial losses and current or prospective revenues, according to approaches consistent with
the highest level of granularity available and with the estimates and assessments made by the VUB Group as part of
its ordinary business planning and risk analysis activities.
The assessment of ﬁnancial materiality is carried out at the same time as the assessment of impact materiality,
identifying possible elements of interaction and connection.
In particular, the ﬁnancial effects of risks are assessed by considering the VUB Group's exposure to counterparties in
its portfolio and ﬁnancial entities issuing debt securities and other forms of ﬁnancial assets that belong to sectors
and countries potentially exposed to ESG risk factors. The impact, in terms of operational losses, resulting from
inadequate operational processes of the VUB Group, including assets, resources and relationships that are part of
the VUB Group's own operations, or from potential sanctions or sanctions suffered with reference to sustainability
matters was also analysed.
ESRS 2 – General disclosures
259
The assessments performed, as required by the regulations, were conducted taking into account the inherent risk
logic, i.e. without considering potential risk prevention or containment mechanisms that the VUB Group has in any
way put in place.
The ﬁnancial effects of the opportunities were taken into consideration by assessing the current and prospective
ﬁnancial effects deriving from the provision of speciﬁc products within the topics investigated. The process of
identifying and assessing them is aligned with the indicators deﬁned in the VUB Group's budget and Strategy, with
regard to the provision of ESG related products.
Consistently with the Guidelines
4
, elements of both a qualitative nature were considered, through the involvement
of the various VUB Group structures, and of a quantitative nature, using, where possible, methodologies, safeguards
and metrics already existing within the VUB Group (e.g. in the context of risk materiality assessment). These analyses
were supplemented, where deemed necessary, by additional assessments in order to meet the regulatory
requirements for sustainability matters of reference.
In particular:
–
The risks identiﬁed have been assessed in accordance with and aligned with the VUB Group's current monitoring
system and current regulations.
–
Each typical risk (e.g. Credit Risk, Market Risk, Liquidity Risk, Operational Risk) of the VUB Group is broken down,
where applicable, with speciﬁc reference to the sustainability issue investigated at the most granular level
possible, linking it to cases that have been the subject of speciﬁc elaboration;
–
Opportunities were assessed considering the ESG initiatives, policies and strategies deﬁned by the Group. The
types of opportunities identiﬁed, as detailed below, are: (i) expanding the product range and customer portfolio,
(ii) improving brand reputation and increasing stakeholder trust, and (iii) attracting talent.
The internal assessment was conducted on the basis of the evaluation metrics deﬁned by the ESRS reporting
standards. The evaluation was done on a Scale of 1 – 5 as described below:
Parameter
Description
Scale = 1
Scale = 5
Magnitude
Indicates the potential magnitude of the financial effects arising from risks or
opportunities
insignificant
significant
Likelihood of
occurrence
Indicates how likely it is that a financial risk or opportunity will occur
very low
very high
If a Risk or Opportunity was assessed over time horizons the Magnitude and Likelihood were
applied 3 times based on each position on the timeline
Time horizons
Analysis over
time horizons
Analyses over different time horizons are conducted in line with the prospective
estimates and developments already elaborated within the VUB Group (e.g.
ICAAP, budget planning/strategic plan) and with scenarios deriving from
external sources, adopting a prudential approach and considering that the
manifestation of ESG risk factor impacts is predominant in the medium and long
term.
Short-
Medium-
Long-term
Consolidating the list of material sustainability topics for the VUB Group
The VUB Group has established a structured decision-making process aimed at consolidating and verifying the
material impacts, risks and opportunities.
Based on the assessment carried out, a summary of the mapping of the identiﬁed IROs was drawn up, along with
the main evidence and results obtained following the execution of the double materiality exercise.
The mapping of IROs was reviewed, shared and consolidated by the VUB Group's internal ofﬁces and operating
structures, each of which examined their own competence through the aforementioned stakeholder engagement
process.
Finally, after completing the impact and ﬁnancial materiality assessment that identify the aspects relating to
environmental, social and governance sustainability that are material for the VUB Group, the list of material matters
was shared with the Parent Company and submitted to the VUB ESG Committee for approval.
The CSRD regulation deﬁnes the sustainability topics to be investigated (e.g. own workforce) by providing a granular
level of detail through the deﬁnition of sub-topics (e.g. working conditions), which delve into a speciﬁc aspect of the
same, and, where available, sub-sub-topics (e.g. adequate wages) which further detail an element of the sub-topic.
Based on the assessment conducted, all macro-themes (‘topics‘) proposed by the ESRS standards are material except
for the topics E2 – Pollution, E3 – Water and marine resources, E4 – Biodiversity, S2 – Workers in the value chain.
The topic E2 – Pollution was evaluated as Non-material for the 2025 reporting period when compared to 2024.
4
EFRAG IG 1: Materiality Assessment Implementation Guidance.
ESRS 2 – General disclosures
260
Topic
Impact Materiality
Financial Material
Positive Impacts
Negative Impacts
Risks
Opportunities
E1 – Climate change
E5 – Circular Economy
S1 – Own Workforce
S3 – Affected Communities
S4 – Consumers and end users
G1 – Business conduct
Materiality
Material
Non-Material
However, as highlighted below, not all sub-topics and sub-sub-topics are relevant.
Entity-speciﬁc disclosures primarily complement provided information on metrics and targets related to sustainable
ﬁnancing, sustainable investment products and approach towards customer. They also provide more representative
data on own workforce. These disclosures are integrated within the material ESRS standards alongside other relevant
disclosures.
A summary representation of the double materiality results is provided below, with evidence of the relevant
perimeters.
ESRS 2 – General disclosures
261
Topic
Sub-Topic
IRO Type
IRO Description
Value chain
E1 – Climate
change
Climate change
adaptation
Positive Impact
Contribution to climate change
adaptation and energy efficiency in own
operations through corporate policies and
strategies
Own
operations
Climate change
mitigation
Risk
Reputational risk arising from failure to
achieve targets set in support of climate
change mitigation (e.g. failure to achieve
targets set within the Net Zero Banking
Alliance)
Own
operations;
Downstream
value chain;
Upstream value
chain;
Opportunity
Improved brand reputation/positioning
resulting from the adequate definition
and achievement of objectives in support
of climate change mitigation (e.g.
achievement of objectives resulting from
membership of the Net Zero Banking
Alliance)
Own
operations
Risk
Credit Risk arising from the failure of
counterparty companies to define a
Transition Plan and the related inability to
meet debts (e.g. costs for counterparties
linked to a failure to define a transition
plan towards a low-emission economy)
Downstream
value chain
Negative
Impact
Contribution to climate change through
indirect greenhouse gas emissions by
individuals and companies through the
lending/financing process and portfolio
composition with reference to
counterparties considered
environmentally and socially unsound
Downstream
value chain
Positive Impact
Progressive reduction of indirect
greenhouse gas emissions through
adherence to dedicated initiatives such as
Global Compact, NZBA, the adoption of
internal financing/investment policies
involving the selection of companies that
have defined a Transition Plan
Downstream
value chain
Energy
Positive Impact
Reduction of energy consumption and
increasing use of renewable energy by
individuals/businesses (e.g. investment
criteria/strategies/financing for businesses,
including equipping themselves with
energy efficiency systems, installing solar
panels, LED light bulbs, solar thermal
collectors)
Downstream
value chain
Risk
Credit risk arising from the failure to
define energy efficiency objectives by the
counterparty companies and the related
inability to meet debts (e.g. costs for the
counterparties linked to a failure to define
an energy efficiency plan for the
operating offices)
Downstream
value chain
Negative
Impact
Direct energy consumption and non-
renewable energy use
Own
operations
E5 – Circular
Economy
Resource outflows
related to products and
services
Positive Impact
Contribution to the recycling and reuse
of materials through financing and
investments
Downstream
value chain
S1 – Own
Workforce
Equal treatment and
opportunities for all
Positive Impact
Contribution to the protection of work,
through the prevention of discrimination
and gender inequality phenomena
(including harassment) and to the
detriment of people with disabilities and
promotion of diversity in all its forms
through the adoption of policies/initiatives
Own
operations
ESRS 2 – General disclosures
262
Positive Impact
Support for training and skills
development and valorisation of the
potential and uniqueness of employees,
also through the definition of talent
management and development programs
(e.g. periodic collection of training needs
from employees through dedicated
surveys, budget dedicated to financing
dedicated training initiatives /
certifications useful for employees to
improve their skills, partnerships with
national and international universities and
business schools; collaborations with IT
and tech sector communities, often with
a focus on the female gender)
Own
operations
Opportunity
Increased trust among Group
Stakeholders (e.g. employees), through
the definition of appropriate policies
aimed at ensuring gender equality and
equal pay, the inclusion of all Group
people and the prevention of violence
and harassment in the workplace
Own
operations
Other work-related
rights
Positive Impact
Contribution to the protection of workers
through the definition of policies, union
agreements and internal systems aimed at
protecting the personal data of personnel
(including cybersecurity measures), in
order to prevent the intentional or
unintentional use of confidential
information for business purposes that
could harm employees.
Own
operations
Working conditions
Opportunity
Attracting talent through the definition
of adequate policies regarding employee
working conditions
Own
operations
Opportunity
Increased trust among Group
Stakeholders (e.g. employees), through
the definition of appropriate policies
aimed at ensuring gender equality and
equal pay, the inclusion of all Group
people and the prevention of violence
and harassment in the workplace
Own
operations
Positive Impact
Contribution to the protection of work by
guaranteeing fundamental rights of
employees (job stability, working hours,
adequate remuneration, social dialogue,
freedom of association, collective
bargaining)
Own
operations
Positive Impact
Protection and increase of physical (health
and safety) and psychological well-being
of employees (work-life balance,
corporate welfare)
Own
operations
S3 – Affected
Communities
Communities’
economic, social and
cultural rights
Opportunity
Increased stakeholder trust resulting from
the definition of targets on economic,
social and cultural rights of communities
Own
operations
Positive Impact
Support for communities through the
development of locally supported
infrastructure and services (housing
support, initiatives to promote access to
food resources and hygiene/health
conditions, economic and educational
development and increased security of
the territories)
Own
operations
S4 – Consumers
and end users
Information-related
impacts for consumers
and/or end-users
Positive Impact
Protecting customer rights through easy
and transparent access to clear and
complete information on the products
and services offered, together with the
adoption of policies and strategies that
promote ethical business practices,
avoiding phenomena such as
greenwashing and ensuring informed
choices and trust in the information
provided.
Downstream
value chain
ESRS 2 – General disclosures
263
Positive Impact
Contribution to the protection and
safeguarding of customers through
suitable safeguards (cybersecurity and
health and safety measures, effective
channels for involving and managing
complaints, protection from possible bank
robberies)
Own
operations;
Downstream
value chain;
Positive Impact
Contribution to corporate integrity by
ensuring the security of the Bank's IT and
network systems for the benefit of
customers through the implementation of
cybersecurity policies and safeguards
Own
operations
Risk
Operational Risk arising from potential
impacts related to information for
consumers and end users (e.g. potential
breach of IT systems, compromise of data,
breach of customer privacy, limitation of
access to clear and non-misleading
information regarding the product/service
offered, limitation of customers' freedom
of expression)
Own
operations
Risk
Reputational risk arising from the
limitation of access to clear and non-
misleading information regarding the
product/service offered, from the
potential violation of privacy and from the
limitation of the freedom of expression of
customers and/or final consumers
Own
operations
Personal safety of
consumers and/or end-
users
Positive Impact
Contribution to the protection and
safeguarding of customers through
suitable safeguards (cybersecurity and
health and safety measures, effective
channels for involving and managing
complaints, protection from possible bank
robberies)
Own
operations
Social inclusion of
consumers and/or
endusers
Positive Impact
Increased access to products and services
also thanks to digital innovation, financial
education and the definition of an offer
to support the productive and economic
fabric, in compliance with fair, inclusive
treatment of all social categories and non-
discriminatory treatment of customers
Downstream
value chain
Social inclusion of
consumers and/or
endusers
Positive Impact
Increased ease of access to quality and
non-misleading information, including
through ethical and transparent business
practices
Downstream
value chain
G1 – Business
conduct
Corporate culture
Positive Impact
Promotion of an ethical corporate culture
based on: i) respect for human rights and
internal and external regulations; ii) fight
against tax evasion, money laundering
and anti-competitive behavior; iii)
principles of protection of corporate
solidity, ensuring efficiency in the
processes of generation and distribution
of value to shareholders and stakeholders,
through tools such as the code of ethics,
the 231/01 model and anti-financial crime
initiatives.
Own
operations
Risk
- Reputational risk arising from
inadequate development and promotion
of corporate culture (e.g. image damage
linked to a lack of corporate values in
employee behaviour or business practices
(e.g. failure to establish safeguards
against tax risk, money laundering))
Own
operations;
Upstream value
chain
ESRS 2 – General disclosures
264
Corruption and bribery
Positive Impact
Prevention of corruption phenomena
through the adoption of internal policies
and strategies aimed at it (e.g. obtaining
ISO 37001 certification)
Own
operations
Management of
relationships with
suppliers including
payment practices
Positive Impact
Contribution to the diffusion of ethical
practices through the definition of
internal policies and strategies aimed at
promoting dialogue and compliance with
payment deadlines towards direct
suppliers and sub-suppliers
Upstream value
chain
Political engagement
Positive Impact
Promotion of ethical and responsible
practices through lobbying activities
carried out according to the adopted
ethical principles that can generate
benefits for the community
Own
operations
Protection of whistle-
blowers
Positive Impact
Contribution to the protection of
individuals who report violations (whistle-
blowers) through measures that
guarantee the anonymity of the
whistleblower and allow for the
avoidance of personal/professional
repercussions on the whistleblower (e.g.
post-report abuse reporting channels)
Own
operations
During the reporting period 2025 a total of 359 IROs have been identiﬁed which is a reduction of 74 IROs identiﬁed
when compared to the previous reporting period. The reduction of total IROs was done mainly by incorporating
existing IROs under a broader macro category, alignment with the parent company or reconsideration of relevance.
Below is a comprehensive overview and rationalization of these changes:
Impacts excluded as marginal and with low relevance to VUB core banking activities:
–
Positive impacts: own operations (marine resources – E3); downstream value chain (gender equality and equal
pay – S2)
–
Negative impacts: own operations (water – E3, biodiversity and ecosystems – E4, waste and resource inﬂows –
E5); social (security of a person – S4)
Risks excluded as low relevance or with limited transmission channels / marginal ﬁnancial effects of risks concerned:
–
Strategic risk: retained only for standard (E1)
–
Credit risk: downstream value chain – diversity, inclusion, equal opportunities (S2); low likelihood of harm to
counterparties
–
Operational & reputational risk: upstream value chain – environmental (nature-related) and diversity topics (S2);
supplier disruptions unlikely
–
Liquidity risk: environmental, social, and governance topics; transmission channels largely residual
Opportunities excluded as not ﬁnancially signiﬁcant:
–
Business Conduct IROs (G1)
–
Own Workforce IROs (e.g., equal opportunities, working conditions)
Out of the total number of IROs evaluated 48 were material, compared to 55 material IROs from 2025. Below is a
comparison of changes to material IROs between 2024 and 2025 reporting periods. Changes to evaluation are
further described within the chapters of individual topics.
ESRS Standard
Impacts
Risks
Opportunities
Reporting year
2025
2024
2025
2024
2025
2024
E1 – Climate change
5
5
3
2
1
1
E2 – Pollution
0
2
0
2
0
0
E5 – Resource use & circular economy
2
2
0
1
0
0
S1 – Own workforce
14
15
0
0
3
2
S3 – Affected communities
1
1
0
0
1
1
S4 – Consumers
10
8
2
2
0
0
G1 – Business conduct
5
6
1
5
0
0
Total
37
39
6
12
5
4
E1 – Climate Change
The adopted Climate Change Adaptation Plan has led to positive impacts on various VUB locations and operations.
However, there are negative impacts from ﬁnanced emissions (existing exposure) and direct energy consumption,
mainly non-renewable energy use by the VUB Group physical infrastructure (the Bank's branch network, data centres
supporting IT infrastructure, and its headquarters and administrative ofﬁces). Future potential positive impacts could
ESRS 2 – General disclosures
265
arise from ﬁnancing energy efﬁciency and transition as well as climate change adaptation and mitigation initiatives
of clients, and from ﬁnancing linked to EIB and EU funds. Risks can arise from both lacking focus on climate change
adaptation objectives, leading to business interruption consequences, and from not meeting deﬁned objectives for
climate change mitigation, such as those set by the Net Zero Banking Alliance. This leads to an opportunity to
improve brand position to become a leader in climate action.
E5 – Circular Economy
The Group ﬁnances recycling and/or circular economy systems of clients via TERRA product line and EIB and EU
funds, including promotion of use of alternative materials. Positive potential impact could be realized by the
expansion of these towards recycling and reuse of materials, greater digitization of the offer itself, including the
offer of products that allow for less use of non-recycled materials.
S1 – Own workforce
The Bank generates positive impacts thanks to a variety of policies already adopted to nurture a thriving and healthy
working environment. This relates to further opportunities to attract talents, promote work-life balance and
employee well-being, and to strengthen the principle of equal pay for equal work in the policies.
S3 – Affected Communities
The positive impact comes from supporting communities focused on economic, educational, social inclusion and
youth employability ﬂows through initiatives such as the Good Angel project, the VUB Foundation, Inspiring Girls
initiative, Youth employability programs through the involvement of schools and universities, etc. The identiﬁed
material opportunity concerns the increase of trust of the VUB Group's stakeholders by enhancing the initiatives to
support positive social and environmental impacts within the affected communities, for example via the Enviro award
Atlas and related grant programs, grants to nurture local cultural heritage and life.
S4 – Consumers and End-users
These are covered by the policies across consumer’s data protection, complaints management, easy access of VUB
products and services to all social categories, and others. Data and privacy might be exposed to potential operational
and reputational risk in the event of breach of IT systems and data compromise.
G1 – Business Conduct
The Group maintains strong business conduct by enforcement of the existing policies related to, for example,
corporate ethics and integrity, whistleblowing, corruption and bribery, and by implementing comprehensive
cybersecurity safeguards. At the same time, this area remains very sensitive for the VUB Group as a ﬁnancial
institution, resulting in a potential reputational risk in case of failure to enforce all of those and address the incidents.
Due to the nature of the VUB Group's business activities and relationships, it remains central to its attention to keep
and build stakeholders' trust, whether it be employees, who play a crucial role in enforcing the implementation of
the VUB Strategy, or clients and society, for whom the Group creates value primarily through the provision of
ﬁnancial products and services. These are related to economic activities of actors across various sectors, which in
turn through their operations generate the identiﬁed impacts of the VUB Group's lending activities.
The VUB Group has excluded certain activities that are deemed to have a signiﬁcant negative impact on sustainability
from its ﬁnancing portfolio. Simultaneously, in line with the VUB Group's Strategy, it has increased its focus on the
quality of the provided sustainable ﬁnancing products not only to minimize the negative risks and impacts on people
and environment, but also to address the opportunities related to increased focus on ESG and green transition,
energy efﬁciency, combating climate change and innovation. Corporate lending portfolio represents the most
substantial potential to better reﬂect the needs of the clients.
The VUB Group recognizes that customer behaviour plays a role in overall environmental impact, thus is actively
promoting digital banking channels to reduce reliance on physical branches and paper-based transactions. The
assessment reafﬁrmed the need to enhance efforts to simplify access to ﬁnancing for individuals, social groups and
enterprises, and to support local initiatives that beneﬁt communities and the environment, in collaboration with a
variety of organizations.
However, the Group must stay strong and inherent also in its own operations, to uphold responsible business
conduct, corporate culture, cybersecurity and protection, and policy uptake. Recognizing the challenges of the Slovak
labour market, the VUB Group reinforced its direction towards continuous improvement of the employee well-being.
The analyses carried out so far (ICAAP and ILAAP stress testing) have conﬁrmed the resilience of the Group's Strategy
and business model, also considering the fact that the potential negative impacts expected and associated with ESG
risk factors are recognized within existing risk categories, which are managed through appropriate actions
(developed and/or planned) aimed at mitigating risks, capitalizing on opportunities and allowing the Group's
ESRS 2 – General disclosures
266
sustainability within a long-term perspective. The main driver of resilience is support of clients in transformation by
provision of sustainable loans and increase of their share within the portfolio as well as constant monitoring of the
business environment for potential risks and opportunities. VUB has been conducting regular market analysis and
surveys as well as receiving updates on macroeconomic trends, for example, as a result of regulatory changes or
wider societal challenges (such as climate change or technological progress). These are considered in modelling of
future developments and yearly update of ﬁnancial plans. Apart from that, the Group uses the SWOT analysis to
periodically reﬂect its strategic and business direction. The consistent integration of sustainability at all levels is
secured by the strong organisational and internal control structure, where the responsible bodies and roles (e.g. the
ESG Committee) propose strategic ESG issues and activities and verify the compatibility of the Group's strategic
objectives and ESG positioning with the overall business plan. For the future, VUB recognizes the value of a
comprehensive resilience analysis and intends to further develop it, especially in relation to more detailed climate
scenarios.
Governance structure
Role and composition of the administrative, management and supervisory bodies and the governance
of sustainability
The VUB Bank adopts a two-tier governance model, where the Supervisory and Management Board both contribute
to performing strategic supervision functions, while responsibility for management function lies solely within the
Management Board and control function within the Supervisory Board.
The activities of the Supervisory Board and the Management Board are governed by the Articles of Association of
the Bank, under a system of clear division of duties and responsibilities and balanced distribution of powers.
The information on governance provided in this section is related to the section Corporate Governance Statement
within this Annual Report. However, this section provides a full picture if read on a stand-alone basis.
The Management Board and the Supervisory Board: role and main characteristics
The Management Board serves as the statutory and executive body governing the executive management of the
VUB Bank and is responsible for the performance of its duties to the Supervisory Board and the General Meeting. It
is authorised to act on behalf of and to represent VUB in relations with third parties, in front of courts or other
authorities. The Management Board has the authority to manage the operational and organizational activities and
to decide on any matters of VUB, which are not transferred to the authority of other bodies by Legal Regulations
and/or the Articles of Association.
In addition, the Management Board is responsible for policy-making and strategic direction of the Bank (and in
general the VUB Group) and deliberates on all the most relevant corporate acts, with the power to carry out all the
operations which are necessary, useful or otherwise opportune for the achievement of the corporate purpose, both
of an ordinary and extraordinary nature. In speciﬁc cases and in the manner provided for by law and the Articles of
Association, the most signiﬁcant management decisions are submitted to the approval of the General Meeting.
The General Meeting is the main decision-making body with the powers exercised under the Articles of Association
and the mandatory requirements of the Legal Provisions. It decides on amendments to the Articles of Association,
decides on the amount and payment of dividends, regulates powers of the Management Board and Supervisory
Board in relation to remuneration, and fulﬁls other duties related to ﬁnancial operations and activities of VUB. It is
represented by the Sole Shareholder of VUB, a.s., (Intesa Sanpaolo Holding International S.A.), exercising the powers
of the General Meeting in accordance with Section 190(1) of Act No. 513/1991 Coll. Commercial Code as amended
(the Commercial Code).
The Supervisory Board is the main control body which supervises the Management Board and the performance of
the Group's business activities. It is bound by the decisions of the General Meeting to the extent permitted under
the Legal Regulations. It veriﬁes the procedures related to the Bank and reviews compliance of the VUB's business
activity with the Articles of Association, Legal Regulations and the instructions of the General Meeting. In addition
to other duties, it reviews the annual report to recommend for approval by the General Meeting and approves the
Bank Remuneration Policies.
The Management Board and Supervisory Board have established the following committees to support them. Each
committee has its own statute, and the role of the committees is described in the Operating Procedures of the
committees. This document is approved by the Management Board after the Parent Company’s approval. The
Supervisory Board adopts the statutes of committees set up under its management.
ESRS 2 – General disclosures
267
Eight committees are established by the Management Board:
–
Credit Risk Governance Committee
–
Credit Committee
–
Problem Assets Committee
–
Assets & Liabilities Management Committee
–
Operational Risk Committee
–
Change Management Committee
–
Internal Controls Coordination Committee
–
Environmental Social and Governance Committee (ESG Committee)
Four committees are established by the Supervisory Board:
–
Audit Committee
–
Risk & Sustainability Committee
–
Remuneration Committee
–
Nomination Committee
VUB Generali (shareholders: VUB Banka together with Generali Česká pojišťovna a.s.) and VUB Operating Leasing
have their own Management Boards and Supervisory Boards (without established committees), with members
representing also the VUB Bank.
Composition of the Management Board and Supervisory Board
The rules governing appointment and removal of the members of the Bank’s Management Board and Supervisory
Board including chairmanship are laid down in the Articles of Association in compliance with the Commercial Code,
as amended, Act No. 483/2001 Coll. on Banks, as amended, and Rules of the Intesa Sanpaolo Group.
The Management Board is in its present mandate represented by 6 (2024: 7) executive members, selected by the
Supervisory Board. The members include the Chief Executive Ofﬁcer (currently the Chairman of the Board), Deputy
Chief Executive Ofﬁcer, Chief Risk Ofﬁcer, Chief Financial Ofﬁcer, Chief Operating Ofﬁcer, and the Heads of Divisions
(Corporate & SME and Retail). These executive functions are equally appointed and removed by the Supervisory
Board in compliance with the Organizational and Competencies Rules of the Company.
The Supervisory Board is in its present mandate represented by 9 (2024: 9) non-executive members elected by the
General Meeting, including the Chairman and Vice Chairman from the members. Out of them, 3 (2024: 3) members
(one third) were elected by the employees as employee representatives. None of the Supervisory Board members is
a member of the Management Board nor holds any other top managerial position in the Bank. Except for members
of the Supervisory Board elected by VUB employees, a Supervisory Board member may not be an employee of VUB.
5 (2024: 5) members (55.5%) (2024: 55.5%) are internationally based in Luxembourg, Italy, Spain and Serbia. 2
(2024: 2) members are independent (22.2%) (2024: 22.2%).
The Committees under the Supervisory Board consist of 3 (2024: 3) members who are members of the Supervisory
Board. It respectively appoints the Chairmans from among the members of the Committees. The Risk and Audit
Committees have permanent invitees from the Intesa Sanpaolo Group with an advisory role in reason of their speciﬁc
expertise, professional experience and corporate seniority.
The Committees under the Management Board are represented by various members from the Board itself and other
Heads in Charge (e.g. Head of Compliance and AML, Credit Department, Risk Management Department, Branch
VUB Praha, Treasury and ALM, HR and Organization, etc.).
All the Committees are chaired by the CEO, apart from the Internal Controls Coordination Committee chaired by
the Head of Internal Audit Department, the ESG Committee and Change Management Committee, both chaired by
the Deputy CEO (ESG Manager), and Credit Risk Governance Committee chaired by the Chief Risk Ofﬁcer. The
Committees also have permanent invitees without a voting right across governance areas, departments and ofﬁces.
Skills and diversity
The members of the Management Board have sufﬁcient knowledge of the areas in which the Bank carries out its
activities, but also for which they are not necessarily responsible. All members of the Bank’s Management Board
have practical experience in the ﬁeld of ﬁnancial markets or sufﬁcient professional experience in the banking sector,
acquired from their previous business/working activities. The members of the Supervisory Board are familiar with
and able to supervise the performance of permitted banking activities, monitor the competency of the Management
Board, and the carrying out of other activities of the Bank.
Based on the extensive applicable regulatory framework, VUB applies its Rules on Suitability requirements for
Members of the Bank’s Management Board, Supervisory Board and Key Function Holders in control and non-control
functions to assess the competence and adequacy of the bodies and its members.
ESRS 2 – General disclosures
268
The composition of the Supervisory Board/Management Board is maintained sufﬁciently diverse to foster discussion
and dialogue within the Board. This diversity ensures a range of approaches and perspectives in the analysis of the
matters and in the decisions-making process, effectively support the company processes for the preparation of
strategies, risk management activities, control over the work of senior management, and take into account the many
interests that contribute to the sound and prudent management of the Bank.
At the time of appointment and, during the mandate, on an annual basis, the General Meeting/Sole Shareholder,
with the support of the Nomination Committee, in line with the guidelines and principles deﬁned by the Parent
Company, assesses the adequacy of the Supervisory Board’s composition, both in qualitative and quantitative terms,
allowing for its correct and effective functioning. The same applies for the Supervisory Board towards the
Management Board. The key criteria to consider include ensuring sufﬁcient diversity of age, gender, geographical
provenance and educational and professional background, suitability of the skills considered collectively in relation
to the targets, sufﬁciency in number, reputation, independence of judgement and time commitment. In addition to
other factors, the business model of the VUB Group and the ISP Group, the type of activity carried out, the VUB
Group’s and Intesa Sanpaolo Group’s strategy and the associated risks should be taken into account.
The Boards shall have a sufﬁcient number of members with adequate professional knowledge in these areas:
–
Strategic planning;
–
Financial markets;
–
Banking and ﬁnancial services and products;
–
Human resources, organization and corporate governance structures;
–
Risk management (identifying, assessing, monitoring, controlling and mitigating the main types of risk of the
Bank and the Group, including ESG risks, and anti-money laundering and terrorist ﬁnancing risk, considering
the Board Member’s responsibilities in those processes);
–
Regulations in the banking and ﬁnancial sector;
–
Internal control systems;
–
Accounting and ﬁnancial information;
–
Audit;
–
Digital & information technology and cybersecurity;
–
Financial intermediation;
–
International experience and outlook.
In addition to these experience requirements, the areas of knowledge relating to the activities carried out by the
Bank, as well as the related risks, including money laundering and terrorist ﬁnancing risks and ESG risks, shall be
met by the Boards on an overall basis. For each area of activity, there shall be a sufﬁcient number of members of the
Board with knowledge of the speciﬁc area to allow for constructive discussion of the decisions to be taken.
The skills matrix prepared for the Boards in its current mandate that reﬂects their actual composition in terms of
overall experience was assessed to be adequate. Their members were ranked as high in their skill to set and
implement the Bank's risk strategy, risk culture and risk appetite, in compliance policies and whistleblowing
mechanisms, in social, ethical and professional standards, weighing the interests of all stakeholders in a decision-
making process, development of the corporate culture, identifying the long-term interests of the Bank, and other
areas.
With regard to gender diversiﬁcation, the Management/Supervisory Board or General Meeting/Sole Shareholder, will
approve the target proportion for the underrepresented gender set by the Nomination Committee and a plan for
recovering the set target if it has not been met. The deﬁned target for the representation of the underrepresented
gender for the Management Board and the Supervisory Board is set as one third of the number of Members of each
Board rounded down to the unit. Within the present mandate, in the Management Board, women represent 17%
(2024: 14%), while men make up 83% (2024: 86%) (gender ratio is 0.2 (2024: 0.17))
5
. The Supervisory Board is
composed of 56% (2024: 44%) women and 44% (2024: 56%) men (gender ratio is 1.25 (2024: 0.8)).
The Committees under the Supervisory Board are managed with a female to male ratio 1:2 (2024: 1:2), apart from
the Remuneration Committee with 3 (2024: 3) male members. Out of the 8 (2024: 8) members across the
Committees under the Management Board, who are not Board members, 25% (2024: 25%) are women and 75%
(2024: 75%) men (gender ratio 0.33 (2024: 0.33)).
Despite the Group's best efforts, the current labour market conditions make it challenging to meet the gender
balance criterion while maintaining high professionalism as a priority. The candidate's professional and personal
qualities and broad range of experience complement the synergy of the members of both Boards very well. The VUB
Group remains committed to pursuing gender balance in future Boards changes.
5
Understood as the number of women on the board compared to the number of men.
ESRS 2 – General disclosures
269
Induction and training
The VUB Bank places a strong emphasis on ensuring that members of the Management Board and the Supervisory
Board continuously develop their skills and expertise in alignment with the strategic objectives of the VUB Group. In
this context, the participation of Board Members in initiatives aimed at increasing knowledge of the Bank's business
sectors, Group companies, corporate dynamics, and their evolution is actively organized and promoted. This includes
an in-depth understanding of the principles of effective risk management, as well as the relevant regulatory and self-
regulatory framework. Additionally, both formal and informal meetings are convened to facilitate the examination
of strategic issues in depth.
Board Members are required to participate in educational activities delivered through e-learning modules or webinars
on selected topics that enhanced their understanding of the Bank’s direction and activities. In 2025, the training
sessions covered a range of crucial subjects, including relevant ESG issues, the new EBA Guidelines on AML, digital
threats and protection, as well as people security and resilience. Furthermore, professional development is reinforced
by participation in expert conferences, professional clubs, and communities, where members can gain new insights
and share experiences, either as participants or speakers. The Board Members are regularly informed about market
trends and analysis from the ESG Committee. Before the adoption of the results of the Double Materiality
Assessment, the members of the Committee were familiarized with the complete methodology and process ﬂow
including stakeholder engagement.
Leadership development is recognized as a critical factor in the successful transformation of the VUB Group and the
cultivation of a progressive corporate culture and nurturing the innovation mindset. Therefore, in addition to
technical and banking-related topics, the Board Members are actively supported to participate in educational
initiatives focused on modern management approaches, such as agility and psychological safety. Each Board Member
has access to individual coaching sessions facilitated by professional partners, as well as personalized leadership
consultations. In 2025, Board Members were also provided with opportunities for individualized training on digital
skills, the effective use of MS365 tools, and AI-based solutions such as Copilot.
Board Members are, in all cases, guaranteed the possibility of individually formulating speciﬁc training requests in
areas they deem necessary for their role and to strengthen their area of competence. Additionally, continuous
knowledge development is supported through regular updates on relevant business and regulatory topics, ensuring
that the Board remains informed on emerging developments. This ongoing ﬂow of information plays a fundamental
role in enhancing decision-making capabilities and reinforcing the VUB Group’s and Bank’s commitment to high
standards of governance and professional excellence. The induction plans are drawn up periodically following the
ﬁrst assessment carried out after appointment and the assessment carried out annually by the respective Board or
General Meeting/Sole Shareholder. Apart from considering the results of the assessment, the plans are structured
based on the recommendation of the Chairpersons of the Boards with the joint support of HR and Organization,
Legal and Compliance and AML Departments and the competent corporate functions in relation to the subject-
matter of the individual sessions.
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The governance of sustainability
The main ESG responsibilities of the VUB Group's Bodies and Structures are listed below, in accordance with the
provisions of the Statute, the Bodies' Regulations and the Group's internal regulations.
Main corporate bodies and functions related to the governance of sustainability
Management
Board
With reference to the sustainability issues, the Management Board, with the support of the relevant
committees:
Defines and approves the strategic guidelines and policies on sustainability (ESG), including the social and
cultural responsibility model and the fight against climate change, taking into account the objectives of
solid and sustainable creation and distribution of value for all stakeholders;
Defines and approves the risk objectives, including in the reference framework for determining the risk
appetite also the risks in terms of sustainability (ESG), with particular reference to climate and
environmental risks;
Approves the Consolidated Sustainability Report, ensuring that it is drawn up and published in compliance
with the provisions of the legislation in force;
Examines the annual information presented by the Manager in Charge regarding the activities for
monitoring sustainability information risk and the periodic reports presented by the corporate control
functions;
Approves the updates to the Code of Ethics and the Policy containing the Principles on Diversity, Equity &
Inclusion.
To ensure an effective and efficient management and control system, strategic decisions on risk
management at Intesa Sanpaolo Group level are overseen by the Board of Directors of Intesa Sanpaolo, in
a capacity as Parent Company, which considers the Intesa Sanpaolo Group’s overall operations and the
risks to which it is exposed.
ESG Committee
It serves as a permanent consultative and decision-making committee with the main goal to coordinate and
steer ESG related matters.
It is headed by the ESG Manager (Deputy CEO), supported by Chief Risk Officer and Chief Financial Officer
(Co-Heads), with participation of:
Head of Retail banking Division;
Head of Corporate & SME banking Division;
Head of Credit Department;
Head of HR & Organization Department.
The Committee supports the Management Board in the exercise of the above-mentioned tasks, primarily in
the following areas:
The strategic proposal for ESG issues and operational coordination of the implementation of initiatives, by
defining priorities and monitoring the progress of activities;
Contribution to the preparation of the Bank’s business plan from ESG perspective;
Coordination of specific and relevant inter-divisional and inter-functional projects aimed at implementing
ESG issues in the VUB Group's strategies and operations, ensuring consistency and the development of
synergies, in line with the Group's strategic guidelines and the full involvement of all units concerned;
Review and approval of the results of the impact and financial materiality assessment (DMA) that identifies
the aspects relating to environmental, social and governance sustainability that are relevant with regard to
the impacts, risks and opportunities considered, in accordance with the applicable legislation;
Oversight of the process of defining, approving and updating ESG sustainability guidelines and policies in
the VUB Group;
Highlighting the opportunities to launch new projects and initiatives, in line with defined priorities, in
coordination with the Parent Company and considering ESG initiatives undertaken by other banking
players or regulatory developments;
Approval of the list of ESG-sensitive sectors relevant to the Group's financing activities, assessing them
based on the analysis of the external context and consistent with the ISP Group's strategic and
sustainability objectives;
Review of the analysis of potential ESG risks and opportunities in the local market brought to it by the
Bank’s competent functions;
Oversight of the contribution of the Bank for the ISP Consolidated Non-Financial statement;
In cooperation with the ISP competent functions, provision of guidance regarding the Bank’s participation
in the regulatory consultation and oversight of the alignment with the internal and external regulatory
framework;
Responsibility for defining the Group's training needs on ESG and sustainability issues, also in cooperation
with the other competent corporate functions.
The ESG Committee meetings are held bimonthly.
The support offered by the Committee to the Board, in the exercise of strategic supervision functions in
terms of sustainability, as well as for the definition and monitoring of climate and environmental risk
objectives, is transversal and is also provided in the examination of the issues concerning risk governance
and management, the business model and strategic directions and the most significant operations for the
purposes of risk management procedures.
In particular, the Committee monitored the progress of the activities related to the preparation of the VUB
Group Consolidated Sustainability Report in compliance with the reference regulation, shared the VUB
Group contribution to Intesa Sanpaolo Group ESG KPIs for the 2025 Budget, and streamlined the process
of identifying and monitoring climate and environmental risks.
The members of the ESG Committee are required to have knowledge, skills and experience, such as to be
able to fully understand and monitor the Bank's risk strategies, impacts and orientations, including in terms
of sustainability.
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271
ESG Manager
(Deputy CEO)
The Deputy CEO represents a point of reference for the development of the Bank’s internal governance in
line with the Group’s strategic direction, as well as governance standards in full compliance with local
regulations. He is responsible for overall coordination and supervision of information flows towards the
Parent Company Group.
He oversees the ESG Office in the exercise of his role as the ESG manager, participates in defining and
managing the ESG strategy and coordinates the activities of internal bodies and cross-functional teams on
the matter, in cooperation with the competent functions of the VUB Bank and the functions of the Parent
Company. ESG Manager governs sustainability performance and exercises the power of proposal to the
ESG Committee and Management Board for resolutions within its competence.
Audit Committee
With reference to the sustainability issues, the Audit Committee:
Monitors the process of reporting sustainability information, including the digital tagging of this
information and the procedure applied by the Bank to identify the information included in the special part
of the annual report, and making recommendations and proposals to ensure the integrity of this process;
Monitors the effectiveness of internal control, internal audit, and risk management systems as they relate
to the preparation of sustainability information reporting, including their digital tagging, while maintaining
their independence;
Monitors the progress and results of assurance in the area of sustainability information reporting
concerning individual and consolidated sustainability information reporting, and taking into account the
findings and conclusions of the Office for Audit Oversight;
Reviews and monitors the independence of the statutory auditor or audit firm performing assurance in the
area of sustainability information reporting in the Bank, especially the appropriateness of providing non-
audit services;
Informs the Management Board or Supervisory Board about the result of assurance in the area of
sustainability information reporting, including an explanation of how assurance in the area of sustainability
information reporting contributed to the integrity of this reporting and the role of the Audit Committee in
this process.
The Audit Committee held six meetings during the 2025 financial year.
More information about the individual responsible persons within the body overseeing impacts, risks and
opportunities can be found starting on page 27 of the Annual Report.
Below are the internal governance structures involved in the management and control of ESG risks, designed to
ensure their oversight in accordance with regulatory requirements and in line with the VUB Group's operations and
the context in which the VUB Group operates.
Supervisory Board and Management Board Committees
Risk & Sustainability
Committee
With reference to the sustainability issues, the Risk & Sustainability Committee:
Provides recommending, advisory, and supporting functions to the Supervisory Board, focusing on risk
monitoring and overall risk management, including ESG risks;
Helps the Supervisory Board in fulfilling its strategic supervisory duties related to the risk management
framework, risk appetite, risk policies, and other risk-related decisions within its legal remit.
The Committee meets at least twice a year.
Credit Risk Governance
Committee
A permanent decision-making and advisory committee which ensures coordinated management of credit
risk within the Bank's credit prerogatives, laws, and strategic guidelines. The Committee defines and
updates credit risk strategic guidelines and credit management policies based on continuous portfolio
monitoring.
It analyses and assesses issues related to the launch and monitoring of products that involve credit risk,
including sustainability related classification.
It defines the maximum exposure and reviews regularly the credit portfolio and related credit risk reports
as regards the ESG risks (e.g. transition risk, physical risk).
Operational Risk Committee
It is a permanent decision-making and advisory body which ensures competent management of
operational risks, including ICT/cyber risks.
It examines the main climate/environmental risk profiles, which are reflected or could be reflected, on the
exposure to operational and reputational risks.
Internal Controls
Coordination Committee
It is a permanent advisory body which facilitates the integration of risk management processes within its
delegated authority. It examines reports submitted by the corporate control functions with respect to
sustainability risks (ESG), examines the VUB Group risks and identifies sustainability issues (ESG) potentially
relevant for the definition and updating of the materiality.
In the area of material impacts, risks, and opportunities, the VUB Group generally achieves its goals primarily
indirectly by minimizing activities that conﬂict with sustainability principles and simultaneously increasing the share
of its sustainable portfolio.
Contributing to the Intesa Sanpaolo Group KPIs, the VUB Bank does pursue internal business KPIs set on local level,
focusing primarily on the share of sustainable ﬁnance on the overall portfolio. The governance bodies regularly
review the Bank’s performance against these KPIs and assess the most signiﬁcant individual impacts, risks, and
opportunities to ensure alignment with its sustainability objectives and to drive continuous improvement in
addressing material sustainability-related impacts, risks, and opportunities.
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272
In December 2023, the ESG Manager role (Deputy CEO function) was established, reporting to the CEO, with the
aim of guiding the Group's development strategies in the area of sustainability.
In support of the exercise of ESG activities within the Management Board, in 2023 the ESG Committee was
established to serve its function of a permanent body providing decision-making and steering support to the ESG
agenda. The Committee provides speciﬁc support to the Management Board with reference to the strategic proposal
of guidelines, policies and initiatives on ESG issues, in the relative monitoring of the achievement of objectives as
well as in the examination of any actions that may be deemed opportune or necessary for the purpose of achieving
the results. The Heads of relevant divisions and departments participate on a permanent basis in the ESG Committee
and, if necessary, based on the topics covered, the Heads of other VUB Group functions are invited.
The Chief Financial Ofﬁcer co-chairs the ESG Committee together with the Chief Risk Ofﬁcer. In a broader sense,
the Chief Financial Ofﬁcer Division veriﬁes the compatibility of the VUB Group's strategic objectives and ESG
positioning with the current Intesa Sanpaolo 2022-2025 Business plan.
In April 2024, the ESG Ofﬁce has been established, supporting the ESG Manager in implementation of the VUB4ESG
programme
6
.
The ESG Ofﬁce has the following main functions:
–
Act as a single point of contact for all ESG topics for the VUB Group and the functional departments of the
Parent Company, ensuring the implementation of Intesa Sanpaolo Group strategies;
–
Ensure the gradual implementation of the ESG framework methodology of the VUB Group in coordination with
the relevant functions;
–
Support the VUB ESG manager in monitoring the implementation of the VUB Group's ESG strategy and the
implementation of planned initiatives and their economic and ﬁnancial performance, proposing adjustments
that could be appropriate to achieve the set results;
–
Coordinate speciﬁc and relevant cross-divisional and cross-functional projects aimed at implementing ESG issues
into the VUB Group's strategies and activities, ensuring consistency and development of synergies in accordance
with the Intesa Sanpaolo and VUB Group's strategic guidelines and the full involvement of all departments
concerned;
–
Coordinate the preparation of all ESG reports required by internal departments or regulatory authorities,
according to the guidelines set by the relevant functional departments of the VUB Group and ensure the
availability of consistent data and information to data owners;
–
Prepare a periodic action plan and monitor progress on activities, including responses to surveys;
–
Support the ESG Manager in the assessment of loan proposals for which ESG impacts have been identiﬁed
(sustainability ﬂag) and send the most signiﬁcant proposal to the relevant functional department of the parent
company responsible for sustainable development for further assessment;
–
Promote awareness of the application and integration of the Code of Ethics into the Bank's decision-making
processes, also with regard to the principles of social and environmental responsibility in cooperation with the
Human Resources and Organization Department;
–
Coordinate all the VUB Group's departments involved in the collection of non-ﬁnancial data, also with regard
to ESG factors, in line with the Intesa Sanpaolo and VUB Group's approach to compiling the Consolidated
Sustainability Report.
Furthermore, the HR and Organisation Department (Internal Communication and CSR Ofﬁce) and PR and Marketing
Department (also through the VUB Foundation) direct, govern and implement social impact initiatives and projects,
promote the well-being and inclusion of people and the Community, and direct, coordinate and control initiatives
to mitigate the direct environmental impacts generated by the VUB Group.
The Chief Financial Ofﬁcer is responsible for preparing the Consolidated Sustainability Report, including monitoring
and interpreting the evolution of European and national regulations on the subject, as well as deﬁning and
subsequently updating the consequent methodological rules.
The Chief Risk Ofﬁcer (CRO) is responsible for deﬁning, developing and updating the ESG risk management and
assessment system. Within the Risk Appetite Framework, and for the purpose of subsequent presentation to the
Corporate Bodies, a level of tolerance to ESG risk (including climate change) and reputational risk is proposed, and
speciﬁc exposure limits, risk indicators, and actions to be monitored and updated are deﬁned. The update of the
Risk Appetite Framework is approved by the Management Board. The CRO is also responsible for the processes of
identiﬁcation, assessment and management of climate risks.
Finally, within the CRO Division, the Risk Management Department periodically reports the overall risk status of the
6
The programme VUB4ESG was launched in 2022 year, with the aim to implement the ESG framework in VUB Group and continually steer the
Group towards the sustainability goals set by parent company and in general European Union (Green deal). The project consists of 4 pillars – ESG
Governance, VUB Ecosystem, Sustainable lending and Sustainable investments.
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VUB Group through the production of various risk reports, delivered and discussed on the Management Board or
relevant Committees, including ESG Committee, and which incorporate a section dedicated to Reputational and ESG
risks, to monitor compliance with risk propensity limits.
As highlighted by the ESG responsibilities of the Management Board and ESG Committee previously described,
sustainability IROs are taken into consideration both in deﬁning and monitoring the VUB Group strategy and in the
context of risk management processes.
With regard to strategic assessment elements, it should be noted that during 2024 the Credit Risk Governance
Committee approved the deﬁnition of new sectoral targets, continuing the Intesa Sanpaolo and Group's
commitment to climate transition, and supported the deﬁnition of new operational tools to support communities to
strengthen the Intesa Sanpaolo Group's positioning in terms of social responsibility.
The Management Board and the ESG Committee continuously address material sustainability IROs throughout the
year, presenting them to the relevant bodies through various reporting structures (and any assisting structures where
necessary) according to the type of relevant topic. In particular, during 2025, the role of rapporteurs on sustainability
issues was mainly delivered by the following structures:
–
ESG Ofﬁce;
–
Chief Financial Ofﬁcer (CFO) Division;
–
Chief Risk Ofﬁcer (CRO) Division.
Below is the list of the main sustainability IROs discussed during the meetings held in 2025 by the Management
Board and the Committees in charge of dealing with ESG issues:
–
ESG Governance – ESG awareness and suitable corporate culture, DE&I issues, health and safety of workers,
climate and environmental risks, governance of reputational risk, ESG client scoring, ESG related reporting
(managerial and regulatory), ESG Data strategy, ECB Expectations on Climate and Environmental risks, etc.;
–
VUB Ecosystem – carbon footprint and own emissions reduction, upstream value chain engagement (incl.
supplier ESG scoring), support for communities, etc.;
–
Sustainable lending – advisory for customers, ﬁnancial solutions supporting clients’ transition, product
innovation;
–
Sustainable investments – advisory for customers, Funds of Eurizon Asset Management, Funds of DSS pension
scheme;
–
Efﬁciency of internal control and risk management system;
–
Other topics.
Integration of sustainability-related performance in incentive schemes
The Intesa Sanpaolo and VUB Group has adopted an incentive system linked to sustainability issues for members of
the administrative, management and control bodies. Speciﬁcally, in the VUB Bank, as part of the Incentive System
for CEO, Management Board members and all Managers, a cross-cutting non-ﬁnancial/qualitative KPI
‘Environmental, Social and Governance’ has been conﬁrmed among the strategic actions and targets.
Annual Incentive System structure
The Annual Incentive System is formalized through a Performance Scorecard, incorporating both economic-ﬁnancial
and non-ﬁnancial KPIs. The KPIs are categorized under four key performance drivers: Growth, Proﬁtability,
Productivity, and Cost of Risk/Sustainability. Meanwhile, qualitative non-ﬁnancial KPIs are aligned with strategic
actions and projects that enable ﬁnancial KPI attainment or contribute to the broader business objectives.
Among the non-ﬁnancial KPIs, the transversal ESG KPI has been maintained for 2025, demonstrating continuity in
sustainability-linked incentive structures. Each KPI is assigned a weight of at least 10% to ensure signiﬁcance of the
objective, while no individual KPI exceeds 30% of the total weight to maintain balance across objectives. The
evaluation (accrual) period is annual.
The total bonus awarded to the CEO is assigned based on the evaluation of the results of the individual performance
sheet according to a deterministic calculation.
In any case, the bonus is subject to veriﬁcation of the activation conditions and the absence of individual so-called
compliance breaches, as well as subject to corrective mechanisms.
The bonus is paid partly in cash and partly in units of Investment Certiﬁcates of VUB and is recognized over a deferral
period of 5 years. Each deferred portion is subject to an ex-post correction mechanism – the so-called malus
conditions. Furthermore, in the 5 years following the payment of the single portion (up-front or deferred) of variable
remuneration, the company reserves the right to activate claw-back mechanisms.
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274
Long-Term Incentive Plan structure
The VUB Bank CEO is also a beneﬁciary of the Performance Share Plan (PSP), a long-term incentive plan. The plan is
based on shares recognized on a ﬁxed-term basis upon achieving speciﬁc performance objectives with the Intesa
Sanpaolo Group Business Plan (Operating Income/RWA, Cost/Income, NPL ratio and relative TSR) and whose target
levels correspond to those set in the Plan itself.
The plan also features two de-multipliers:
1.
ESG Composite KPI: Consists of sub-KPIs related to Environmental, Social, and Governance factors whose
target level is deﬁned within the Intesa Sanpaolo Group 2022-2025 Business Plan. Failure to meet these
objectives can reduce the number of vested shares by 10-20%;
2.
Capital Target: Ensures CET1 levels remain above the Intesa Sanpaolo Group's RAF target over the Plan’s
duration. Failure to meet this condition results in a 10% reduction in vested shares for each year of non-
compliance, up to a maximum reduction of 40% over the entire Accrual Period.
The PSP remains subject to activation conditions, individual compliance evaluations, and risk oversight. 60% of any
award accrued is deferred over a ﬁve-year period, with 60-55% of the shares subject to a retention period. Malus
and claw-back provisions apply throughout this timeframe.
The ESG Component in CEO Incentive Plans (annual and long-term)
With reference to the variable remuneration of the CEO, the ESG component plays a central role in the Annual
Incentive System through the establishment of a speciﬁc and well-deﬁned KPI. This KPI – present since 2021 and
which represents an evolution compared to the previous transversal KPI ‘Diversity & Inclusion’ – was assigned in the
CEO's Performance Scorecard, in line with the Bank's ever-increasing commitment to social, cultural and
environmental sustainability and with the aim of creating long-term value for its people, its customers, the
community and the environment. In addition, the KPI forecast is in line with the increasingly signiﬁcant attention on
these issues by the Group's Regulators, Proxy Advisors, Shareholders and Stakeholders.
The CEO ‘ESG KPI’ (with a weight of 15%) is evaluated on the basis of speciﬁc drivers:
–
Presence of Intesa Sanpaolo in the sustainability indices of specialized companies (number of presences);
–
Promotion of an inclusive work environment through the identiﬁcation and implementation of targeted
management actions, with a particular focus on the achievement of the gender equality commitments assigned;
–
Group ESG initiatives linked to support for the green economy and the circular economy, including credit
development with a focus on ESG:
o
Support for the green economy and the circular economy: i) development of ESG-based
employment; ii) deﬁnition of targets for the reduction of ﬁnanced emissions in additional priority
sectors; iii) reduction of exposure to ESG-risk sectors; iv) completion of the ESG Credit Framework;
o
Growth of Sustainable Investments through the incidence of ESG investments on total AuM (%);
o
Initiatives for youth orientation and employability.
The PSP long-term incentive plan includes a composite KPI which, in terms of sustainability, acts as a de-multiplier
as anticipated in the previous paragraph. The KPI consists of a sub-KPI identiﬁed in the Business Plan for each of the
3 factors into which ESG is divided, namely:
–
Environmental: new credit for the green/circular economy and the ecological transition with a particular focus
on supporting the transition of Corporate/SMEs (weight 40%);
–
Social: number of people who have successfully completed the re-skilling and up-skilling paths with relocation
in the case of the former to landing jobs (weight 40%);
–
Governance: percentage of women in new appointments for senior positions, i.e. -1 and -2 organizational levels
below the CEO (weight 20%).
The Annual Incentive System and the Performance Share Plan (long-term incentive plan) are approved by the
Supervisory Board, on the proposal of the Management Board supported by the Remuneration Committee. In
addition, the Risk Committee, without prejudice to the prerogatives of the Remuneration Committee, supports the
Supervisory Board and examines them in order to verify their connection with current and prospective risks.
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275
Risk management and internal controls over sustainability reporting
As of 31 December 2025, the ‘Guidelines for the Preparation of Consolidated Sustainability Reporting’ identify the
reference principles and regulate the process of preparing, approving and publishing the Consolidated Sustainability
Report pursuant to the Amendment to the Act on Accounting 105/2024.
The Consolidated Sustainability Report:
–
must be included in a separate section of the Management Report on the ﬁnancial statements;
–
must contain the information necessary for understanding the VUB Group's impact on sustainability issues as
well as the information necessary for understanding how sustainability issues affect the Group's performance,
results and position;
–
is prepared on a sub-consolidated basis and includes the data of VUB Bank and the companies consolidated –
VUB Operating Leasing and DSS VUB Generali.
The macro-stages of the process of preparing the Consolidated Sustainability Report are:
–
preparation and allocation of roles and responsibilities;
–
gathering of information and preparation of contributions;
–
harmonisation and a ‘sanity check’;
–
review of the Consolidated Sustainability Report by the Corporate Bodies, approval by the CEO and the Manager
responsible for preparing the company’s ﬁnancial reports (CFO), and approval by the Corporate Bodies;
–
certiﬁcation by the Independent Auditor;
–
publication.
Corporate Bodies and Structures are responsible, each to the extent of their responsibilities, for ensuring that the
information included in the Consolidated Sustainability Report is provided in compliance with the provisions of the
relevant regulations.
The Data Collection Model deﬁnes a standardized process for collecting, validating and delivering quantitative data
required for ESRS/CSRD reporting. It outlines responsibilities, data ﬂows, general timelines, validation procedures
and classiﬁcations to ensure full compliance with the relevant legislation.
Accounting Department, consulting with ESG Ofﬁce and Risk Management Department, conducts the impact and
ﬁnancial materiality analysis along the entire value chain.
The Management Board approves the results of the impact and ﬁnancial materiality analysis that identiﬁes those
environmental, social and governance aspects that are relevant with regard to the impacts, risks and opportunities
considered.
The ESG Committee monitors the effectiveness of the Bank's internal quality control and risk management systems
and internal auditing.
Internal Audit ensures independent internal audit and oversight of the overall process of preparing and publishing
the Consolidated Sustainability Report.
The Data Collection Model provides:
–
ﬁrst-level validation conducted by the Head of Ofﬁce or Manager supervising the data provider;
–
second-level validation conducted by the ESG Monitoring and Reporting Manager, including year-over-year
consistency checks and identiﬁcation of unexpected deviations.
The identiﬁed risk concerns the further enhancement and formalization of ESG data collection and reporting.
As of 31 December 2025, the VUB Group implemented the Guidelines for the Preparation of Consolidated
Sustainability Reporting (Legislative Decree 125/2024), deﬁning data ownership and responsibilities, standardizing
collection and reporting processes, reinforcing key metric controls, and reducing operational risk.
General Risk mitigation within the reporting process is ensured through:
–
deﬁned roles and responsibilities of Corporate Bodies and Structures;
–
impact and ﬁnancial materiality analysis;
–
the Monitoring and Reporting Manager responsible for preparing the CSRD/ESRS report;
–
harmonisation and ‘sanity check’ of qualitative and quantitative contributions;
–
independent audit certiﬁcation of the Consolidated Sustainability Report;
–
multi-level validation of quantitative data, including documentation of primary data source, handling type and
validation conﬁrmation.
The Consolidated Sustainability Report is subject to limited review by the Independent Auditors, who express their
conclusions on compliance with the Act and with the disclosure requirements of Article 8 of Regulation (EU)
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276
2020/852.
The process of contributing the required information involves identifying the Contributor, i.e. the Structure that
holds the necessary quantitative and/or qualitative information, and the Validator, i.e. the Structure that checks that
the information is correct.
Contributors submit the information into the reporting. Validators validate the submitted contributions, each for the
content under their responsibility.
Accounting Department and ESG Ofﬁce harmonise and perform a ‘sanity check’ to ensure the standardisation and
consistency of the document and compliance with regulatory requirements.
The Manager responsible for preparing the company’s ﬁnancial reports carries out veriﬁcation and monitoring
activities to ensure that the Consolidated Sustainability Report has been prepared in accordance with the reporting
standards.
The Management Board:
–
approves the Consolidated Sustainability Report;
–
examines the annual report submitted by the Manager responsible for preparing the company’s ﬁnancial reports
on sustainability risk monitoring;
–
examines the outcome of the auditors’ check of the Consolidated Sustainability Report.
The ESG Committee monitors the process of Consolidated Sustainability Reporting and the effectiveness of the
Bank's internal quality control and risk management systems in relation to the Report.
The CEO and the Manager responsible for preparing the company’s ﬁnancial reports provide the legally required
certiﬁcations conﬁrming that the Sustainability Report has been prepared in accordance with the reporting standards
applied pursuant to the CSRD and the Act.
The Bank adopted an Integrated Internal Control System based on three levels. This model provides for the following
types of control:
–
Level I: Line controls that are designed to ensure that operations are carried out correctly (e.g. hierarchical,
systematic and sample internal controls) and, where possible, are embedded into IT procedures. These controls
are performed by the operational and business organisational units themselves (the ‘Level I Functions’) including
through units that are exclusively dedicated to control tasks and that report to the head of the units or are
performed as part of back-ofﬁce operations;
–
Level II: Controls on risks and compliance that aim to ensure, inter alia: (i) correct implementation of the risk
management processes (both formal and substantial); (ii) respect of the operating limits assigned to the various
functions; (iii) compliance of operations with laws, regulations and internal policies, rules and procedures. The
functions responsible for these controls are independent from the business and operating functions and
contribute to deﬁning the risk governance policies and the risk management process. Level II includes the
following Bank organizational structures: Compliance and AML Department, Risk Management Department and
Internal Validation Ofﬁce;
–
Level III: Internal auditing controls, designed to identify violations of procedures and regulations and to
periodically assess the comprehensiveness, adequacy, functionality (in terms of efﬁciency and effectiveness) and
reliability of the internal control system and the IT system (ICT audit) at the VUB Group level, at pre-established
intervals depending on the nature and severity of the risks.
The VUB Group has therefore equipped itself with a structured system of controls and responsibilities to ensure
compliance of the Consolidated Sustainability Report with current legislation according to a risk-based approach,
aimed at managing the risks associated with reporting sustainability information to third parties.
The structures involved in the control system carry out speciﬁc activities, detailed in the VUB Group's internal
documents and aimed at ensuring the quality and compliance of the Consolidated Sustainability Report throughout
all phases of the process. These control activities are directly correlated to the main types of risks identiﬁed and
represent forms of mitigation of the latter.
Speciﬁcally:
–
During the phase of deﬁning the work plan and the structure of the Sustainability Report, the controls focus on
the analysis and interpretation of the relevant legislation, on the correct deﬁnition of the consolidation perimeter
and on verifying that the double materiality assessment is complete and accurate, with a clear identiﬁcation of
its results;
–
During the collection of information and the preparation of contributions, control activities include the
veriﬁcation of data sources and the uploading of information through formal systems and procedures, aimed at
verifying the completeness, precision, coherence and exhaustiveness of such information by the respective
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277
contributors and validators;
–
In the aggregation and ﬁnalization phase of the Consolidated Sustainability Report, the outcomes of the
contribution and validation process are veriﬁed, the correctness of the metrics is checked and the information
relating to policies, actions and objectives is harmonized, ensuring that the ﬁnal document meets the regulatory
and quality requirements.
Furthermore, the Chief Financial Ofﬁcer, through the reporting structures under her authority, conducts the
veriﬁcation and monitoring activities aimed at ensuring that the Consolidated Sustainability Report included in the
Management Report has been drawn up in accordance with the reporting standards applied under the CSRD
regulation.
This integrated system ensures effective and transparent management of Consolidated Sustainability Report, in line
with regulatory requirements and quality standards deﬁned by the VUB Group.
The risk assessment and internal controls related to sustainability reporting have therefore been integrated within
the functions identiﬁed by the new internal regulatory framework deﬁned by the VUB Group.
The results of the control and risk assessment activities will subsequently be communicated to the Administrative,
Management and Control Bodies, as provided for in the aforementioned framework.
In particular, the Chief Financial Ofﬁcer presents the annual report to the Management Board on the activities to
monitor the sustainability disclosure risk, included in the Report on the system of internal controls relevant to ﬁnancial
reporting, while the corporate control functions submit their own periodic reports.
278
Environmental information
Reporting in accordance with the EU Taxonomy
(EU Regulation 2020/852)
Regulation (EU) 2020/852 (so-called ‘Taxonomy Regulation’), introduced as part of the Action Plan for ﬁnancing
sustainable growth of the European Union, provides that those activities that contribute to at least one of the
following environmental objectives, without causing signiﬁcant harm to the other objectives and carried out in
compliance with minimum safeguards
7
can be considered environmentally sustainable:
–
Mitigation of climate change;
–
Adaptation to climate change
–
Sustainable use and protection of water and marine resources;
–
Transition towards a circular economy;
–
Prevention and control of pollution;
–
Protection of ecosystems and biodiversity.
This Regulation has been supplemented over time by delegated acts that have deﬁned, for each of the six
environmental objectives, the economic activities that have the potential to contribute to these objectives (so-called
‘Taxonomy-eligible‘ activities) and the technical screening criteria that make it possible to conﬁrm the actual
substantial contribution of these activities to the objectives themselves (so-called ‘Taxonomy-aligned’ activities).
Regarding the content, methodology, and presentation of information on environmentally sustainable economic
activities, Delegated Regulation (EU) 2021/2178 was amended by the European Commission in July 2025 and
published in the Ofﬁcial Journal of the European Union on 8 January 2026 as Delegated Regulation (EU) 2026/73
(hereafter also ‘Omnibus delegated act’). This act is part of the European Commission’s ‘Omnibus I ’package to
simplify sustainability regulations in key areas, including the EU Taxonomy, reducing reporting burdens for companies
and ﬁnancial intermediaries while safeguarding transparency and reliability of environmental information provided
to the market.
The new Regulation applies from 1 January 2026 with reference to the 2025 ﬁnancial year, with the possibility for
companies subject to Taxonomy reporting to postpone application by one year if deemed appropriate. The VUB
Group has chosen to report based on the provisions of Delegated Regulation (EU) 2026/73, applying it in full. Among
the main changes introduced is the revision of the methodology for calculating the GAR, as well as the elimination
of templates related to the disclosure of activities connected to nuclear energy and fossil gas, which are now reported
in aggregate form in a single template.
In accordance with the current regulatory framework and in light of clariﬁcations published from time to time by the
European Commission
8
:For the ﬁnancial year ended 31 December 2025, the VUB Group prepared the following
indicators, using the appropriate tabular format where required:
–
Green Asset Ratio (GAR);
–
Key performance indicator relating to ﬁnancial guarantees (FinGuar KPI);
–
Key performance indicator relating to managed ﬁnancial assets (AuM KPI);
–
Key performance indicators for asset managers;
–
Green Asset Ratio – Sectoral information including exposures of the banking portfolio to the ten main sectors
covered by the Taxonomy using counterparty NACE codes, as well as aggregate information on activities in the
nuclear and fossil gas sectors;
–
Share of exposures in Taxonomy-aligned economic activities with reference to the other four environmental
objectives and new economic activities introduced for the ﬁrst two environmental objectives.
For more details on the tabular representation of these indicators, see Annex I – Taxonomy Template of this
Consolidated Sustainability Report.
7
The minimum safeguards are procedures implemented by a company carrying out an economic activity in order to ensure that it is in line with
the OECD guidelines for multinational enterprises and with the United Nations Guiding Principles on Business and Human Rights, including the
principles and rights established by the eight fundamental conventions identified in the International Labour Organization's declaration
on fundamental principles and rights at work and by the International Charter of Human Rights.
8
In 2025, the Group analysed the provisions of the Commission Notice of 8 November 2024 published in the OJEU and the further set of
clarifications published in draft format on 17 December 2025, defining the necessary actions to adhere to these indications on a best-effort basis
considering the timing and data available. It should be noted that the draft FAQs are not binding.
Reporting in accordance with the EU Taxonomy (EU Regulation 2020/852)
279
TEMPLATE 0: Summary of KPIs that credit institutions must disclose pursuant to Article 8
of the Taxonomy Regulation
Disclosure reference period:
2025
Total exposure to Taxonomy-
aligned activities (currency)
KPI (2) (%)
KPI (3) (%)
% coverage
(over total
assets) (4)
non assessed
exposures (% of
covered assets) (5)
(%)
non assessed
exposures (% of
covered assets)
(5) (%)
Turnover-
based
CapEx-based
Turnover-based
CapEx-based
(%)
Turnover-based
CapEx-based
Main KPI
Green asset ratio
(GAR) – stock
1,766
1,938
11.42%
12.54%
57.91%
2.51%
2.51%
Addition
al KPIs
GAR (flow)
232
301
6.34%
8.22%
13.74%
2.98%
2.98%
Trading book(1)
Financial guarantees
35
48
7.77%
10.46%
Assets under
management
32
56
7.88%
13.72%
Fee and commission
income(1)
Previous reporting period
Disclosure reference period: 2024
Total exposure to Taxonomy-
aligned activities (currency)
KPI (2) (%)
KPI (3) (%)
% coverage
(over total
assets) (4)
non assessed
exposures (% of
covered assets) (5)
(%)
non assessed
exposures (% of
covered assets)
(5) (%)
Turnover-
based
CapEx-based
Turnover-based
CapEx-based
(%)
Turnover-based
CapEx-based
Main KPI
Green asset ratio (GAR)
– stock
1,534
1,768
10.39%
11.98%
58.60%
2.25%
2.25%
Additional
KPIs
GAR (flow)
75
121
2.62%
4.20%
11.41%
5.63%
5.63%
Trading book(1)
Financial guarantees(6)
29
41
3.41%
4.90%
Assets under
management(6)
14
31
5.66%
12.41%
Fee and commission
income(1)
(1) Fees and Commissions (sheet 6) and Trading Book (sheet 7) KPIs shall only apply starting 2028
(2) based on the Turnover KPI of the counterparty
(3) based on the CapEx KPI of the counterparty
(4) % of assets covered by the KPI over banks´ total assets
(5) in accordance with Article 7(8) of this Regulation
(6) KPIs of Financial Guarantees and AuM for 2024 have been calculated using exposures to Undertakings subject to CSRD disclosure obligations only
Note 1: Across the reporting templates: cells shaded in black should not be reported.
As illustrated in the introductory section, the VUB Group has chosen to report, for the 2025 ﬁnancial year, the
Taxonomy KPIs by applying Delegated Regulation (EU) 2026/73, which introduces signiﬁcant methodological
innovations. In particular, the main innovation concerns the revision of the GAR calculation logic, aimed at ensuring
greater consistency between numerator and denominator. The new methodology provides, among other things, for
the exclusion from the denominator, among other items
9
of exposures to counterparties not subject to CSRD,
resulting in an improved indicator value.
The Group has decided not to assess for environmental compliance those assets it determined to be insigniﬁcant,
even though they are eligible assets with a known use of proceeds. Their cumulative value represents less than 10%
of all balance sheet assets included in the denominator of the GAR indicator. These consist mainly of motor vehicle
loans and other forms of ﬁnancing provided to local governments.
The GAR stock Turnover-based of the VUB Group, equal to 11.42%, is made up of the following exposures:
–
Loans to Households collateralized by residential properties that have been assessed as aligned with the
9
In addition to exposures to counterparties not subject to CSRD, the following assets are excluded from the GAR calculation: central
administrations and supranational issuers, exposures to central banks, trading portfolio, derivatives, sight interbank loans, cash and liquid assets,
other asset categories (e.g., goodwill, goods, etc.)
Reporting in accordance with the EU Taxonomy (EU Regulation 2020/852)
280
Taxonomy for the environmental objective of climate change mitigation based on compliance with the relevant
technical screening criteria for buildings contained in Delegated Regulation (EU) 2021/2139 (9.28%).
10
–
Exposures aligned with the Taxonomy towards ﬁnancial (0.44%) and non-ﬁnancial counterparties (1.7%) subject
to NFRD/CSRD.
Regarding comparative data
11
for the previous ﬁnancial year, the VUB Group provides disclosure of ‘Template 0 –
Summary of KPIs that credit institutions must report under Article 8 of the Taxonomy Regulation’, using the new
methodology. The recalculated value as of the previous reporting period of 10.39% (7.12% under the old
methodology) is comparable to the 11.42% recorded in 2025. The increase of about 9.9% is attributable to the
component of loans to households secured by residential real estate and exposures towards non-ﬁnancial
counterparties subject to NFRD/CSRD.
With reference to the KPI related to ﬁnancial guarantees, ﬁnancial guarantees in support of loans, advances and
debt securities that ﬁnance economic activities of ﬁnancial and non-ﬁnancial enterprises and local administrations
12
have been considered.
For the KPI related to managed ﬁnancial activities, the consolidated investments of the VUB Bank and VUB Generali
DSS, a.s. were considered. It should be noted that the value of this indicator should also be read considering that
the managed ﬁnancial activities are largely made up of exposures in investments in European and non-European
companies not subject to CSRD, which are excluded from the calculation.
With reference to the methods of calculating the reported indicators, it is generally noted that:
–
Exposures to ﬁnancial and non-ﬁnancial counterparties with ‘use of proceeds not known’ were weighted based
on Taxonomy-eligible and Taxonomy-aligned Turnover and CapEx indicators for all environmental objectives,
published by such counterparties in their non-ﬁnancial statement (‘actual’ data)
13
and obtained by the Bank
through a specialized infoprovider;
–
Exposures to ﬁnancial and non-ﬁnancial counterparties with ‘use of proceeds known’ were considered to the
extent that the ﬁnanced activities are Taxonomy-aligned economic activities for all environmental objectives. In
particular, for the debt securities component, exposures were weighted based on the eligibility and alignment
percentages for each ISIN and obtained by the Bank through a specialized infoprovider.
Taxonomy in business and financial strategy and in product design
The VUB Group, intends to continue creating value in sustainable way, further strengthening its performance in ESG
issues together with a world-leading parent Intesa Sanpaolo Group.
The VUB Group is aware that the Taxonomy has been designed with the aim of assigning the European banking
system a decisive role in stimulating the real economy to pursue the European Union's ambitious strategy for
sustainable development and the transition to a low-carbon economy, increasing the level of transparency and
comparability of markets. In this context, the VUB Group participates in the ‘EU Taxonomy Green Enhancement’
project of the parent company to respond to the regulatory requirements of the EU Taxonomy, assess the level of
alignment of its exposures to the regulation, and dynamically steer the loan portfolio with particular attention to
new disbursements through the identiﬁcation of new business opportunities, including new products, and a revision
of the pricing incentive system.
10
It is specified that the alignment checks also concerned compliance with the Do Not Significantly Harm (DNSH) criterion for the environmental
objective of adapting to climate change (i.e. physical risk assessment).
11
In addition to the provisions of Delegated Regulation (EU) 2021/2178 Article 8(3), the communication of EU Taxonomy KPIs in comparative
form between year ‘T’ and year ‘T-1’ was addressed in FAQ#4 ‘Draft Commission Notice’ published on 17 December 2025.
12
For the 2025 financial year, financial guarantees attributable to local administrations are included in the calculation of the FinGuar KPI, in line
with the new formulation of Template 1 Annex VI of Delegated Regulation (EU) 2026/73.
13
As foreseen by FAQ no. 3 (Commission Notice of 8 November 2024).
281
ESRS E1 – Climate Change
Introduction
Climate change is increasingly impacting our ecosystems, with disruptive effects on the social well-being, economic
development, and ﬁnancial stability of current and future generations. Transforming the economies toward
sustainability requires not only reducing greenhouse gas emissions to prevent devastating global temperature
increase and ecosystems collapse but also rapidly enhancing community resilience and also adapting the global
consumption and production patterns. In this, the crucial role of ﬁnancial institutions as enablers and catalysts of
economy change, requires deep understanding of the commercial risks and opportunities, and knowing how to act
on them.
VUB Group, with support of the parent Intesa Sanpaolo Group, is aware of both the negative and positive aspects
in this area and internalized this commitment to support the green transition via supporting businesses and the
circular economy as well as reducing its own emissions.
The VUB Group understands transition to sustainability as an innovation-driven process that promotes the transition
to a system of regenerative production and consumption that has economic, social and environmental sustainability
as its goal. Since 2022, the VUB Group brings on the Slovak market ﬁnancial products that enable companies, public
sector entities, and individuals in these transition initiatives.
Materiality assessment process on impacts, risks and opportunities related to climate change
The methods for identifying material topics for the VUB Group is described in detail in the chapter ESRS 2 – General
Disclosures – Double Materiality Assessment.
The impacts, risks and opportunities in the ESRS E1 – Climate change are identiﬁed by taking into account the
speciﬁcities of the VUB Group. In particular, the mapping of such impacts, risks and opportunities was carried out
on the basis of the context in which the VUB Group deﬁnes and implements its activities and business relationships
in the ﬁeld of climate change. This includes internal policies and initiatives supporting the climate neutrality and
energy efﬁciency, as well as safeguards put in place to minimize the negative climate-related impacts within its own
operations and across the upstream and downstream value chain. Additionally, the assessment considered the risks
associated with climate change that the VUB Group may be exposed to. The mapping of impacts also reﬂects the
views of external stakeholders (e.g. expert organizations in the community and environment).
For the purpose of impact materiality, the assessment of the identiﬁed impacts was conducted through interviews
with the internal structures and external stakeholders, as well as through a detailed qualitative-quantitative analysis
of the main relevant indicators related to climate change attributed to the VUB Group, and, where feasible, to
individual locations. The assessment was carried out on the basis of the criteria required by the reference legislation
(i.e. scale, scope, irremediability nature of the impact and probability), In particular, with reference to:
Value Chain
Scope & Assessment Method
Identified Impacts
Own Operations
Physical assets: owned/rented buildings,
branches, offices, ATMs, vehicle fleet.
Geographical scope: Slovakia & Czech
Republic.
Material
Contribution to climate change adaptation and energy
efficiency in own operations through corporate policies
and strategies.
Direct energy consumption and non-renewable energy use
Upstream Value Chain
Review of procurement-related internal
documentation (green procurement rules,
ESG supplier evaluation, ESG questionnaire
feedback).
-
Downstream Value Chain
Analysis of indirect impacts through financed
portfolios, especially in climate-sensitive
sectors. Consideration of credit, market,
strategic risks and sustainability criteria.
Material
Progressive reduction of indirect greenhouse gas emissions
through adherence to dedicated initiatives such as Global
Compact, NZBA, the adoption of internal
financing/investment policies that include the selection of
companies that have defined a Transition plan
Reduction of energy consumption and increasing use of
renewable energy by individuals/businesses
For the purposes of determining ﬁnancial materiality, the relevance of risks and opportunities was assessed through
a dual approach, quantitative and qualitative, applied to the identiﬁed perimeters.
A sustainability issue could be relevant from the short-, medium- or long-term perspective as deﬁned in line with the
time horizons used in the ﬁnancial perspective:
ESRS E1 – Climate Change
282
Scenario Type
Reference Time Horizon
Short-term
1 year
Medium-term
Up to 5 years
Long-term
More than 5 years
Based on the time period, internal benchmarks were taken into consideration (e.g. documentation relating to the
limits of the Group's Risk Appetite Framework, business plan projections, simulations and projections used for
internal purposes for risk analysis consistent with the regulatory and prudential elements to which the Group is
subject) and impacts, risk and opportunities were analysed. However, the results of Double materiality analysis are
not formulated for speciﬁc time horizon expressing the urgency of all the matters.
The VUB Group applies a structured process to identify and assess climate related physical risks across its own
operations and the upstream and downstream value chain. This process includes the identiﬁcation of acute and
chronic climate related hazards using geospatial climate data, sectoral heatmaps, and high emission climate
scenarios. The Group evaluates the exposure and sensitivity of its assets, operational sites, supply chain partners and
ﬁnanced counterparties to these hazards to determine the extent of potential physical risks. The outcomes of this
assessment support the integration of climate related physical risks into the Group’s overall risk management
framework and inform adaptation and mitigation measures.
With regards to physical climate risks in its own operations, along the value chain and within the ﬁnanced portfolio,
the VUB Group has established a process for identiﬁcation and assessment, consisting of the following key steps:
–
Identiﬁcation of climate hazards – analysing potential climate-related physical risks, distinguishing between acute
risks (e.g., ﬂoods, landslides, wildﬁres, wind gusts) and chronic risks (e.g., rising sea level, changes in average
temperatures, changes in precipitation patterns);
–
Identiﬁcation of support tools and climate data (hazard sectorial heatmaps, geospatial analysis, climate models
and the hazard probability of occurrence and impact for each geography). Climate scenarios with high physical
risk are being used.
–
Assessment of exposure and sensitivity for own operations – evaluating assets and operational activities to
determine their level of exposure and sensitivity to identiﬁed climate hazards. This analysis considers the
likelihood, potential severity, and duration of risks, incorporating the speciﬁc geographic coordinates of
operational sites and high physical risk scenarios;
–
Value chain analysis – engaging key suppliers and partners to map physical risks across the supply chain,
assessing the vulnerability of critical assets, logistics infrastructure and strategic raw materials;
–
Financed portfolio assessment – evaluating climate-related risks within the ﬁnanced portfolio by analysing the
exposure of counterparties to physical climate risks. This includes sector-speciﬁc and geographic assessments to
identify vulnerabilities and potential ﬁnancial impacts on lending and investment activities;
–
Integration into risk management systems – incorporating assessment results into the company’s risk
management framework, establishing priorities and developing mitigation and adaptation strategies to minimize
overall vulnerability.
With reference to the loan portfolio, the identiﬁcation of physical risks and the assessment of exposure to these risks
take into account climate projections based on the
NGFS (Network for Greening the Financial System)
climate
scenarios characterized by a high physical risk and, in particular, the Hot House World scenario.
The VUB Group utilizes climate scenario analysis to assess physical risks, with a particular focus on collateral exposure
to climate hazards. The analysis was conducted using hazard maps and geospatial data, aligned with NGFS (Hot
House World) scenarios, to evaluate level of risk (low, medium, high, very high) of potential depreciation of
residential and commercial real estate. The impact of climate-related hazards on ﬁnanced non-ﬁnancial corporate
clients was assessed using sector-speciﬁc heatmaps, geolocation data across the relevant time horizons according to
the maturity, applying NGFS and Shared Socioeconomic Pathways (SSPs) and Representative Concentration Pathways
(RCPs) scenarios, providing insights into the potential future exposure and physical risk.
To ensure a more precise risk assessment, loan portfolios were categorized based on maturity buckets (<5Y, 5-10Y,
10-20Y, >20Y) of the exposure. This approach, while distinct from the broader time horizons used in the Double
Materiality Assessment (DMA), provides a more detailed perspective on risk distribution over time.
With reference to physical risks of own operations the effective operational losses caused by disasters and other
related events (operational risk) were considered. This includes meteorological phenomena, earthquakes, and ﬂoods
that could disrupt business continuity and cause ﬁnancial losses.
Based on the assessment performed, physical climate risks have been consistently identiﬁed as low or very low across
all time horizons and traditional ﬁnancial risk categories (credit, market, liquidity, and operational risk), thus
reinforcing a stable risk proﬁle of the Group.
The VUB Group has established a structured process to identify and assess climate
‑
related transition risks and
ESRS E1 – Climate Change
283
opportunities across its own operations and the upstream and downstream value chain.
This process includes identifying relevant climate
‑
related transition events by applying at least one climate scenario
aligned with limiting global warming to 1.5°C with no or limited overshoot. It also involves assessing how the
Group’s assets and business activities may be exposed or sensitive to these transition events, thereby determining
potential transition risks or opportunities for the undertaking.
With reference to the transition risks, the following analyses were carried out for the different reference perimeters
identiﬁed:
Value chain
Description
Own operations
Operational risks (e.g., regulatory changes, energy transition requirements) and reputational
risks related to any initiatives that may not align with Group's own sustainability
commitments and climate objectives were assessed. This included evaluating potential
challenges in adapting our operations to mitigate climate change impacts effectively;
Upstream
Operational and reputational risks were evaluated concerning our suppliers. Specifically, the
risk of engaging suppliers with insufficient or inadequate climate-related measures, such as
inadequate management of greenhouse gas emissions. The potential for supply chain
disruptions linked to the transition towards low-carbon alternatives were also examined;
Downstream
Downstream value chain: Credit, market, and liquidity risks potentially arising from exposure
to transition risks, such as changes in consumer demand, regulatory pressures, or shifts in
market sentiment were assessed. The reputational risks related to Group's products and
services, especially in light of evolving sustainability preferences among customers and
stakeholders were also considered. Additionally, liquidity risks arising from the potential loss
of institutional investors in case of failure to meet climate-related expectations were
analysed, as that could affect access to capital and the Group’s financial stability.
The identiﬁed transition events and their potential impacts on assets and business activities are as follows:
–
Short-term: Events such as increased pricing of GHG emissions, enhanced emissions-reporting obligations, and
potential legal mandates on existing products or services. These events may lead to higher costs and changes in
consumer behaviour;
–
Medium-term: Risks related to the failure of counterparties to deﬁne a transition plan, such as market risks and
credit risks. These may affect the value of corporate bonds and the ability of counterparties to service debts,
particularly if they fail to transition to a low-emission economy;
–
Long-term: The company may face reputational risks and potential exposure to litigation related to failure to
meet climate targets or align with climate-related goals like those of the Net Zero Banking Alliance. These risks
are linked to long-term exposure to regulatory changes and the transition to a low-carbon economy.
The assessment of transition risks and opportunities has been primarily based on:
–
An analysis of real estate collateral and their EPC (Energy Performance Certiﬁcate) label, providing an overview
of the energy efﬁciency distribution within the loan portfolio;
–
ESG sectoral assessment approach for Non-ﬁnancial corporations (NFCs). This approach, common for all
members of the ISP Group, provides a prudent, worst-case-scenario estimate of the NFCs susceptibility to a set
of risk drivers, including, among others, physical, transition and environmental risk. This approach is mainly
based on qualitative external sources analysis (qualitative top-down element) complemented by leveraging the
granular and forward-looking results of the scenario analysis (quantitative bottom-up element). The top-down
element analyses economic sectors’ vulnerability to C&E risks at large drawing on several external sources, thus
leveraging on multiple perspectives in reaching a conversant evaluation. The bottom-up element leverages on
climate stressed counterparty-level data, providing a more granular and forward-looking insight into the
underlying vulnerabilities of the NFC portfolio. Together, these approaches help identify and qualify the risks
economic sectors are exposed to;
–
A similar screening of individual borrowers, assessing their performance in ESG area through internally developed
ISP Group ESG score.
The Group identiﬁed several assets that need signiﬁcant efforts to be compatible with a transition to a climate-
neutral economy, especially within the 2030 milestone. These assets are mostly connected with downstream value
chain namely ﬁnancing operations to Non-ﬁnancial corporations that did not develop transition plan nor committed
to adequate GHG emission goals or loans collateralized by immovable property with low energy efﬁciency.
The assessment of exposure to transition events has been concluded as follows:
–
Credit risk related to counterparties failing to deﬁne a transition plan is currently assessed as immaterial. The
likelihood of such an event is considered low;
–
Market risk arising from counterparties' failure to deﬁne a transition plan is also assessed as immaterial. This risk
is not highly relevant within the business model of the VUB;
ESRS E1 – Climate Change
284
–
Liquidity risk associated with assets not aligned with sustainability objectives has been assessed as immaterial.
The assessment, including the HQLA relevance analysis, indicates that such assets are unlikely to be classiﬁed as
High-Quality Liquid Assets (HQLA), meaning that their impact on overall liquidity is lower.
The assessment process is expected to evolve over time to incorporate additional forward-looking methodologies for
evaluating transition risks and opportunities, especially further scenario-based analysis such as NGFS or IEA
(International Energy Agency) climate scenarios.
The material risks identiﬁed in the double materiality assessment are described below.
Value Chain
Identified Risk
Upstream, Own
Operations,
Downstream
Material
Reputational risk arising from failure to achieve targets set in support of climate change mitigation (e.g. failure
to achieve targets set within the Net Zero Banking Alliance).
Downstream
Material
Credit risk arising from the failure of counterparty companies to define a Transition Plan and the related inability
to meet debts (e.g. costs for counterparties linked to a failure to define a transition plan towards a low-emission
economy).
Value Chain
Material
Credit risk arising from the failure to define energy efficiency objectives by the counterparty companies and the
related inability to meet debts (e.g. costs for the counterparties linked to a failure to define an energy efficiency
plan for the operating offices).
Changes to materiality of risks in 2025
Changed to:
Sub/sub-sub topic
Value chain
Description
Reasoning
Material
Climate change
mitigation
Downstream
Credit Risk arising from the
failure of counterparty
companies to define a
Transition Plan and the
related inability to meet debts
(e.g. costs for counterparties
linked to a failure to define a
transition plan towards a low-
emission economy)
Higher concentration of clients
in NSF subsectors with
potential impact
Material
Energy
Downstream
Credit risk arising from the
failure to define energy
efficiency objectives by the
counterparty companies and
the related inability to meet
debts (e.g. costs for the
counterparties linked to a
failure to define an energy
efficiency plan for the
operating offices)
Higher concentration of clients
in NSF subsectors with
potential impact
Non-Material
Climate change
adaptation
Upstream,
downstream and own
operations
Reputational risk arising from
the lack of attention towards
objectives supporting
adaptation to climate change
(e.g. reputational impacts
linked to business
interruption)
Re-evaluation, of the
likelihood, which was lowered
for 2025 when compared to
2024. Risk lowered since
adaptation to climate change
is embedded within internal
processes
The material opportunities identiﬁed in the double materiality assessment are described below.
There were no changes in materiality between 2024 and 2025 for impacts and opportunities.
In 2025, the VUB Group advanced its approach to climate resilience by conducting a materiality analysis as a ﬁrst
step toward a comprehensive climate
‑
resilience assessment. This analysis helped identify priority climate
‑
related
impacts, risks and opportunities, and established the foundations for a more structured resilience framework in the
coming years. Building on these results, the Risk Department will lead the development of a full resilience analysis
during 2026, with the aim of progressively integrating more detailed climate scenarios and quantitative modelling
capabilities.
–
the assessment created a Risk Factor Inventory,
–
the Risk Department developed a methodological structure aligned with ECB expectations,
–
the work is intended to feed into later scenario-based resilience analysis.
Selected stress tests were performed to assess the potential impact of ESG-related risks on credit risk. These tests
Value Chain
Identified Opportunity
Own
Operations
Material
Improved brand reputation/positioning resulting from the adequate definition and achievement of objectives in support of
climate change mitigation (e.g. achievement of objectives resulting from membership of the Net Zero Banking Alliance)
ESRS E1 – Climate Change
285
are part of the 2025 ICAAP/ILAAP Adverse scenario and focused on estimating potential effects on risk-weighted
assets (RWA) and proﬁt/loss (P&L). The stress test methodology includes:
–
Corporate portfolio: Economic sectors were classiﬁed by ESG sensitivity based on an internal methodology. The
probability of default (PD) was adjusted according to sector classiﬁcation;
–
Retail mortgages: Energy Performance Certiﬁcates (EPC) were used as an indicator of transition risk, with
adjustments applied to loss given default (LGD);
–
Flood event scenario: Potential effects of ﬂooding were modelled for the retail portfolio, considering increased
PD for affected borrowers and higher LGD for unsecured loans.
The approach is based on expert judgment and does not use climate scenario models such as NGFS or IEA.
–
The methodology is under development and may be expanded in the future to incorporate additional factors.
–
The stress test analysis shows that the VUB Group is able to maintain a sound capital adequacy even under an
adverse scenario.
VUB Group recognizes the value of a comprehensive resilience analysis and intends to further develop this approach
in the future, especially in relation to more detailed climate scenarios.
The Group has conducted a partial assessment of the resilience of its business model as part of the DMA process,
during which the main impacts, risks and opportunities related to climate change were identiﬁed. The results of the
dual signiﬁcance analysis are subsequently discussed with the executive management, which takes measures to
reduce the adverse impacts of the identiﬁed risks. These measures will be gradually incorporated into the Group's
long-term strategic plans.
For impacts and opportunities, there were no changes in signiﬁcance between 2024 and 2025.
Connection to climate-related assumptions in ﬁnancial statement
The company has utilized climate scenarios primarily for the identiﬁcation and prediction of climate-related risks.
Most assessed risks were determined to be immaterial, and as a result, no direct integration of climate scenario
outcomes into ﬁnancial statement assumptions has been made at this stage.
However, reputational risk related to climate targets and commitments were assessed as material, but they have not
yet been quantiﬁed or directly linked to ﬁnancial statement assumptions. To ensure proactive risk management, the
company has established limits and early warning indicators to monitor potential future developments and reassess
materiality if necessary.
Integration of climate-related performance in incentive schemes
The VUB Group, in line with ISP Group approach, considers it essential to address and monitor climate-related issues
and therefore implemented intermediary objectives in the incentive system.
The ESG KPI (key performance indicator) was assigned in the 2025 Remuneration and Incentive Policies
documentation to the CEO as well as all Risk Takers, Middle Managers in Business and Governance Functions of the
VUB Group in Slovakia and the Czech Republic. The characteristics of the KPI are in line with the growing attention
on these issues by the Group's Customers, Shareholders, Regulators and other Stakeholders.
With speciﬁc reference to the variable remuneration of the Managing Director and CEO, climate aspects are taken
into account both in the Annual Incentive System (15% weight) and in the long-term incentive plan.
Speciﬁcally, the KPIs are linked to the ﬁnancing of clients in transition to sustainability:
1.
% of new production of Sustainable Loans to Retail Customers;
2.
% of new production of Corporate & SME Sustainable Loans.
With reference to variable remuneration for Management – including the CEO, the remaining Top Management
Risk Takers of the Group and other Group Risk Takers – climate
‑
related aspects are also factored in through the
Performance Share Plan (PSP). Within the PSP, the Composite ESG KPI directly inﬂuences the number of shares that
vest. Underperformance against ESG targets may result in a 10–20% reduction of the vested portion.
More information on remuneration and incentive schemes can be found within ESRS 2 – Integration of sustainability-
related performance in incentive schemes – Long-Term Incentive Plan structure.
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286
Strategy for combating climate change
Policies related to climate change mitigation and adaptation
Climate change represents one of the most signiﬁcant global challenges of our time, with far-reaching impacts on
the natural environment, human health, and economic prosperity. Effectively combating this existential threat
requires a well-crafted, multidimensional strategy that encompasses global collaboration, technological innovation,
policy reform, and community engagement. The VUB Group, recognizing the crucial role that ﬁnancial institutions
can play in this area, has developed and adopted a series of policies governing its business operations, resource
procurement, ﬁnancing and investments to address climate change mitigation, adaptation, energy efﬁciency,
renewable energy deployment, and transition to climate neutrality of the economy.
These policies incorporate the interests of stakeholders, collected through targeted surveys and dialogues, while also
considering feedback from rating agencies and ﬁnancial regulators.
In 2020, the VUB Bank, as a pioneer in the Group in Slovakia, published the
Green Manifest
where it declared its
commitment to sustainability and environmental protection, as an integral part of its business DNA. With regards to
climate change, Green Manifest declares supporting the transition to carbon neutral economy. The Bank is
committed to supporting its clients by providing sustainable banking products and services while continuously
enhancing internal standards and processes. It prioritizes energy efﬁciency, emphasizes the use of renewable energy
sources, and collaborates with suppliers who share its commitment to sustainability and engages employees by
fostering a culture of environmental responsibility. Furthermore, the Bank supports the non-proﬁt sector through
partnerships that promote environmental education, and climate change awareness in Slovakia. In this effort, VUB
Bank is accompanied by its subsidiaries and strongly supported by the parent Intesa Sanpaolo Group.
The cornerstone of VUB Group's environmental policy is its Code of Ethics, a binding document outlining standards
and principles for managing and controlling bodies, for employees and contracted third parties in line with the
commitments made by the ISP Group in relation to international initiatives: UN Global Compact, the contribution to
the Sustainable Development Goals, the Women's Empowerment Principles, the Net Zero Alliances as well as the
PRB Principles for Responsible Banking, PRI Principles for Responsible Investment and PSI Principles for Sustainable
Insurance Programs under the United Nations Environment Program Finance Initiative (UNEP FI). It promotes efﬁcient
and conscious resource use, sustainable decision-making, and ﬁght against climate change. The Code also provides
guidelines for management of indirect environmental impacts in value chain among others by promoting services
and products to foster the development of a low-emission economy, also through the dissemination of renewable
energy and energy efﬁciency improvement. It also speciﬁes the principles of the process of managing purchases of
goods and services:
–
Transparency and fairness in the selection and qualiﬁcation of suppliers throughout the entire supply chain, also
evaluating local speciﬁcities, respect for the environment, human rights, working conditions, business ethics;
–
The adoption of measures and tools aimed at minimizing negative impacts and promoting awareness of ESG
risks and opportunities.
The document is publicly available on the Bank's website for all stakeholders
(Code of ethics | VUB Bank)
.
The implementation of the Code of Ethics has resulted in supplementary policies and procedures aimed at speciﬁc
areas of operations. For resource procurement, it is the Green Banking Procurement Rules that ensure responsible
purchasing in areas such as energy, ofﬁce materials, and sustainable renovations via identiﬁcation of the best design
solutions, products, or services from an environmental perspective throughout its life cycle, considering market
availability. Key impacts considered include energy consumption and the resulting carbon dioxide emissions, waste
generation, and the consumption of materials such as paper, toner, stationery, and ofﬁce machines. The choice of
supplier takes into account not only its specialization in the required product ﬁeld and its economic and ﬁnancial
stability but also its reputational and sustainability proﬁle across all ESG areas. This includes assessing potential
external risks, such as ongoing judicial and insolvency proceedings.
In its operations, the Group adheres to the Environmental and Energy Policy of the Intesa Sanpaolo Group. This
policy aims to minimize environmental impacts, manage ESG risks, and ensure compliance with regulations. It
emphasizes efﬁcient resource and energy use, careful supplier selection based on ethical, social, and environmental
criteria, and the prevention of environmental harm.
The Guidelines for the Governance of environmental, social and governance (ESG) risks address climate change
within the broader context of environmental risks across operations, the value chain, and the ﬁnanced portfolio.
These guidelines aim to mitigate material risks associated with climate change and support the transition to a low-
carbon economy. The guidelines establish a framework for managing sustainability risks, stating key principles,
specifying sectors sensitive to ESG or reputational risks, deﬁning responsibilities, and monitoring mechanisms. The
core focus is placed on limiting exposure to high-carbon industries, integrating ESG risk factors into credit policies,
and promoting sustainable ﬁnancing solutions. The effectiveness of the policy is monitored through internal limits,
ESRS E1 – Climate Change
287
ESG Committee oversight, and risk appetite thresholds.
The guidelines apply across the entire Group, including all banking activities, risk management processes, and
ﬁnancing operations. They cover both corporate and retail portfolios, ensuring ESG factors are assessed in client
screenings and sectoral risk evaluations. Exclusions apply primarily to the coal mining and oil and gas sectors, where
stricter rules aim at phasing out exposure for coil mining.
The policy aligns with international sustainability frameworks, including the UN 2030 Agenda, the European
Commission’s Action Plan for Sustainable Growth, the EBA Guidelines, and ECB expectations.
The policy takes into account the interests of key stakeholders, including regulators, investors, and clients, by
balancing ﬁnancial stability with sustainability goals. In lending activities, sustainability-linked ﬁnancing and advisory
services are provided to help clients transition to greener business models.
The policy is integrated into internal governance frameworks and embedded in the Group’s risk appetite and credit
policies, which deﬁne VUB Group’s lending portfolio strategy for each relevant sector based on ESG aspects, among
others. Relevant guidelines are communicated to stakeholders through corporate reports, regulatory disclosures, and
direct engagement with clients and investors.
In order to steer the development of ﬁnanced portfolio, the Group equipped itself with Rules for the classiﬁcation
of sustainable credit products and operations. This regulation applies to Group companies and outlines various
categories of environmentally sustainable activities, with internal criteria different from the European Taxonomy, in
favour of both climate change mitigation and climate change adaptation. The classiﬁcation categories of credit
products and sustainable credit operations have been deﬁned in line with the internationally recognized guidelines
of the Loan Market Association (LMA) on Green Loan, Social Loan and Sustainability-linked Loan Principles. These
principles provide a shared framework at a global level, promoting standardization and transparency of practices in
the sustainable ﬁnancial sector.
The Group publicly declares its commitment to the environment across all activities – from the creation of ﬁnancial
products, through procurement and negotiations with suppliers, to the impact of operating its own buildings and
premises.
The above-mentioned internal policies are accessible to respective internal stakeholders via the Group’s intranet.
The main goal of the Environmental Social and Governance Committee (‘ESG Committee’), as a permanent
consultative and decision-making committee of VUB Bank, is to coordinate and steer ESG related matters and to
ensure the correct implementation of the ESG strategy, policies and respective ISP Group guidelines within the VUB
Group. It also regularly evaluates policy effectiveness, reviews sustainability KPIs, and oversees risk mitigation
measures.
It is headed by the Deputy CEO who acts as ESG Manager – the top management level responsible for the
implementation of the policies in sustainability area.
ESG risk governance process
The ‘ESG Risk Governance Guidelines’ outline the ESG risk governance process of the Group (also on climate change
adaptation issues), which is divided into 5 phases:
1.
Identiﬁcation: Identiﬁcation and description of ESG risk factors, also in terms of transmission channels, with
particular reference to climate and environmental risks (for example, ESG risk scenarios in Stress Testing
processes);
2.
Evaluation and measurement: Determination of exposure to ESG risks (e.g. the ESG & Reputational Risk
Clearing process);
3.
Monitoring and control: Outpost in the continuous evolution of exposure to ESG risks (regular reporting of
ESG risks to ESG Committee, monitoring of established ESG KPIs in the Risk Appetite Framework);
4.
Mitigation: Containment of ESG risks through appropriate actions and strategies, also preventive, aimed at
reducing the severity of the impact of such risks (for example, deﬁning remedial actions in case of exceeding
ESG limits in the RAF, deﬁnition of Credit Strategies for all relevant sectors);
5.
Communication: Preparation of suitable information ﬂows aimed at ensuring adequate transparency and
knowledge of exposure to ESG risks (for example, ESG risk reporting and ESG risk disclosures, including
indicators that factor in physical climate risks).
In particular, with reference to the above-mentioned evaluation and measurement phase, the ESG & Reputational
Risk Clearing process has been implemented. It aims to identify and assess ex ante the potential ESG and reputational
risks (including climate and environmental risks) related to credit proposals, supplier/third-party selection connected
to commercial agreements, equity investments, and extraordinary transactions.
The ESG & Reputational Risk Clearing process is therefore intended to represent the potential ESG and reputational
ESRS E1 – Climate Change
288
risk proﬁles related to a speciﬁc operation/counterparty or initiative, enabling an informed assumption of risk for the
interested decision-making processes. A ﬁrst level of clearing, carried out by the line functions, is aimed at analysing
the main ESG and reputational risk factors and is performed by the structure that manages the relationship with the
counterparty. In this context, credit proposals are subject to ﬁrst-level clearing with differentiated methods based on
sectoral assessments and the characteristics of the individual counterparty and operation. A second level of clearing,
activated based on the results of the ﬁrst level, is aimed at deepening and evaluating the critical issues that may have
emerged from the ﬁrst level and involves an expert analysis of these risk proﬁles. Generally, the outcome of the
evaluation consists of an advisory opinion that includes an assessment of the main critical issues identiﬁed, the
related mitigants, and the level of risk assigned based on proprietary metrics. In the presence of risk classes that are
not consistent with the Group's risk propensity, speciﬁc escalation mechanisms are activated.
The implementation of the Equator Principles (EP) is situated within the broader framework of ESG risk assessment
and management. These principles establish a framework for environmental and social risk management in the
ﬁnancing of large projects, thus strengthening the commitment to managing the impacts associated with customer
business activities. The EPs are international guidelines that the Intesa Sanpaolo Group adheres to on a voluntary
basis since 2007, using the latest updated version (EP IV) applicable to the ﬁnancing of infrastructure and industrial
projects that can have negative effects on people and the environment (such as energy plants, petrochemical plants,
mines, infrastructure in the ﬁeld of transport and telecommunications). These principles are based on the criteria of
the International Finance Corporation (IFC) of the World Bank and concern, regarding to environmental issues:
pollution prevention and the promotion of energy efﬁciency; the preservation of biodiversity and the sustainable
management of natural resources.
The EP apply, regardless of the industrial sector in which the customer operates, when ﬁnancing product is used to
support the development of new projects and meet speciﬁc criteria:
The project evaluation process begins with the assignment of a risk category on three levels by the Group, which
involves the integrated consideration of various factors. Proportionally to the assigned risk level, the requirements to
be met are deﬁned in terms of both documentations to be produced, and activities to be carried out by the customer.
In this context, the Group incorporates environmental and social clauses into the ﬁnancing documentation and
veriﬁes the correct implementation of the agreed clauses.
Management of sustainability issues in sensitive sectors
At the portfolio level and with reference to decarbonization objectives, the ESG Risk Management Guidelines also
detail the ESG risk management model based on the materiality assessment of ESG risk factors with respect to the
different risk families (credit risk, market risk, operational risk, liquidity risk, and reputational risk) and their
integration into the various risk management areas. The materiality analysis (Climate/ESG Materiality Assessment) is
an evaluation process that assesses the potential impacts of ESG and climate risks on the Group. This analysis is
based on an organic and structured approach to risk assessment, which involves a granular breakdown of risk drivers
and the integration of forward-looking elements. The aggregated analysis of the materiality of ESG risk factors at
the sector level facilitates the establishment of an enhanced risk management framework for the sectors most
exposed to ESG risks. This process includes deﬁning sector-speciﬁc strategies and implementing speciﬁc measures
within the Risk Appetite Framework (i.e., the RAF). These measures may consist of general criteria for limiting and
excluding loans or a detailed criteria applicable to individual sensitive sectors through the application of speciﬁc
sectoral rules.
GHG emissions reduction targets
The Intesa Sanpaolo Group, aware of the challenge posed by climate change, has committed to contributing to the
achievement of global climate goals, by pursuing the Net-Zero goal by 2050 in terms of both own emissions and
loans and investments portfolios, also by setting intermediate targets by 2030.
The VUB Group, as part of Intesa Sanpaolo Group, contributes and fully commits to fulﬁlment of the targets at the
ISP Group level. Therefore, it has not set GHG emissions reduction targets or adopted transition plan at its own
consolidation level. The Group aims to work toward the development of a transition plan. The exact scope and
timeline will be determined in alignment with the parent company’s consolidated approach and subject to the results
of further internal discussions.
Nevertheless, the VUB Group is contributing to parent Intesa Sanpaolo Group's plan for the reduction of its ‘own’
emissions, adopted in 2022 and conﬁrmed within a new Business plan for 2026-2029, called the ‘Own Emissions
Plan’, which is compliant with Science Based Target Initiative (SBTi) protocol (validation obtained in January 2025).
In determining its decarbonisation levers, the Intesa Sanpaolo Group considers a diverse range of climate scenarios—
including a baseline pathway compatible with limiting global warming to 1.5°C, as well as three additional reference
scenarios (Hot House World, Orderly Transition and Disorderly Transition). The VUB Group aligns its approach with
these Group
‑
level scenarios.
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289
The Own Emissions Plan progress is periodically shared during the meetings of the ESG Committee.
Other targets related to climate change mitigation and adaptation
Portfolio level
To achieve the objectives for reducing emissions and to accompany customers on their path towards
decarbonization, intermediary 2030 emission reduction targets were set on the ISP Group level, which includes the
VUB Group. These targets focus on sectors identiﬁed based on a materiality criterion among those with the highest
emission intensity as per NZBA. The VUB Group has not set targets on its own consolidated level.
To support this objective, the VUB Group has identiﬁed several levers:
–
Dedicated products and incentives, including:
o
Access to a credit ceiling dedicated to the circular economy, aimed at customers who adopt a
circular business model with innovative methods, granting them supportive conditions for access
to credit. The ceiling does not follow the technical screening criteria of the European Taxonomy,
having been developed before its entry into force, in close partnership with the Ellen MacArthur
Foundation;
o
Green ﬁnancings aimed at ﬁnancing projects with a signiﬁcant environmental impact;
o
Sustainability-linked ﬁnancing that provides a discount/bonus mechanism as an incentive for
customers who meet predeﬁned sustainability targets;
o
Advisory services to support customer decarbonization and accompany them in the utilization of
proper ESG ﬁnancial tools linked to their strategies and transition plans.
To ensure constant progress, internal KPIs have been set in both Retail and Corporate banking Divisions and their
development is being monitored regularly by ESG Committee.
Actions and resources related to climate change
To support ISP Group in its climate change mitigation and adaptation objectives, the VUB Group has designed several
action types:
–
In 2025, the Group continued to strengthen these efforts, particularly through the improvement of its physical
infrastructure — focusing on energy efﬁciency measures, increased use of renewable energy, and the reduction
and avoidance of GHG emissions in the operation of its own buildings;
–
Continued improvement of data—enriched also through in
‑
house surveys among Group counterparties—and
IT infrastructure, together with the ongoing enhancement and expansion of internal policies to ensure full
alignment with the Intesa Sanpaolo Group’s frameworks and methodological standards;
–
Continued development of the sustainable product portfolio by expanding ﬁnancing options for small
businesses—introducing the Green Proﬁ Loan, Green Proﬁ Mortgage and Green Car Finance—and by further
broadening the range of sustainable investment opportunities offered through VUB Generali DSS and Eurizon.
Eurizon Asset Management Slovakia, správ. Spol., a.s., is a fund manager and these funds are offered as
products by the VUB Bank, but it is not a part of the VUB Group, to which this sustainability report applies. In
addition, as part of our innovation efforts, we developed a Real Estate Simulator that helps homeowners
estimate potential savings from energy
‑
efﬁcient upgrades, indicates expected EPC improvements, and supports
informed decision
‑
making; the tool is publicly accessible free of charge.
–
Awareness raising and marketing support for dedicated ﬁnancial products and incentives;
–
VUB continues in its own ‘ATLAS’ series of conferences, discussions, and panel talks focused on good practices,
innovation, and knowledge sharing, launched in 2022;
–
Partnerships with professional organizations for knowledge sharing.
This involves both knowledge sharing for improvement of Group's own infrastructure, practices and strategies, as
well as improvement of the sustainability of the overall economy, primarily in Slovakia and the Czech Republic. The
Group is active in the following areas where awareness raising, education, best practice and knowledge exchange
projects and events enable mitigation and/or adaptation to climate change:
–
Sustainable buildings and their energy efﬁciency, sustainable construction and renovation; e.g. Buildings For
Future, Slovak green building council;
–
Sustainable urban planning, climate change adaptation of cities, and green infrastructure; e.g. Institute for
Passive Houses, International Climate Adaptation Institute, Manifest2020;
–
Circular economy, waste reduction, and sustainable procurement; e.g. Circular Slovakia, Sustainable e-shop
project with VISA and Heureka;
–
Sustainable and biodiversity friendly agriculture and food production; e.g. Living Farm project of
Environmentalist association BROZ;
–
Environmental education and support for innovation for children and young people, e.g. For Better Future of
ESRS E1 – Climate Change
290
Earth, Lifbee Academy;
–
Support for relevant programs and projects of VUB Foundation.
This includes ﬁnancial support, provision of creative agency services, and covering marketing costs for projects and
programs Envirogrants, and ATLAS Award to raise public awareness, motivate and foster the shift towards
sustainability.
Climate change actions and resources at the own operation
In line with ISP Group commitment to addressing the climate change, the VUB Group has implemented and planned
a series of key actions aimed at mitigating its environmental impact and achieving Group´s medium- and long-term
sustainability goals:
1.
Energy Efficiency Initiatives:
o
VUB Group is progressively replacing obsolete and ineffective energy appliances – air conditioning
and electrical systems at selected sites, speciﬁcally by LED re-lamping , refurbishment of HVAC
systems, complete refurbishment of electricity consuming systems, replacement of heating and hot
water preparation, replacement of windows and building envelope insulation
o
VUB Group is researching possibilities of replacing the cooling gases with ozone depleting potential
(ODP) and high global warming potential (GWP) with environmentally friendly substitutes
2.
Transition to Renewable Energy:
o
Installation of renewable energy sources (mainly photovoltaic panels and heat pumps) on the VUB
Group´s buildings,
o
Purchase of renewable electricity for owned buildings (started in 2025)
o
VUB Group is researching possibilities to purchase renewable electricity for rented premises via
unbundled contractual instruments
3.
Fleet and Mobility Enhancements:
o
The company car ﬂeet is undergoing a gradual transition to hybrid and fully electric vehicles.
o
Installation of charging stations for electric vehicles at VUB Group´s premises.
4.
Infrastructure Improvements:
o
VUB Group is researching possibilities of buildings insulation and application of green roofs and
green walls.
5.
Paper and Material Usage Optimization:
o
The VUB Group has long sought and implemented strategies to reduce paper and material
consumption. From 2024 onwards, all ofﬁce paper is being procured exclusively from eco-friendly,
sustainable sources, from 2025 only certiﬁes recycled paper is used.
o
Digitalization of the banking services is the main action in paper use reduction.
6.
Green procurement for selected materials and services:
o
IT and ofﬁce machines
o
Bank cards from recycled plastics
o
Safe and sustainable events
o
Business travel
These actions are expected to contribute signiﬁcantly to the reduction of the Group’s negative impacts in medium-
term and serve as building blocks for long-term sustainability extending to 2050 Medium-term objectives include
completing infrastructure upgrades and expanding the deployment of sustainable technologies.
An exact quantiﬁcation of the emission reductions associated with individual actions within our own operations is
not feasible, given the complex relationship between speciﬁc measures implemented and the resulting emission
trends across operational sources.
The Bank leverages its annual capital budget cycle to ensure funding for these measures while strategically allocating
resources to areas of the highest impact. Successful implementation is also contingent on access to appropriate
technologies, employee expertise, and supportive regulatory frameworks.
Climate change actions and resources at the portfolio level
In line with the regulatory evolution on sustainability, the Group adopts a medium-long term strategy and a cross-
cutting and holistic approach to ESG issues, which is based on:
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–
The deﬁnition of a Group ESG strategy;
–
The integration of ESG factors into the general Risk Management framework, particularly within the Risk
Appetite Framework, where a speciﬁc section is dedicated to ESG risks and climate change;
–
The integration of ESG factors in credit processes and in the deﬁnition of credit strategies;
–
A careful evaluation of ESG factors in the development of policies, products and services;
–
The spread of ESG risk culture throughout the corporate organization.
With reference to climate change mitigation, the integration of ESG risks into the Risk Management framework
takes place through various actions. In particular, the RAF integrates and translates into speciﬁc measures what is
deﬁned in terms of strategic guidelines, ESG/Climate Materiality Assessment and ESG Sectoral Colour Coding,
identifying year by year limits, Key Risk Indicators, and speciﬁc actions aimed at containing ESG risks, with particular
reference to the sectors most exposed to such risks.
–
Speciﬁc limits with reference to exposure to the Coal Mining and Oil & Gas sectors, particularly for Coal mining
the limit is revised annually in line with the objective of phasing out ﬁnancing by 2025;
–
The monitoring of new disbursements broken down by energy performance classes (EPC) with the aim of
improving the quality of residential properties taken as collateral and, consequently, reducing the transition risk
related to mortgage loans;
–
Speciﬁc Risk appetite limits on share of collateral with EPC classes F and G and with Very high physical risk in
the Retail Mortgage portfolio, with the aim of improving the quality of residential properties taken as collateral
and consequently, reducing the risk of transition and physical risk related to mortgage loans. In particular, with
reference to the lower energy performance classes (APE certiﬁcations) and areas with very high physical risk;
–
Transactions with potentially high ESG risks undergo ESG & Reputational Risk Clearing process, utilizing the ESG
proﬁle and score of the counterparty and considerations on the impacts that physical and transition risk drivers
can have.
Within the ESG & Reputational Risk Clearing process, where the ESG proﬁle and score of the counterparty are used,
which also includes considerations on the impacts that physical climate risk drivers might have.
The actions reported are implemented as an essential part of the Group's strategy for managing climate risks and
do not require speciﬁc dedicated resources exclusively for these actions, as they are included in the general context
of the Group's ESG strategy.
An exact quantiﬁcation of the reduction of emissions associated with each action at portfolio level is not feasible,
due to the complex connection between the actions taken and the trend of emissions in the reference sectors of the
counterparties.
In 2025, the VUB Group continued its commitment to retail customers, both individual and small business, through
the provision of mortgages and loans with environmental purposes.
Via Green mortgages, the VUB Bank incentivizes clients with a preferential interest rate for ﬁnancing a purchase of
a property with high energy performance class (‘A’). Clients with other properties are encouraged to assess their
energy efﬁciency and when they provide a valid EPC, they receive a reduction of loan granting fee. In addition to
offering a new mortgage the VUB Group has implemented a series of activities aimed at collecting the information
on the energy performance of the properties that guarantee existing mortgages, which further raises awareness
among clients and allow the Bank to precisely manage the associated transition risk.
Green loan is a ﬁnancial solution with incentive for clients who want to improve energy performance through, for
example, the replacement of windows and high-yield boilers, insulation and the installation of solar and photovoltaic
panels.
To support sustainable transition of SME and Corporate clients, the VUB Bank introduced the TERRA product line,
offering loans with preferential interest rates to support sustainability in areas of environmental, social and
governance sustainability. Within the TERRA Enviro two products are offered:
–
GREEN S-LOAN+: Dedicated loan to support all types of corporate investments and projects capable of
generating a positive environmental impact on processes, infrastructures, technologies, services and products in
line with the LMA categorization (e.g., Renewable energies, Energy efﬁciency, Pollution prevention and control,
environmentally sustainable management of natural resources, Clean transportation, Sustainable water and
wastewater management, Climate change adaptation, Eco-efﬁcient and/or circular economy, Green buildings
or Projects aimed at activities with zero CO2 emissions, such as electricity production using solar, wind, oceanic,
hydroelectric technology). When granting the loan, the client also undertakes to complete project within the
agreed deadline.
–
ENVIRO LOAN: Dedicated loan supporting circular economy projects, including resource efﬁciency, extending
the service life of products or materials, sustainable sourcing, recyclability, and green innovation. For these loans,
individual ESG KPIs can be set up with the client.
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Amount disbursed in Retail Business line relates predominantly to Mortgage loan with EPC A and B. The disbursed
data of the ﬁnancings are calculated using management balances.
The VUB Group supports sustainable choices of clients also in the area of investments. Please refer to the standard
ESRS S4 – Metrics related to Access to products and services, Non-discrimination and Responsible marketing
practices.
Actions and resources related to supply chain
To manage the impacts from value chain, each vendor undergoes a qualiﬁcation process through the Supplier Portal.
The evaluation of registered suppliers considers not only their economic-ﬁnancial and technical-organizational
characteristics but also aspects related to business ethics, respect for human rights, workers' rights, and the
environment. This evaluation is based on speciﬁc questionnaires and/or the possession of certain certiﬁcations
(including ISO 50001 and 14001, and the adoption of an energy management system compliant with ISO 50001
standards). Completing the ESG questionnaire became mandatory in 2024, as a prerequisite for participating in
tenders or direct negotiations through the Supplier Portal and the ESG evaluation was incorporated into the technical
assessment of the supplier’s offer in the tender evaluation. VUB Group adopts actions continually to transform its
supply chain to sustainable, in accordance with the Group´s Green procurement rules.
The main activity in transformation of the supply chain to sustainability in 2025: VUB Group has started to procure
100% of the electric energy consumed in owned buildings from certiﬁed renewable energy sources since 2025, thus
contributing to the ISP Group´s objective of reaching 100% RES in 2030.
VUB Group also continues activities and negotiations with the landlords in order to ensure renewable electricity also
for its rented buildings.
Metrics on energy consumption
The goal of the VUB Group is to reduce the consumption of primary energy in its own buildings as well as in rented
branches. The total energy consumption consists of electricity consumption, including that of e-vehicles, natural gas
consumption in own boiler rooms, and heat/cold taken from district heating/cooling supply in both owned and
rented buildings, and fuel for diesel back-up generators, and company ﬂeet. Within the individual energy
components, the source from which the energy is produced is assessed.
The actions implemented by VUB Group in 2025 to transition to sustainable energy and contribute to the declared
ISP Group´s 2030 objective of 100% renewable energy:
–
The electricity in owned buildings has been purchased from renewable sources bundled with contractual
instruments – Guarantees of Origin (GOs) since 2025. The renewable electricity share on the total electricity
purchase in 2025 thus represents 68.89%.
–
VUB Group has commenced its own renewable electricity generation from photovoltaic power plant located on
the roof top of the headquarters building in Bratislava in May 2025, and produced 66.31 MWh
el
together in
2025, all of which has been consumed in the building.
–
Fleet electriﬁcation is ongoing, and VUB Group has 18% of its ﬂeet full electric or hybrid vehicles, comparing to
3% in 2024
Change of reporting methodology for 2025: In connection with the purchase of renewable electricity under
guarantees of origin (GO), the remaining electricity consumed in leased premises (buildings and ATMs), where VUB
Group has no operational control over the supply of electricity or information on the energy mix, is reported as
electricity from fossil fuels in accordance with the GHG Protocol.
ESRS E1 – Climate Change
293
Energy consumption and mix
The energy consumption and mix for the current and the previous year are described below, including recalculation
of 2024 data with the new methodological approach, for comparison.
Energy consumption and mix (in MWh)
2025
2024 recalculated with
2025 methodology
2024
Total energy consumption
17,696
17,305
17,305
Total fossil energy consumption
12,263
16,929
10,367
Fuel consumption from coal and coal products
0
0
0
Fuel consumption from crude oil and petroleum
products
2,459
2,629
2,629
Fuel consumption from natural gas
1,645
1,184
1,184
Fuel consumption from other fossil sources
0
0
0
Consumption of purchased or acquired electricity,
heat, steam, and cooling from fossil sources
8,160
13,116
6,554
Share of fossil sources in total energy consumption
69.30%
97.93%
59.91%
Consumption from nuclear sources
0
0
4,016
Share of consumption from nuclear sources in total
energy consumption
0%
0%
23.21%
Total renewable energy consumption
5,433
376
2,922
Fuel consumption from renewable sources
0
0
0
Consumption of purchased or acquired electricity,
heat, steam, and cooling from renewable sources
5,366
376
2,922
Consumption of self-generated non-fuel renewable
energy
66
0
0
Share of renewable sources in total energy
consumption
30.70%
2.17%
16.88%
Non-renewable energy production
0
0
0
Renewable energy production
66
0
0
Total energy consumption from activities in high
climate impact sectors
0*
0*
0*
Total energy consumption from activities in high
climate impact sectors per net revenue from
activities in high climate impact sectors
0*
0*
0*
* No income from high climate impact sectors
Exposure in high climate impact sectors
The VUB Group doesn’t have activity and revenues from high climate impact sectors.
ESRS E1 – Climate Change
294
Metrics on GHG emissions
Gross Scopes 1, 2, 3 and Total GHG emissions
VUB Group monitors and reports data on greenhouse gas emissions arising within its own operations, as well as at
the level of the entire portfolio, covering scopes 1, 2 and 3. Below is an overview of emissions expressed in tCO
₂
for
2025 and 2024.
GHG emissions (in tCO
2
e)
2025
2024 recalculated with
2025 methodology
2024
Greenhouse gas (GHG) emissions Scope 1
GHG emissions Scope 1
1,210
949
949
Percentage of Scope 1 emissions from regulated emissions trading
systems
-
-
-
Greenhouse gas emissions (GHG) Scope 2
GHG emissions Scope 2 location-based
1,959
2,050
2,050
GHG emissions Scope 2 market-based
2,057
3,892
1,331
Percentage of contractual instruments Scope 2 emissions
36.47%
0%
18.87%
Greenhouse gas emissions (GHG) Scope 3
GHG emissions Scope 3
2,435,216
3,500,080
3,506,887
Percentage of Scope 3 emissions calculated using primary data
16.01%
10.19%
8.9%
1. Purchased goods and services
85
81
81
2. Capital goods
264
254
254
3. Fuel and energy-related activities
1,211
1,477
704
4. Upstream transportation and distribution
1,069
823
823
5. Waste generated in operations
13
6
6
6. Business travel
7
-
-
7. Employee commuting
-
-
-
8. Upstream leased assets
-
-
-
9. Downstream transportation
-
-
-
10. Processing of sold products
-
-
-
11. Use of sold products
45
30
30
12. End-of-life treatment of sold products
-
-
-
13. Downstream leased assets
38
42
42
14. Franchising
-
-
-
15. Investments
2,432,483
3,497,365*
3,504,945
Total GHG emissions
Total GHG emissions (location- based)
2,438,385
3,503,078
3,509,885
Total GHG emissions (market- based)
2,438,483
3,504,920
3,509,167
*The recalculation of the emissions from financing products is explained further below.
Change of reporting methodology for 2025: Due to changes in the methodology of calculation of energy
consumption, GHG emissions were recalculated as well. The values were recalculated for 2024. For more information
related to the changes of the methodology refer to Metrics on energy consumption section.
The Group monitors and reports the ﬁnanced emissions of the investment portfolio (Scope 3, category 15) also
through country-speciﬁc metrics below.
ESRS E1 – Climate Change
295
Metric ton of CO2 equivalent (tCO2eq)
Country split of GHG emissions from investments
Slovakia
Other countries
2025
1,298,796
1,133,687
2024
recalculated
with 2025
methodology
2,137,167
1,360,198
2024
2,144,747
1,360,198
Greenhouse gas emissions are reported in line with the GHG Protocol Corporate Standard (GHG Protocol). The
emission factors are used centrally across the whole ISP Group, including the VUB Group. To characterize the impacts,
regional data were used, where possible, or average European/global scenarios. Country-speciﬁc ‘residual mix’ was
used for electricity consumption (the International Energy Agency (IEA) is the source of emission factors for
calculating the location-based emissions, and the Association of Issuing Bodies (AIB) is the source of emission factors
for calculating the market-based emissions).
The emission factors of Ecoinvent 3.11 (2024: Ecoinvent 3.5 were used), and the IPCC 2021 (2024: IPCC 2013)
equivalence factors were applied.
Due to the more prudent reporting approach, as described above in chapter on energy consumption metrics, the
increasing the fossil energy component of the energy mix, and application of the new datasets of Ecoinvent and
IPCC, resulted in the GHG emissions increase.
The methodologies for collecting and calculating the data in the signiﬁcant categories of GHG emissions are detailed
below:
Scope /
Category
Emission Source
Methodology / Data Source
Scope 1
Direct emissions: natural gas (heating), fuel
(fleet & generators), refrigerant leaks (F-
gases)
Natural gas: meter readings; UNFCCC emission factors.
Fuel: GPS mileage monitoring, fuel invoices (diesel, petrol, petrol-hybrid
vehicles), regulatory infrastructure tests, emergency generator service logs;
ISPRA emission factors.
F-gases: equipment maintenance service logs; IPCC emission factors
Scope 2
Purchased energy: electricity and district
heating
Electricity: invoices, meter readings.
Market-based approach: emission factor ‘2024 residual mix’ for Slovakia,
calculated by the parent company.
Location-based approach: emission factor ‘2024 national mix’ for Slovakia,
obtained from the International Energy Agency.
Thermal energy: natural gas consumption data from landlords; in the
absence of data, average consumption values per m² were used; UNFCCC
emission factors.
Scope 3 –
Cat. 1
Purchased goods & services: office paper,
cloud data center services
Paper: UK gov. conversion factors, Ecoinvent 3.11, IPCC 2021 – Cloud:
Scope 1, 2, 3 emissions reported by providers
Scope 3 –
Cat. 2
Capital goods: IT and electronic equipment
(e.g., PCs, laptops, ATMs, phones)
Based on most relevant equipment purchased in the year
Scope 3 –
Cat. 3
Fuel/energy-related activities not in Scope 1
or 2
Includes fuel supply chain, infrastructure operations, transmission losses –
Ecoinvent 3.11, IPCC 2021 used; regional/EU/global scenarios where possible
Scope 3 –
Cat. 4
Upstream transportation & distribution:
cash transport for ATMs
Modelled as van transport; includes entire lifecycle: fuel supply, combustion,
vehicle production – Ecoinvent 3.11 used
Scope 3 –
Cat. 5
Waste generated in operations
Special waste end-of-life, transport, treatment – Ecoinvent 3.11 and IPCC
2021 applied
Scope 3 –
Cat. 6
Business travel
Based on the analysis performed, this category of scope 3 emissions was
assessed as insignificant in the context of the VUB Group.
Scope 3 –
Cat. 7
Employee commuting
Based on the analysis performed, this category of scope 3 emissions was
assessed as insignificant in the context of the VUB Group.
Scope 3 –
Cat. 8
Upstream leased assets
Based on the analysis performed, this category of scope 3 emissions was
assessed as insignificant in the context of the VUB Group.
Scope 3 –
Cat. 10
Processing of sold products
Based on the analysis performed, this category of scope 3 emissions was
assessed as insignificant in the context of the VUB Group.
Scope 3 –
Cat. 11
Use of sold products: banking services via
internet/mobile
Est. average time & electricity per operation/device – Emission factors same
as Scope 2
Scope 3 –
Cat. 12
End-of-life of sold products
Based on the analysis performed, this category of scope 3 emissions was
assessed as insignificant in the context of the VUB Group.
Scope 3 –
Cat. 13
Downstream leased assets (IAS 40
properties)
Real data used, otherwise intensity factors CO
₂
e/m² from similar buildings.
Scope 3 –
Cat. 14
Franchises
Not applicable – no franchises
Scope 3 –
Cat. 15
Financed emissions
Covered in separate chapter below
ESRS E1 – Climate Change
296
The Group’s ability to obtain the necessary information from the upstream and downstream value chain for Scope
3, Categories 1-14 emissions calculation vary depending on various factors, such as the type of contractual
agreements concluded by the Group, its purchasing power and the level of control exercised on operations outside
its consolidation area. In addition, data obtaining may be difﬁcult if counterparties along the value chain are not
covered by the current sustainability reporting. In accordance with ESRS 1 regulatory forecasts, the VUB Group has
made every reasonable effort to collect quantitative information related to its value chain. Where data provided
directly by stakeholders in the value chain on greenhouse gas emissions was not possible, estimates were made
based on variable media and other proxy sector derivatives.
No signiﬁcant changes are reported regarding any effects of events and signiﬁcant changes in circumstances
(affecting GHG emissions) that have occurred between the reference date of this document and the reference dates
of the entities included in the Group's value chain.
Financed Emissions
Reporting boundaries for the ﬁnanced emissions are only VUB Bank and their portfolio.
Under Scope 3 category 15, emissions estimation of ﬁnanced emissions is based on the PCAF standard. The
methodology for individual calculations, along with exceptions such as unavailable data, is described below within
the methodology for speciﬁc portfolios. The calculation of ﬁnanced emissions is based on the Bank’s activity data as
of the date of the preparation of the annual report containing sustainability information, i.e., as of December 31,
2025.
The Group has analysed the possibilities of disclosing the carbon footprint for assets under management under ESRS
E1.44 and 51, the GHG standard and the PCAF methodology, and has not yet disclosed this part of the carbon
footprint.
1.
Housing loans
According to the PCAF standard, this asset class includes balance sheet loans for speciﬁc consumer purposes—
speciﬁcally for the purchase and reﬁnancing of residential properties, including single-family homes and small multi-
family housing units. Within the Bank’s portfolio, Loans to Households collateralized by residential immovable
property were considered, as they account for a signiﬁcant portion of total assets and ﬁnanced emissions.
Compared to the previous year, the bank expanded the available data through digitalization, which allowed for
more accurate calculations. At the same time, it used a new calculation model for collaterals for which it did not
have information on the energy classes of the properties. In these cases, it applied proxy data on the energy efﬁciency
of the collaterals based on the primary energy factor and the total energy need.
2.
Government bonds
Based on the World Development Indicators, data about GDP and CO
₂
emissions of the country where government
bonds are assigned and the accounting price of investment in the banking book of VUB Bank were used.
The ﬁnal value of ﬁnanced emissions for this asset class is calculated as the product of an attribution factor, expressed
as the ratio of the book value of the security to the country’s GDP at purchasing power parity (PPP), and the country’s
total emissions.
This approach allows us to estimate the ﬁnanced emissions associated with securities based on their proportional
economic footprint within each country.
3.
Exposure to non-financial corporations
Exposure from Loans and Advances, Debt securities and Equity of Non-ﬁnancial corporations within the banking
book of the VUB Group were included. Emissions estimation is based on counterparty information and information
on average emissions intensity by sector, in line with the methodology developed by the Partnership for Carbon
Accounting Financials (PCAF). The share of emission data coming from company speciﬁc reporting is also disclosed.
ESRS E1 – Climate Change
297
The following table shows the Financed emission (in tCO
2
e) expressed as Scope 3 category 15:
Bank´s investments mapped to asset classes according to the PCAF
2025
2024 recalculated with 2025
methodology
2024
PCAF asset
class
Bank portfolio
Amount of GHG (in tCO2e)
Mortgages
Housing loans
142,361
141,691
149,272
National debt
Government
bonds
460,63
300,042
300,042
Business loans,
Exchange-
traded shares
and corporate
bonds
NFCs
1,829,492
3,055,632
3,055,632
% of GHG Scope 3, Category 15
calculated using primary data
16.04%
10.20%
10.20%
VUB Group has achieved a signiﬁcant reduction of ﬁnanced GHG emissions in 2025 due to reduction of exposure
to several large emitters (companies) especially from Slovakia. Increase of emissions from government bonds is mainly
driven by overall increase of the bond portfolio. Reduction of emissions from mortgages is driven mainly by increase
of precision in estimation of energy efﬁciency of collaterals.
GHG emissions intensity
The table below provides net revenue used to calculate GHG intensity reconciling it with the balance sheet value. In
calculating the intensity of greenhouse gas emissions, following formula was applied: total GHG emissions
(tCO
2
e)/net revenues.
Metric ton of CO2 equivalent per million EUR (tCO2e/€ million)
2025
2024 recalculated with
2025 methodology
2024
Intensity of greenhouse gas emissions (according to
the location-based method) per net revenue
2,000
2,763
2,768
Intensity of greenhouse gas emissions (according to
the market-based method) per net revenue
2,000
2,764
2,767
The 'net revenue‘ to calculate intensity of GHG emissions in 2025 amounts to 1,219 million EUR (2024: 1,268 million
EUR), and the deﬁnition of 'net revenue‘ to calculate intensity of GHG emissions was chosen in accordance with the
deﬁnition of the directive on annual accounts and consolidated accounts of banks and other ﬁnancial institutions.
Speciﬁcally, it considered the following items of the income statement: Interest income, Fees and commissions
income, Dividend income, Net trading income (only positive components), Other operating income, and Share of
the proﬁt or loss of investments in joint ventures and associates accounted for using the equity method (only positive
components).
298
ESRS E2 – Pollution
Materiality assessment process on impacts, risks and opportunities related to pollution
The methods for identifying material topics for the VUB Group is described in detail in the chapter ESRS 2 – General
Disclosures – Double Materiality Assessment.
The impacts, risks and opportunities in the ESRS E2 – Pollution are identiﬁed by taking into account the speciﬁcities
of the VUB Group. In particular, the mapping of such impacts, risks and opportunities was carried out on the basis
of the context in which the VUB Group deﬁnes and implements its activities, business relationships (for example,
Rules on environmental and energy policy, Guidelines for the Management of VUB Group Environmental, Social and
Governance (ESG) risks and Own emission plan) and safeguards put in place to minimize the negative impacts with
reference to its own operations and to the upstream and downstream value chain, in addition to an assessment of
risks related to the aspects of pollution to which the VUB Group could be exposed. It should be noted that for the
purposes of the double materiality analysis, publications from The Ministry of the Environment of Slovak Republic,
enviroportal.sk, European Commission (e.g. EU Soil Strategy for 2030) and others were reviewed, consultations were
carried out with experts in environmental matters and opinions of external stakeholders were considered.
For the purpose of impact materiality, the assessment of the identiﬁed impacts was conducted through interviews
with the internal structures and external stakeholders, as well as through a detailed qualitative-quantitative analysis,
carried out on the basis of the criteria required by the reference legislation (i.e. scale, scope, irremediability nature
of the impact and probability). In particular, with reference to:
Value Chain
Scope & Assessment Method
Own Operations
Assessment based on qualitative drivers, including the adoption of internal policies and initiatives aimed
at achieving pollution-reduction objectives.
Upstream Value
Chain
Analysis of ESG questionnaires submitted to suppliers and review of their feedback.
Downstream Value
Chain
Analysis of indirect impacts arising from exposures in the VUB Group’s portfolios; consideration of
exposure and share of VUB Group financing on total liabilities of counterparties in sectors with pollution-
related impacts. Also includes review of investment definitions, financing criteria and counterparty
evaluation strategies.
Changes to materiality of impacts in 2025
Changed to:
Sub/sub-sub
topic
Value chain
Description
Reasoning
Non-Material
Microplastics
downstream
Release of substances of concern,
very high concern and
microplastics
Microplastics attributable to the bank is
very limited (1,4%) evaluated as the share
of financing provided by the bank
Non-Material
Pollution of
soil
downstream
Contribution to pollution (of air,
water and soil, living beings and
food resources)
Only 4,18% can be attributed to VUB
when the share of VUB financing on total
liabilities (EVIC) of these sources is
considered.
For the purposes of determining ﬁnancial materiality, the relevance of risks and opportunities was assessed through
a dual, quantitative and qualitative approach. This was applied to the identiﬁed perimeters through the following
analyses:
Value Chain
Scope & Assessment Method
Own Operations
Evaluation of activities linked to the VUB Group’s core business, including attributes and scale; supported by
in-depth interviews with relevant departments.
Upstream Value
Chain
Assessment of potential reputational risk arising from suppliers with insufficient controls related to pollution
(e.g., pollution incidents, use of polluting substances, absence of pollution-reduction measures).
Downstream
Value Chain
Assessment of credit risk, market risk and reputational risk related to pollution. Note: analysis based on
evolving models and metrics, expected to improve with future methodological standards and more detailed
data.
Changes to materiality of risks in 2025
Changed to:
Sub/sub-sub
topic
Value chain
Description and Reasoning
Removed from
assessment
Pollution of
soil
downstream
Strategic Risk related to the loss of customers due to the failure to
offer products aligned to the needs of counterparties (e.g. financing
for the purchase and installation of low-emission technologies) is not
considered as a risk since these products are offered to customers.
Removed from
assessment
Pollution of air
downstream
Strategic Risk related to the loss of customers due to the failure to
offer products aligned to the needs of counterparties (e.g. financing
for the purchase and installation of low-emission technologies) is not
considered as a risk since these products are offered to customers.
ESRS E2 – Pollution
299
The double materiality assessment was conducted across all physical locations and business activities in which the
VUB Group operates.
The identiﬁed stakeholders were engaged speciﬁcally on the topic of Pollution, and their responses formed part of
the internal decision
‑
making process. General information on stakeholder engagement can be found in ESRS 2 –
Double materiality assessment – Engaging with the VUB Group's stakeholders.
The double materiality assessment did not identify any impacts, risks, or opportunities related to Pollution as material.
300
ESRS E3 – Water and marine resources
Materiality assessment process on impacts, risks and opportunities related to water and marine
resources
The methods for identifying material topics for the VUB Group is described in detail in the chapter ESRS 2 – General
Disclosures – Double Materiality Assessment. The impacts, risks and opportunities in the ESRS E3 – Water and marine
resources are identiﬁed by taking into account the speciﬁcities of the VUB Group. In particular, the mapping of such
impacts, risks and opportunities was carried out on the basis of the context in which the VUB Group deﬁnes and
implements its business activities and relationships in this area (for example, Rules for the environmental and energy
policy, Group Guidelines for the governance of environmental, social and governance (ESG) risks and the controls
implemented by the VUB Group. The VUB Group analysed scientiﬁc and professional studies, reports, and
publications, to evaluate the status quo and assess risks related to the aspects of water management and use to
which the VUB Group could be exposed. Especially publications from The Ministry of the Environment of Slovak
Republic, enviroportal.sk, Copernicus program of the EU, Slovak hydrometeorological institute and others were
considered, which represent current scientiﬁc and objective view on impacts on affected communities and
environment.
The double materiality assessment was conducted across all physical locations and business activities in which the
VUB Group operates.
The identiﬁed stakeholders were engaged speciﬁcally on the topic of Water and their responses formed part of the
internal decision
‑
making process. Consultations were carried out also with experts in environmental issues. General
information on stakeholder engagement can be found in ESRS 2 – Double materiality assessment – Engaging with
the VUB Group's stakeholders.
For the purposes of impact materiality, the assessment of the identiﬁed impacts was conducted through interviews
with the dedicated internal structures as well as through a qualitative-quantitative analysis, carried out on the basis
of the criteria required by reference legislation (i.e. scale, scope, irremediable nature of the impact and probability).
In particular, with reference to:
Value Chain
Scope & Assessment Method
Own Operations
qualitative information such as the definition of internal policies, corporate strategies and initiatives
aimed at the responsible use of water;
Upstream Value Chain
analysis of the ESG questionnaire collected by the VUB Group to suppliers and the related feedback
provided by them on the matter;
Downstream Value Chain
An analysis was carried out on the indirect impacts conveyed through the exposures on the VUB
Group's portfolios, in order to take into account the Group's exposure to counterparties/companies
belonging to sectors considered to have an impact from the point of view of water and marine
resources. Furthermore, the definition of investment, financing criteria and strategies for evaluating
counterparties was taken into consideration.
For the purpose of determining ﬁnancial materiality, the relevance of risks and opportunities was assessed through
a dual, quantitative and qualitative approach. This methodology was applied to the identiﬁed perimeters with the
following analyses:
Value Chain
Scope & Assessment Method
Own Operations
Consideration of the activities connected with VUB Group's core business, its attributes and magnitude
and in-depth interviews with the dedicated structures;
Upstream Value
Chain
The reputational risk to which the Group is potentially exposed was mainly assessed, in the event that it
uses suppliers that adopt less structured controls with reference to water and marine resources;
Downstream Value
Chain
The credit risk and market risk connected to the reference topic were assessed, including elements of
risk from a reputational perspective.
With reference to the assessment of the ﬁnancial materiality of the opportunities, the analyses focused on the
downstream value chain in consideration of the type of business of the VUB Group and the peculiarity of the ﬁnancial
activities. In particular, in the assessment of the commercial development opportunities, the possible introduction of
objectives and performance indicators attributable to the sustainability issues investigated into the strategy and
planning of VUB Group and their beneﬁts were assessed.
The VUB Group operates primarily in Slovakia, a landlocked country. Therefore, the relevance of E3 standard for
VUB Group is limited to freshwater topics only. Any impacts and risks are prevented by all Group´s premises being
connected to the urban water supply and sewage system and operating in alignment with the respective legislation.
Due to the speciﬁcity of the VUB Group's core business and following in-depth interviews with the dedicated
structures, no material impacts have been identiﬁed. With reference to the upstream and downstream value chains,
the concentration of exposures and suppliers that may present critical issues with respect to the topics in question is
not signiﬁcant.
ESRS E3 – Water and marine resources
301
Through loans from the TERRA product line, such as ENVIRO loan and GREEN S-LOAN+, VUB supports projects
focused on sustainable water management, aquatic biodiversity, and wastewater treatment with preferential interest
rates. But these initiatives are currently marginally relevant with respect to the overall business and therefore not
signiﬁcant for the purposes of speciﬁc disclosure in this document.
No changes to materiality have been identiﬁed for impacts, risks and opportunities in 2025, compared to 2024.
302
ESRS E4 – Biodiversity and ecosystems
Materiality assessment process on impacts, risks and opportunities related to biodiversity and
ecosystems
The methods for identifying material topics for the VUB Group is described in detail in the chapter ESRS 2 – General
Disclosures – Double Materiality Assessment. The impacts, risks and opportunities in the ESRS E4 – Biodiversity and
ecosystems are identiﬁed by taking into account the speciﬁcities of the VUB Group. In particular, the mapping of
such impacts, risks and opportunities was carried out on the basis of the context in which the VUB Group deﬁnes
and implements its business activities and relationships, the measures put in place by the VUB Group to promote
and protect biodiversity and ecosystems, including through dedicated initiatives and projects as well as an assessment
of the risks related to the biodiversity aspects to which the Group could be exposed.
The double materiality assessment was conducted across all physical locations and business activities in which the
VUB Group operates.
The identiﬁed stakeholders were engaged speciﬁcally on the topic of Biodiversity and ecosystems, and their responses
formed part of the internal decision
‑
making process. General information on stakeholder engagement can be found
in ESRS 2 – Double materiality assessment – Engaging with the VUB Group's stakeholders.
The double materiality assessment did not identify any impacts, risks, or opportunities as material.
Speciﬁc analyses were conducted to assess the VUB Group’s dependencies and impacts in terms of biodiversity,
ecosystems and related services. In particular, for the purposes of impact materiality research of available scientiﬁc
literature, mainly from the sources of OECD – Environment performance review, European Commission, Ministry of
Environment of Slovak Republic etc. was performed to map economic activities with their negative impacts
speciﬁcally on the territory of Slovakia, the assessment of the identiﬁed impacts was conducted through interviews
with dedicated internal structures and with expert stakeholders, including experts in environmental issues. This was
complemented by a detailed qualitative-quantitative analysis, carried out on the basis of the criteria required by the
reference legislation (i.e. scale, scope, irremediable nature and probability). Speciﬁcally:
Value Chain
Scope & Assessment Method
Own Operations
qualitative drivers such as VUB Group internal policies and corporate strategies relating to this area (for
example, Rules on biodiversity and nature, Rules for the environmental and energy policy; strategy for
combating climate change, excessive land exploitation, etc.);
Upstream Value
Chain
analysis of the ESG Questionnaire collected by the VUB from suppliers and the related feedback provided
by them on the matter and in the context of Green banking procurement rules;
Downstream Value
Chain
the indirect impacts conveyed through the exposures on the VUB Group's portfolios, in order to take
into account the VUB Group's exposure to counterparties in sectors deemed to affect biodiversity, on
the status of species, as well as on the extension and conditions of ecosystems. Furthermore, the
definition of investment, financing criteria and strategies for the evaluation of counterparties was taken
into consideration.
During the double materiality assessment (DMA), potential systemic risks related to biodiversity and ecosystems were
also considered based on expert analyses. The assessment also included information obtained through a
questionnaire from external stakeholders to engage communities and their perspectives. After performing the DMA,
across all deﬁned time horizons, no material impacts, risks or opportunities related to biodiversity and ecosystems
were identiﬁed.
VUB Group does not own or have operational control over any relevant sites of shared biological resources,
ecosystems or production or extraction of raw materials located in or near biodiversity-sensitive areas. For this reason,
it does not carry out any activities that could have negative or potential negative impacts on biodiversity, ecosystems
or affected communities.
As no such impact was identiﬁed, consultation with affected communities was not required. However, the DMA
was expanded to include consultation with the scientiﬁc community and experts in the ﬁeld of biodiversity and
ecosystems.
Since all the VUB Group's premises are in urban areas, already built on areas, and the VUB Group's operations are
of administrative character, it has very limited direct impact of the existing biodiversity. Similarly, the dependency of
VUB's operational perimeter on the ecosystem services does not exceed the general overall dependency on
the natural resources and the environment. Therefore, no material impacts were identiﬁed.
However, in 2025 the VUB Group is enhancing its operational rules and procedures for building operation,
refurbishment, reconstruction or new construction, applying the same criteria as in ﬁnancing.
For the purposes of determining ﬁnancial materiality, the relevance of risks and opportunities was assessed using a
dual approach, quantitative and qualitative, applied to the identiﬁed perimeters.
ESRS E4 – Biodiversity and ecosystems
303
With reference to risks, the following analyses were conducted:
Value Chain
Scope & Assessment Method
Own Operations
Considering the specific nature of the VUB Group’s core business, the fact that its offices are not
located in protected areas or regions with high biodiversity, and based on in-depth analyses conducted
by the relevant expert departments;
Upstream Value Chain
The reputational risk to which the Group is potentially exposed was assessed, in the event that it uses
suppliers that adopt less structured safeguards with respect to biodiversity and ecosystems (for
example, adoption of practices to mitigate the risk of environmental pollution with impact on
biodiversity or definition of an environmental policy);
Downstream Value
Chain
Credit risk and market risk potentially arising from threats to biodiversity and the balance of the
reference ecosystems were mainly considered. This could also determine elements of risk from a
reputational perspective.
VUB Group does not have sites located in or near biodiversity
‑
sensitive areas.
The VUB Group does not carry out any activities related to sites in or near biodiversity
‑
sensitive areas that would
negatively affect natural habitats or species for which protected areas have been designated.
As a result, the VUB Group concluded that it was not necessary to implement biodiversity mitigation measures.
Through loans from the TERRA product line, such as ENVIRO loan and GREEN S-LOAN+, VUB supports projects
focused on sustainable management of natural resources, soil and aquatic biodiversity with preferential interest
rates.
No changes to materiality have been identiﬁed for impacts, risks and opportunities in 2025, compared to 2024.
304
ESRS E5 – Resource use and circular economy
Materiality assessment process on impacts, risks and opportunities related to resource use and
circular economy
The methods for identifying material topics for the VUB Group is described in detail in the chapter ESRS 2 – General
Disclosures – Double Materiality Assessment. The impacts, risks, and opportunities within the scope of ESRS E5 –
Use of resources and circular economy are identiﬁed considering the speciﬁcities of the VUB Group. The mapping
of such impacts, risks, and opportunities was carried out on the basis of the context in which the Group deﬁnes and
implements its business activities and relationships (for example, Environmental Policy of the VUB Group, Group
Guidelines for Environmental, Social and Governance (ESG) Risks, Green Procurement Rules, VUB Green Manifesto
and Code of Ethics), the measures put in place by the VUB Group to contribute to the implementation of recycling
systems and the use of recycled/recyclable materials, the renewal of partnerships related to this theme, in addition
to an assessment of the risks related to circular economy aspects to which the VUB Group may be exposed.
To support the analysis, consultations were conducted with retail consumers and the public through a dedicated
representative survey, measuring the importance of these topics (sorting and recycling of own waste, reducing the
use of plastics, packaging goods in recycled or recyclable packaging, supporting sustainable local production,
reduction of paper correspondence and documentation, offering the option of purchasing goods without packaging
and receipts and invoices in electronic form).
In addition, various scientiﬁc and professional studies, reports and publications, especially Report on the State of the
Environment of Slovak Republic in 2024 and enviroportal.sk have been analysed.
For the purposes of impact materiality, the assessment of the identiﬁed impacts was conducted through interviews
with the competent internal structures of the VUB Group and with expert stakeholders, including experts in
environmental issues, as well as through a detailed qualitative-quantitative analysis, carried out on the basis of the
criteria required by the reference legislation (i.e. scale, scope, irremediable nature of the impact and probability).
Following the analysis carried out, the following impact materiality outcomes emerged:
Value Chain
Scope & Assessment Method
Identified Impacts
Own Operations
The assessment of impacts was carried out based on qualitative drivers such as
the definition by the VUB Group of internal policies and corporate strategies
relating to this area (for example, recycling systems and use of recyclable /
biodegradable materials);
-
Upstream Value Chain
Assessment of impacts was carried out through the analysis of a dedicated
questionnaire submitted by the VUB Group to suppliers and the feedback
provided by them on the matter;
-
Downstream Value Chain
An analysis was carried out on the indirect impacts conveyed through the
exposures on the Group's portfolios, in order to take into account, the VUB
Group's exposure to counterparties/companies operating in sectors considered
to have an impact from the point of view of the circular economy and the use
of resources. Furthermore, the definition of investment/financing
criteria/strategies for the evaluation of counterparties was taken into
consideration.
Material
Contribution to the
recycling and reuse of
materials through
financing and
investments
No negative material impacts have been identiﬁed as attributable to exposures to counterparties operating in sectors
identiﬁed as relevant, such as plastic manufacturing, electronics industry, the mining and extractive industries,
chemical industry, agriculture, and construction and demolition.
For the purposes of determining ﬁnancial materiality, the relevance of risks and opportunities was assessed through
a dual approach, quantitative and qualitative, applied to the identiﬁed perimeters.
With reference to risks, the following analyses were conducted:
Value Chain
Scope & Assessment Method
Own Operations
In consideration of the specificity of the VUB Group's core business and following in-depth analyses with
the dedicated structures, no risks were identified relating to the topic of circular economy and use of
resources;
Upstream Value
Chain
Reputational risk to which the VUB Group is potentially exposed was mainly assessed, in the event that it
uses suppliers who adopt less structured controls with respect to the topic in question (for example, lack of
definition of an environmental policy);
Downstream Value
Chain
Credit risk and the market risk potentially deriving from threats to the circular economy and the use of
resources were mainly considered. This could also determine elements of risk from a reputational
perspective.
ESRS E5 – Resource use and circular economy
305
Changes to materiality of risks in 2025
Changed to:
Sub/sub-sub topic
Value chain
Datapoint
Reasoning
Non-Material
Waste
Ustream and
downstream
Reputational risk linked to the
lack of definition of recycling
/ circular economy systems,
also with reference to
counterparts subject to
financing / investment.
Low concentration of clients in
subsectors with potential
impact.
From the analyses conducted, for the purposes of ﬁnancial materiality, no signiﬁcant reputational risks relating to
waste management in the production process were identiﬁed, for both downstream and upstream value chain.
With reference to the ﬁnancial materiality of the opportunities, analyses were conducted mainly relating to the
downstream value chain, taking into account the type of business of the VUB Group and the peculiarity of the
ﬁnancial activities. Analyses and evaluations of commercial opportunities were carried out in terms of ﬁnancing of
counterparties with the aim of improving their circular economy proﬁles and improving the efﬁciency of production
processes. Additionally, the possible presence of objectives and performance indicators related to the VUB Group's
Strategy was considered.
In light of the ﬁnancial materiality analysis carried out, no signiﬁcant opportunities emerged.
Policies, actions and objectives related to resource use and circular economy
Policies related to resource use and circular economy
The circular economy policies of the VUB Group are in line with Intesa Sanpaolo Group's strategy, focusing on
resource efﬁciency, waste reduction, and value creation throughout the product life cycle. The goal is to facilitate
the transition of businesses and territories to an inclusive circular economy, enhancing climate change mitigation,
biodiversity restoration, and pollution reduction. This approach optimizes raw material use, regenerates natural
resources, and fosters technological innovation, contributing to a sustainable, equitable, and resilient economic
system. These policies cover all the VUB Group's activities, emphasizing internal resource management and ﬁnancial
support for circular business models, aligning with global sustainability trends and reducing resource price volatility
risks.
The Code of Ethics of the VUB Group integrates the principles of circular economy through environmental protection,
support for the development of the country thanks to the ecological transition and the adoption of circular economy
models, as well as through responsible management of indirect environmental impacts.
Furthermore, the VUB Group adopted the following internal policies related to the circular economy:
In direct relation to the European Taxonomy, the Rules for the application of the European Taxonomy from a Green
Asset Ratio (GAR) perspective, approved at Intesa Sanpaolo Group level and prepared in compliance with regulatory
legislation, with the aim of outlining the rules necessary for the application of the EU Taxonomy and measurement
of aligned economic activities with the fourth of the six environmental objectives set out in European legislation,
namely ‘Transition to a circular economy’;
The Rules for the classiﬁcation of sustainable credit products and lending transactions, which identiﬁes a speciﬁc
category in the ﬁeld of environmental sustainability called ‘Ecological efﬁciency and circular economy’ assigned on
the basis of the consistency of the credit transaction to a speciﬁc framework of ﬁve Circular Economy criteria, deﬁned
in collaboration with the Ellen MacArthur Foundation (EMF);
The ESG Scoring Rules outline how Intesa Sanpaolo Group and VUB Group evaluate the environmental, social, and
governance (ESG) performance of its corporate clients, including SMEs that are often excluded from market ESG
ratings. The ESG Score is a comprehensive rating based on multiple factors, including a speciﬁc focus on the circular
economy. The ESG Score is used in key banking processes, such as:
–
Credit Risk Appetite Framework – deﬁnes the Bank’s willingness to take on risk for different customer categories;
–
Credit Strategies Framework – guides credit portfolio growth to balance risk and return over time.
–
Organizational Waste Management Directive, governing the waste hierarchy (prevention, preparing for re-use,
recycling, other recovery, disposal), waste avoidance, minimization, separate collection and ways of disposal;
–
The Green Banking Procurement Rules, addressing transitioning away from extraction of virgin resources,
including increases in use of secondary (recycled) resources, sustainable sourcing and use of renewable resources
is the internal rules for green procurement aiming to pursue sustainability objectives, and identifying the best
design solution, product or service, taking market availability into account.
ESRS E5 – Resource use and circular economy
306
Key principles of green banking procurement within the VUB Group:
–
mandatory environmental criteria for all key product categories (paper, stationery, toner, electricity, buildings,
equipment, events)
–
products via lifecycle
‑
based environmental assessment, prioritising low energy use, low emissions, and reduced
waste
–
certiﬁed sustainable materials, such as recycled paper, FSC/PEFC wood, remanufactured toner, and eco
‑
labelled
products
–
renewable electricity, progressively increasing the share toward 100% by 2030
–
energy
‑
efﬁcient solutions in building renovations and ofﬁce equipment purchases
–
supplier compliance through required documentation and certiﬁcations
–
monitoring and reporting of indicators annually
The Policies are available to relevant internal and external stakeholders through corporate communication channels,
mainly via the Bank’s intranet and bilateral communication with the clients and suppliers.
The VUB Group, as a part of Intesa Sanpaolo Group, integrates the principles of circular economy into its policies
within the credit process, based on speciﬁc circular economy criteria established by parent company, VUB assesses
and classiﬁes individual credit transactions as sustainable based on speciﬁc procedures that apply to transactions as
sustainable based on speciﬁc procedures that apply to transactions aimed at ﬁnancing sustainable initiatives of
corporate clients.
It should be noted that the internal framework does not appear to be completely superimposable on the criteria of
the European Taxonomy on the Circular Economy and therefore the ﬁnancing granted with this framework is not
considered ’aligned’ with the criteria of the taxonomy for the purposes of calculating the Green Asset Ratio.
Furthermore, in 2020 the VUB Bank has published the Green Manifest, which represents a pillar and inspiration for
VUB Group's sustainable policies and strategies. In the Green Manifest, the VUB Group declared objective to support
clients by offering banking products and services that promote sustainability, including ﬁnancing for individuals and
businesses focused on ecological innovations and circular economy initiatives.
In addition to guaranteeing full and total compliance with legislative provisions for the protection of the
environment, the VUB Group aims to identify innovative and effective solutions in this ﬁeld, to apply the best
environmental standards and to promote and develop the concept of environmental responsibility, with a
commitment to translating the international principles to which the whole Intesa Sanpaolo Bank Group has adhered,
particularly the UNEP Financial Institutions Declaration and the Global Compact of the United Nations, into concrete
actions.
The VUB Group is also open to dialogue and discussion with those stakeholders who represent the ’voice’ of
environmental concerns and focus on energy consumption. The ESG Manager (Deputy CEO of VUB Bank), is
responsible for overseeing and implementing sustainability policies, including policies referring to resources use and
circular economy. The VUB Group guarantees transparency towards stakeholders, making the main policies available
through the company's communication channels.
Targets related to resource use and circular economy
VUB Group has not set targets yet, as these are deﬁned, approved and monitored at the level of the parent company,
Intesa Sanpaolo, within the framework of the Group’s consolidated strategy and governance structure.
As a subsidiary, VUB Group aligns with these Group-level objectives, ensures their implementation in its operations,
and provides relevant performance data for the purpose of consolidated reporting. The applicable targets,
methodologies, and disclosures on progress are therefore included in the consolidated reporting published at the
Intesa Sanpaolo Group level, of which VUB group forms part.
Actions related to resource use and circular economy
The VUB Group's transition to a circular economy is further supported through cooperation with the Intesa Sanpaolo
Innovation Centre (ISPIC). VUB and ISPIC collaborate on identiﬁcation of Slovak innovative companies in the area of
circular economy and sustainability in order to provide them ﬁnancial and non-ﬁnancial support and networking.
The VUB Group supports circular economy practices by providing incentivized ﬁnancing through ’VUB ENVIRO loan’
aimed at ﬁnancing of projects that support the circular economy. Eligible purposes were deﬁned in collaboration
with the Ellen MacArthur Foundation (in connection with the circular economy framework). The loan is ﬁnanced by
above mentioned credit plafond (CE and Green Plafond) created by Intesa Sanpaolo.
As part of the Intesa Sanpaolo Group's 2022-2025 Business Plan, an additional EUR 8 billion credit plafond has been
allocated to support businesses transitioning to a circular economy. This initiative renews and expands upon the
previous commitment from the 2018-2021 Business Plan, highlighting the long-lasting and constant commitment
ESRS E5 – Resource use and circular economy
307
to these issues.
Speciﬁcally, the eligibility criteria of the internal circular framework include:
–
Solutions that extend the useful life of the product or the use cycles of goods and materials (circular design
activities; application of modular design; implementation of reverse logistics programs; repair and regeneration
or reconditioning of products; use of product-as-service, pay-per-use and/or sharing economy models);
–
Procurement of secondary or sustainably sourced renewable resources and/or recycled material (including the
use of renewable energy for self-consumption);
–
Solutions that signiﬁcantly increase the efﬁciency of resource consumption, within the company or along its
value chain (application of industrial symbiosis principles and creation of an integrated value chain that
transforms waste into production inputs; implementation of cycle closure models and/or application of eco-
design and systemic design principles; implementation of processes based on natural principles for the capture
and storage of CO2 and/or the capture and use of CO2, to support the achievement of decarbonization and
net-zero impact objectives);
–
Products that are totally reusable, recyclable or compostable, inserted in an efﬁcient context of collection,
separation and recovery after use;
–
Innovative technologies and activities that enable circular economy models (e.g. Internet of Things solutions for
the implementation of traceability systems, reverse logistics and/or predictive maintenance; Big Data, Artiﬁcial
Intelligence and Cloud Computing in order to dematerialize services and develop markets for raw and/or
secondary materials;
–
Regenerative agriculture practices and/or hydroponic/aeroponic/precision agriculture technologies, to improve
soil health, increase biodiversity, produce food close to the place of consumption and grow in unfavourable
areas).
Clients also have access to GREEN S-LOAN
+
, which allows them to obtain an even more favourable interest rate for
eligible circular purposes if they commit to completing the project within the agreed deadline.
The VUB Group is dedicated to promoting and supporting the circular economy through speciﬁc awareness-raising
initiatives (ATLAS Talks), partnerships (Circular Slovakia), and business cooperations (Sustainable E-shop with VISA
and Heureka.sk).
A project Sustainable E-shop (Udržateľný e-shop) was launched in 2023 in collaboration with Heureka and Visa to
help e-shops operate sustainably and reduce their overall environmental footprint. E-shops are encouraged to adopt
circular practices such as zero waste packaging, climate-neutral delivery, supporting local suppliers, and thorough
recycling of all waste.
E-Shops can earn a sustainability label on Heureka.sk by passing questionnaire inspection designed in line with ESG
principles by the Association for Social Responsibility and reviewed by the Institute of Circular Economy in Slovakia.
The project Sustainable E-shop (Udržateľný e-shop) also helps consumers make more informed and conscious
purchasing decisions by highlighting sustainable e-shops. The action culminated in the ’Shop of the Year’
competition, where the ’Sustainable E-shop Award’ was introduced. For more details, visit
www.udrzatelnyeshop.sk
.
The VUB Group promotes the circular economy by organizing the VUB Atlas Fórum, focusing on ﬁnancing green
projects, ESG strategies, and sustainable development. The forum discusses current trends, legislative challenges,
and the role of banks and investors in supporting ecological initiatives. Additionally, the Bank became an
implementation partner of Slovakia's ﬁrst Circular Summit, highlighting the potential of the circular economy for
micro, small, and medium-sized enterprises, emphasizing the ecological and economic beneﬁts of efﬁcient resource
management.
To promote and disseminate the circular economy paradigm, online sessions were organized throughout the year
dedicated to the relationship managers of the Bank, with the aim of supporting customers in the transition process
towards a sustainable and circular economy, also through the sharing of best practices at VUB Group level.
The efforts of VUB Group in its own operation not only promote circular economy but also foster a culture of
sustainability among its stakeholders. Forums and summits organized by the VUB Group facilitate knowledge sharing
and highlight economic beneﬁts of the circular economy, sharing sustainable practices in both the upstream and
downstream value chain.
308
Social Information
ESRS S1 – Own Workforce
Interests and views of stakeholders
VUB Group incorporates the interests, views, and rights of its own workforce into its strategy and business model
through systematic materiality assessment, social dialogue, internal policies, and feedback mechanisms.
Materiality process on impacts, risks and opportunities and their interaction with strategy and
business model
The methods for identifying material topics for the VUB Group is described in detail in the chapter ESRS 2 – General
Disclosures – Double Materiality Assessment. The impacts, risks, and opportunities within the scope of ESRS S1 –
Own workforce are identiﬁed taking into account the speciﬁcities of the VUB Group. In particular, the mapping of
such impacts, risks, and opportunities was carried out on the basis of the context in which the Group deﬁnes and
implements its business activities and relationships (for example, Intesa Sanpaolo Business Plan 2022-2025, VUB
Group Strategy, policies developed in various areas, etc.) and the measures put in place to minimize the negative
impacts related to the topic with reference to its own operations, in addition to an assessment of the risks to which
the VUB Group may be exposed with reference to its own workforce.
Within the scope of the double materiality assessment, the VUB Group has considered all its own workers who fall
under the deﬁnition of 'own workforce', including both its direct employees (those with permanent or ﬁxed-term
contracts) and workers engaged through stafﬁng agencies or self-employed individuals performing tasks that would
otherwise be carried out by employees of the VUB Group, on which it produces or may produce signiﬁcant impacts,
risks and opportunities.
For the purposes of material impact, the assessment of identiﬁed impacts was conducted through analysis of
employee engagement surveys, interviews with internal structures and external stakeholders (e.g., trade unions
feedback through dedicated questionnaire), as well as through a detailed qualitative-quantitative analysis carried out
on the basis of the criteria required by the reference legislation (i.e. scale, scope, irremediable nature of the impact
and probability) on the perimeter of its own operations.
Value Chain
Scope & Assessment Method
Identified Impacts
Own Operations
The impact assessment was carried
out based on definitions
implemented by the VUB Group
regarding safeguards to working
conditions, equal treatment and
opportunities for all, and workforce
privacy (e.g., recruitment plans,
talent development programs,
measures to ensure safe and healthy
workplaces, safeguards to promote
diversity and inclusion).
Material
Contribution to the protection of work by guaranteeing
fundamental rights of employees
Contribution to the protection of work, through the prevention of
discrimination and gender inequality phenomena (including
harassment) and to the detriment of people with disabilities and
promotion of diversity in all its forms through the adoption of
policies/initiatives
Support for training and skills development and valorisation of the
potential and uniqueness of employees, also through the definition
of talent management and development programs
Contribution to the protection of workers through the definition of
policies, union agreements and internal systems aimed at
protecting the personal data of personnel (including cybersecurity
measures), in order to prevent the intentional or unintentional use
of confidential information for business purposes that could harm
employees.
Protection and increase of physical (health and safety) and
psychological well-being of employees (work-life balance,
corporate welfare)
ESRS S1 – Own Workforce
309
Changes to materiality of impacts in 2025
Changed to:
Sub/sub-sub
topic
Value chain
Description
Reasoning
Material
impact
merged
Health and
safety
Own operations
Personal safety equipment such as
anti-panic devices and/or protective
clothing, ergonomic workstations, air
quality checks more frequently than
the de minimis required by legislation,
provision of training courses with
periodic compulsory first aid
simulation
Compared to 2024, the
described positive impact
was merged as part of a
broader consolidation of
similar topics.
For the purposes of determining ﬁnancial materiality, the relevance of risks and opportunities was assessed using a
dual approach, quantitative and qualitative, applied to the perimeter of own operations. In the process of mapping
and assessing risks and opportunities that have or could have ﬁnancial effects, the VUB Group took into account the
connections of its impacts and dependencies with the risks and opportunities that may arise from said impacts and
dependencies. For example, positive impacts resulting from the establishment of policies aimed at ensuring adequate
working conditions, such as safe employment and adequate wages, and equal treatment, such as gender equality
and inclusion, ﬂexible work, work-life balance, could contribute to the emergence of opportunities to improve brand
reputation, increase stakeholder trust and attract new talent.
Value Chain
Scope & Assessment Method
Identified Risks
Own Operations
The operational and non-compliance risks that could be
generated in the face of inadequate preparation and
implementation of policies aimed at protecting workers'
rights were assessed. This could also lead to elements of risk
from a reputational point of view.
Based on discussions with internal structures
and involved stakeholders, as well as the
analyses conducted, these risks did not
appear to be relevant concerning the
standard in question.
Compared to 2024, no changes in risks for the topic of own workforce were identiﬁed in 2025.
Considering the type of operations and business activities performed by the VUB Group, and countries/geographies
in which the VUB Group operates, no signiﬁcant risks of incidents related to forced, compulsory or child labour have
been identiﬁed.
Value Chain
Scope & Assessment Method
Identified Opportunities
Own Operations
With regard to opportunities, the
initiatives, safeguards, policies and
processes in place and/or planned by
the Group that could determine the
opportunity to attract talent from
outside and strengthen the Group's
reputation, as well as the trust of
stakeholders with reference to the
protection of the rights of its own
workforce, were analysed.
Material
Increased trust among Group Stakeholders (e.g. employees),
through the definition of appropriate policies aimed at ensuring
gender equality and equal pay, the inclusion of all Group people
and the prevention of violence and harassment in the workplace
Attracting talent through the definition of adequate policies
regarding employee working conditions
These opportunities are relevant in the short- and medium-term time horizons.
Changes to materiality of opportunities in 2025
Changed to:
Sub/sub-sub
topic
Value chain
Description
Reasoning
Material – new
opportunity
Collective
bargaining,
including
rate of
workers
covered by
collective
agreements
Own operations
Increased trust among Group
Stakeholders (e.g. employees),
through the definition of
appropriate policies aimed at
ensuring gender equality and
equal pay, the inclusion of all
Group people and the prevention
of violence and harassment in the
workplace
Expanding an existing datapoint to
the topic of Collective bargaining,
including rate of workers covered
by collective agreements
ESRS S1 – Own Workforce
310
Characteristics and composition of the VUB Group’s employees
With reference to its workforce, the main characteristics of the VUB Group's employees are set out below.
The workforce shown is consistent with the provisions of the consolidated ﬁnancial statements, limited to the
corporate perimeter deﬁned for the CSRD and with the exclusion of non-employee collaboration contracts (project
and administration contracts). The data represents the total number of employees (in head count) and refers to the
speciﬁc situation at the end of the reporting period.
As of December 31, 2025, the VUB Group's total workforce consisted of 3,450
14
employees: the following table
below shows the total number of employees, broken down by gender.
Gender
2025
2024
Female
2,367
2,506
Male
1,083
1,131
Other
0
0
Not reported
0
0
Total
3,450
3,637
Number of employees represents the total headcount including active employees and long-term absences.
The following table shows the total number of VUB Group employees as of December 31, 2025, broken down by
gender (women and men) and by type of employment contract. As can be seen from the table, the vast majority of
the VUB Group's employees have a permanent employment contract.
2025
Female
Male
Other
Not disclosed
Total
Number of employees
2,367
1,083
0
0
3,450
Number of permanent employees
2,101
992
0
0
3,093
Number of temporary employees
266
91
0
0
357
Number of non-guaranteed hours employees
0
0
0
0
0
2024
Number of employees
2,506
1,131
0
0
3,637
Number of permanent employees
2,179
995
0
0
3,174
Number of temporary employees
327
136
0
0
463
Number of non-guaranteed hours employees
0
0
0
0
0
During the 2025 ﬁnancial year, the total number of employees who left the Group is 460 (2024: 429) and the
turnover rate for the same period stands at 14,25%, (2024: 14,09%). This turnover rate is calculated by relating the
total number of departures to the average active headcount during the year, where departures refer to all
employment relationships terminated during the year (resignations, terminations, retirements, departures, deaths,
etc.).
It is reported that the only country where the VUB Group has a signiﬁcant employment level (i.e. with 50 or more
employees representing at least 10% of the total number of employees) is Slovak Republic with a total of 3,419
employees, which accounts for 99% of the total workforce. The VUB Group also has a small number of employees
in the Czech Republic.
Country
Headcount 2025
Headcount 2024
Slovakia
3,419
3,606
Czech Republic
31
31
Total
3,450
3,637
14
The total active headcount of VUB Group is 3,215 employees, the difference represents employees on a long-term absence, such as maternity
leave.
ESRS S1 – Own Workforce
311
VUB Group’s commitment to human rights
VUB Group is deeply committed to promoting and safeguarding human rights, ensuring that dignity, respect, and
inclusion are embedded in our corporate culture. We actively work to protect the rights of our employees, uphold
ethical business practices, and create a safe, fair, and inclusive work environment for all. Our approach aligns with
internationally recognized human rights frameworks, including the UN Universal Declaration of Human Rights, the
UN Guiding Principles on Business and Human Rights, the ILO Declaration on Fundamental Principles and Rights at
Work, and the OECD Due Diligence Guidance for Responsible Business Conduct.
The VUB Code of Ethics serves as the foundation for our human rights commitments, articulating the VUB Group’s
core values and guiding the behaviour of employees, management, and stakeholders. It is a living document,
continuously updated to reﬂect evolving societal and business expectations. Alongside the Human Rights Principles,
the Diversity, Equity & Inclusion (DE&I) Principles, and the Intesa Sanpaolo (ISP) Modern Slavery Statement, the Code
of Ethics provides a comprehensive framework for ensuring that human rights are upheld in all aspects of our
operations.
With the Human Rights Principles, VUB is committed not only to complying with Slovak and European legislation
but also to proactively identifying, mitigating, and preventing human rights violations related to its activities. As a
signatory to the UN Global Compact, VUB promotes sustainable business practices, ethical labour conditions, and
responsible business conduct across its value chain.
The core principles of the VUB Group, enshrined in the Code of Ethics, and to which all the VUB Group's policies
are aligned, are as follows:
Principle
Description
Listening and dialogue
The VUB Group values listening and dialogue to build trust, promoting internal
communication and inclusion, and developing tools for sharing and discussion between
the various corporate functions. In addition, it encourages managers to understand
people's needs and to value suggestions for improvement and growth together
Transparency
The VUB Group aims to continuously develop the culture of transparency as the basis
for building relationships between people, placing transparency at the base of its
actions to enable anyone to make informed, aware and autonomous choices
Equity and inclusion
for the VUB Group, respect for individuality and human dignity is fundamental to
creating an inclusive work environment with a commitment to avoiding any
discrimination in behaviour and respecting every difference (gender, gender identity
and/or expression, affective-sexual orientation, marital status and family situation, age,
ethnicity, religious belief, political and trade union affiliation, socio-economic status,
nationality, language, cultural background, physical and mental conditions or any other
characteristic of the person also related to the expression of one's thought)
Respect for people
The VUB Group is committed to preventing conduct that is detrimental to human
dignity, guaranteeing assistance and confidentiality, and to promoting an inclusive work
environment that respects privacy, is sustainable and attentive to the balance between
personal and professional life
Protection of health and safety
The VUB Group is committed to identifying and controlling risks to health and safety in
the workplace, adopting preventive and protective measures, and managing residual
risks with emergency and intervention plans to improve people's well-being
Enhancement and motivation
The VUB Group recognises the strategic importance of the relational, intellectual,
organisational and technical skills of each individual, considering them fundamental for
enhancing and motivating people in relationships
Cohesion
The VUB Group is committed to strengthening the spirit of belonging by spreading its
values, strategies and objectives, supporting leaders, providing forms of participation in
successes and promoting solidarity initiatives
Management and personnel
remuneration policies
in defining the remuneration policy, the VUB Group bases itself on the principles of
fairness, merit and sustainability of results
To ensure maximum dissemination, the Code of Ethics is published both on the VUB Bank's website and on the
company Intranet. In addition, relevant stakeholders (i.e. suppliers) are explicitly informed about the document and
asked to follow the main principles.
To materialize the commitments and values set out in the Code of Ethics, and to ensure respect for the rights of
each employee, the VUB Group, as part of the ISP Group, applies the Human Rights Principles, approved by the VUB
Management Board, which take up and develop the values already present in the VUB Group's Code of Ethics. With
the Human Rights Principles, the VUB Group, in addition to complying with the relevant legislation to which it is
subject in all the countries in which it operates, undertakes to identify, mitigate and, where possible, prevent,
potential human rights violations related to its activities, as recommended by the UN Guiding Principles on Business
and Human Rights. The document is made available to all relevant stakeholder groups, including employees, on the
VUB Group’s website (www.vub.sk). Employees are also required to complete mandatory training that includes
familiarisation with the content of the Group’s Code of Ethics and Internal Code of Conduct.
In addition, the VUB Group, as part of the ISP Group, has also adopted Diversity, Equity & Inclusion Principles to
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312
solidify its commitment to implementing and promoting a policy that supports the inclusion of all forms of diversity,
both within the Group and in the wider community.
To demonstrate the VUB Group's strong commitment to the respect for human rights, the Bank – as part of the ISP
Group – follows the ISP Group Modern Slavery Statement, which outlines the actions taken to prevent modern
slavery in its operations and supply chain. For further details, please refer to the Intesa Sanpaolo Modern Slavery
Statement document, available on the Intesa Sanpaolo Group's institutional website.
Human rights metrics in the workforce
The following table presents a set of indicators that allows for monitoring the presence of reports and incidents
related to social issues and human rights concerning its employees:
–
The indicator ‘Number of incidents of discrimination‘ shows the number of reports received by the VUB Group
in the form of labour lawsuits, criminal complaints or cases of non-compliance identiﬁed internally, all of which
have as their main or secondary object issues of discrimination, including harassment;
–
The indicator ‘Number of complaints submitted through the appropriate channels set up for the company's own
workers‘ measures the number of reports submitted by employees through the company channels set up, such
as the Code of Ethics and Whistleblowing, to express concerns on issues of various kinds always related to
human rights incidents;
–
The indicator ‘Number of complaints at the National Contact Points (NCPs) for OECD Multinational Enterprises‘
accounts for complaints sent to NCPs for OECD multinational enterprises, concerning the same issues as aspects
such as working conditions, equal treatment and fundamental workers' rights as the previous indicator;
–
The indicator ‘Total amount of ﬁnes, penalties and compensation resulting from the incidents and reports
referred to above‘ indicates the total amount of ﬁnes, penalties and compensation imposed due to violations of
a social or human rights nature;
–
The indicator ‘Number of Serious Human Rights Incidents‘ indicator refers to the number of serious human rights
incidents related to the workforce, including legal proceedings, ofﬁcial reporting via grievance channels, serious
allegations reported in the media or in formal public reports (provided they are not disputed by the company),
or other known signiﬁcant impacts. Severity is assessed on the basis of the extent, scope and irreparability of
the accident;
–
The indicator ‘Number of serious incidents constituting cases of non-compliance with the UN Guiding Principles
on Business and Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work or the OECD
Guidelines for Multinational Enterprises‘ highlights the cases in which such incidents constitute a violation of the
UN Guiding Principles on Business and Human Rights, the ILO Declaration on Fundamental Principles and Rights
at Work or the OECD Guidelines for Multinational Enterprise;
–
The indicator ‘Total amount of ﬁnes, penalties and reparations resulting from the human rights incidents referred
to above‘ shows the total amount of ﬁnes, penalties and reparations imposed with reference to the serious
human rights incidents mentioned above.
2025
2024
Number of incidents of discrimination
0
0
Number of complaints filed through channels for own workers to raise concerns
1
1
Number of complaints filed to National Contact Points for OECD Multinational
Enterprises
0
0
Amount of material fines, penalties, and compensation for damages as result of
violations regarding social and human rights factors
0
0
Number of severe human rights issues and incidents connected to own workforce
0
0
Number of severe human rights issues and incidents connected to own workforce
that are violations of UN Guiding Principles and OECD Guidelines for Multinational
Enterprises
0
0
Amount of material fines, penalties, and compensation for severe human rights issues
and incidents connected to own workforce
0
0
It should be noted that there have been no serious incidents in the ﬁeld of Human Rights or that constitute cases of
non-compliance with the United Nations Guiding Principles on Business and Human Rights, the ILO Declaration on
Fundamental Principles and Rights at Work or the OECD Guidelines for Multinational Enterprises.
With regard to the single recorded report of a breach submitted through the Whistleblowing mechanism, the case
was reported in 2025 and is still under investigation. For this reason, it is not possible to provide further details on
the subject of the report.
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313
Working conditions
Policies related to employment protection and labour relations
The protection of the rights of the VUB Group's workers is governed by the general principles of the Code of Ethics,
the Human Rights Policy, the Principles on Diversity, Equity and Inclusion and the collective bargaining system, which
operates fully on two distinct and complementary levels, the ﬁrst at the local level of the VUB Group and the second
at the Intesa Sanpaolo Group level.
The VUB Group is committed to guarantee trade union freedoms and the right of association in representative bodies
of VUB Group's workers, adopting complementary protection measures and recognising all individuals the possibility
to express their individuality and creativity in their work, enhancing diversity and the speciﬁcities of each individual,
as a drive for innovation and an essential contribution to the VUB Group's growth.
In line with the commitment enshrined in the Code of Ethics, the management model is based on agreements
relating to bargaining. Compliance with these rules, along with legal requirements, contributes to fostering a positive
work environment and continuously enhancing the quality of relationships between the company and its employees.
The Code of Ethics is made available both on the company intranet, for the Group's employees, and on the
institutional website, for external stakeholders.
The employment relationship is also regulated, for the matters delegated, by collective bargaining. Dialogue with
the trade unions is conducted regularly, with the aim of seeking solutions to improve the well-being of the Group’s
employees, particularly those in need, and positively contribute to productivity through activities in the areas of social
security, assistance and services for families, education, and work-life balance.
The development of labour policies is managed by the HR and Organization Department, with the Head being
responsible for their implementation, which has the task of deﬁning trade union agreements and monitoring their
implementation.
The VUB Group did not implement any speciﬁc policies addressing trafﬁcking in human beings, forced labour or
compulsory labour and child labour, as they are considered immaterial, also thanks to the regulation and controls in
place that are enforced by the states in which VUB Group operates.
Policies related to compensation
VUB Bank has concluded Collective Agreement with the trade union organization represented by the Council of
Trade Union Representatives of VUB, a.s. (ROZ) in accordance with the provisions of generally binding legal
regulations, Act No. 2/1991 Coll. on Collective Bargaining, as amended, and Act No. 311/2001 Coll. the Labour
Code, as amended. It regulates individual and collective labour relations between VUB, a.s. and its employees,
including the right to adequate compensation.
The Bank adheres to the principle of equal treatment in all aspects of labour relations as established by Act No.
365/2004 Coll. on Equal Treatment in Certain Areas and on the Protection Against Discrimination, as amended (the
Anti-Discrimination Act). VUB’s obligation regarding non-discriminatory pay practices is also stipulated in the
Collective Agreement. Differences in remuneration must not be based on gender, race, ethnicity, or other potentially
discriminatory factors.
The VUB Group, provides employees with a salary for the work performed. Speciﬁcally, for VUB Bank remuneration
is determined in accordance with the provisions of the Labour Code, under the conditions agreed upon in the
collective agreement, and speciﬁc regulations related to performance evaluation of managerial, non-managerial and
network population – VUB Remuneration and Incentives Policy, internal document Performance and Development
Management System and the internal regulation Employee Remuneration System.
VUB Group is obliged to agree on the main principles, guidelines, and forms of employee remuneration with the
representatives of Trade Union. The salary increase is agreed upon with the ROZ on annual basis even though the
collective agreement is typically concluded for 3 years. The Bank’s remuneration pay policy reﬂects the economic
conditions in Slovakia.
The variable salary component is a motivational tool used by the Bank to increase the personal involvement of
employees in achieving set tasks and to reward the quantity and quality of the work performed and the contribution
to the Bank.
In particular, the VUB Group ensures that the deﬁnition of remuneration and incentive systems, as well as decisions
related to remuneration, are based on merit and professional skills, regardless of gender or other forms of diversity,
and are inspired by principles of fairness. For further information on the subject, reference is made to the Policies
related to equal pay section of the Diversity, equity and inclusion section.
The development and implementation of the policies is entrusted to the Head of HR and Organization Department.
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314
The Policies are available to all VUB Bank employees at the VUB's intranet.
Commitment to Human Rights and Ethical Standards
VUB Bank and the VUB Group are ﬁrmly committed to protecting the human rights of their employees and to
upholding the highest ethical standards. This commitment is embedded in the Code of Ethics, the Human Rights
Principles, the Diversity, Equity and Inclusion (DE&I) Principles, as well as in other internal policies governing labour
conditions and equal treatment.
These documents are inspired by and aligned with internationally recognised frameworks, in particular:
–
the United Nations Universal Declaration of Human Rights,
–
the ILO Declaration on Fundamental Principles and Rights at Work,
–
the OECD Guidelines for Multinational Enterprises,
–
the OECD Due Diligence Guidance,
–
the UN Guiding Principles on Business and Human Rights.
The Group actively promotes the principles of decent working conditions, a safe and healthy working environment,
equal pay for work of equal value, the right to collective bargaining, and the rejection of discrimination, harassment,
or any form of forced or child labour. These commitments are applied in everyday practice and form the foundation
of all human resources processes within the Bank.
General Approach to Respect for Human Rights, Including Labour Rights
The VUB Group adopts a comprehensive and preventive approach to human rights. Respect for human rights is
integrated into employment relationships, human resources management, management decision-making processes
and risk management systems. The Bank:
–
ensures equal opportunities,
–
guarantees non-discriminatory treatment,
–
promotes diversity and inclusion (including equal pay, gender equality, age diversity and the inclusion of persons
with disabilities),
–
ensures occupational health and safety,
–
applies a zero-tolerance policy towards violence and harassment,
–
provides employees with opportunities for professional and personal development through mandatory,
professional and voluntary training,
–
ensures transparency of internal processes, including performance management, remuneration, career
development and job changes.
This approach is supported by due diligence processes and mechanisms for identifying, assessing, preventing and
mitigating potential risks, in line with ESRS requirements.
General Approach to Engaging the Workforce
The Group actively involves its employees and their representatives in decision-making on matters that affect them.
Engagement is carried out through a range of formal and informal channels, including:
–
social dialogue and regular communication with trade unions,
–
formally established Employee Councils,
–
focus groups and consultations prior to the implementation of signiﬁcant changes,
–
climate and engagement surveys (with outcomes translated into concrete action plans),
–
workshops, feedback tools, HR Info Brieﬁngs and other communication platforms,
–
employee involvement in strategy development, process design and talent programmes.
The process also includes individuals who may be more vulnerable (e.g. employees with disabilities, parents returning
from parental leave, older employees), in order to ensure non-discriminatory access to opportunities and fair working
conditions.
General Approach to Measures for Providing or Enabling Remedy
The VUB Group operates a comprehensive system of grievance and remedy mechanisms that allows employees to
safely report complaints, concerns and issues. This system primarily includes an internal whistleblowing mechanism,
compliant with EU and Slovak legislation, enabling anonymous reporting, as well as other reporting channels, such
as the possibility to report breaches of ethical conduct via
etickykodex@vub.sk
or
codice.etico@intesasanpaolo.com
.
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315
These remedy mechanisms are designed to:
–
ensure a timely and fair response,
–
prevent the recurrence of incidents,
–
strengthen employee trust in the integrity of internal processes,
–
foster a culture of transparency, respect and safety.
Metrics related to collective bargaining and social dialogue
As of 31 December 2025, 98% (2024: 98%) of the VUB Group's employees are covered by the Collective
Agreement.
With reference to the Slovak Republic, which is the only country with signiﬁcant employment level, the coverage by
the Collective Agreement is 99% (2024: 99%).
There are no agreements providing for employee representation outside EEA. There are also no agreements in place
with employees for representation by a European Works Council (EWC), a Societas Europaea (SE) Works Council, or
a Societas Cooperativa Europaea (SCE) Works Council.
Collective Bargaining Coverage
Social dialogue
Coverage Rate
Employees – EEA (for countries with
>50 empl. Representing >10% total
empl.)
Workplace representation (EEA only)
(for countries with >50 empl. representing >10%
total empl.)
80-100%
Slovakia
Slovakia
Metrics related to adequate wages
The VUB Group is committed to ensuring an adequate salary for all its employees. In this regard, it should be noted
that in every country in which the Group is present, all employees are paid more than the minimum wage set in the
country by law
15
. This information were equally true for 2024 and 2025.
Engagement processes with own workers and their representatives
The industrial relations model adopted and developed by the VUB Group, in agreement with the Council of Trade
Union Representatives of VUB, a.s. (ROZ), has constantly promoted discussion between the parties to identify the
most suitable solutions and tools to face and manage the various phases of growth and reorganization. Concrete
evidence of the ways in which trade union relations are articulated and enhanced in the VUB Group is also given by
the work of bilateral company/trade union bodies, created with the aim of analysing, researching and proposing
positive actions, solutions and tools in the ﬁeld of equal opportunities, welfare, safety and sustainable development.
The function responsible for ensuring the operational involvement of workers’ representatives is that of HR and
Organization Department.
The dialogue with the Trade Unions on company projects is constant, timely and aimed at identifying mutually
agreed solutions that address the various needs brought forward by both parties.
Remediation processes with own workers and their representatives and channels to raise concerns
The VUB Group has set up several conﬁdential company channels to report requests, needs, and inconveniences, for
example, the Code of Ethics mailbox and the whistleblowing channel. The Code of Ethics mailbox allows you to
report any non-compliance via email, ensuring maximum conﬁdentiality and protection from any form of retaliation,
discrimination or penalization. Furthermore, the whistleblowing channel allows any authorized person (employees,
collaborators, suppliers, consultants, etc.) to report suspected violations, both actual and potential, through speciﬁc
channels available 24 hours a day. For further information on the Code of Ethics reporting channel and the
whistleblowing procedure, please refer to the section Policies related to protection of whistleblowers and Policies
related to corporate culture in the standard G1 Business conduct.
Targets related to employment protection
VUB Group has not set targets yet, as these are deﬁned, approved and monitored at the level of the parent company,
Intesa Sanpaolo, within the framework of the Group’s consolidated strategy and governance structure.
As a subsidiary, VUB Group aligns with these Group-level objectives, ensures their implementation in its operations,
and provides relevant performance data for the purpose of consolidated reporting. The applicable targets,
methodologies, and disclosures on progress are therefore included in the consolidated reporting published at the
Intesa Sanpaolo Group level, of which VUB group forms part.
15
For countries in the European economic area, reference is made to Directive (EU) 2022/2041 on adequate minimum wages in European Union.
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316
Actions related to employment protection and labour relations
The VUB Group protects employment by considering it one of the key elements of its strategic plan. In the context
of the generational turnover amid technological transformation with a resilient and sustainable business model in
the scenario of digitalization and artiﬁcial intelligence, VUB focuses at enabling service and offer models oriented
towards greater simplicity and effectiveness for customers.
In line with the ISP Group strategy, the VUB Group is working towards the rejuvenation of the workforce to ensure
smooth generational change, kicking off the Early Retirement Plan, fully voluntary program aimed at colleagues
already in retirement age, or max 2 years prior to retirement. The aim is to offset the program by acquiring or
developing the new talent potential, while optimizing workﬂows through technological solution, thus gaining more
time for people to focus on more value-added activities. This includes freeing up time to dedicate to professional
development activities through various training activities for upskilling/reskilling, to better address the need for new
widespread digital skills and new professions.
In terms of development, full-ﬂedged digital skills academy, as well as the wide-ranging People for Future program,
featuring analytical, interpersonal, technology or leadership skills development was setup in 2023 and is an ongoing
activity aimed to requalify or upskill the workforce capacity towards new priority initiatives.
The VUB Group is also strongly focused on implementing the actions towards the New Way of Working,
implementing Smart Work principles to support the wellbeing of employees and offer the possibility to accommodate
to both professional and private responsibilities and expectations.
The VUB Group commitment to fair compensation ensures that its employees are paid adequately for their work, in
line with company values, legal requirements, and social responsibility. Salaries are structured based on job grades,
roles, responsibilities, and market benchmarks.
The VUB Group and speciﬁcally the VUB Bank regularly benchmarks its pay practices against other banks and other
companies in Slovakia to maintain adequate remuneration. The Bank benchmarks its Critical population to 75
percentile of the market, while Specialists, Flexible and Core population is benchmarked to the median of market
remuneration; differentiated according to the professional family to which they belong. This is crucial for attracting
and retaining talent, as employees often compare their compensation packages against industry standards.
Competitive salaries help prevent turnover and make the company an attractive place to work.
A process of annual salary revision has been established to ensure compensation of its employees remains
competitive and reﬂects changes in market conditions, cost of living, and inﬂation. It is important to emphasize the
Bank's commitment to target salaries meeting the ‘living salary‘ standard rather than just the legal minimum salary.
The Bank's current minimum salary is nearly 47% higher than legal minimum salary in Slovakia. Compared to
minimum legal requirements, VUB Bank has set up higher minimum base salaries for all work difﬁculty degrees
stipulated in Section 120 of the Labour Code.
In addition to base salaries, the Bank motivates employees through performance-based bonuses, aiming to reward
personnel for outstanding performance and to align their success with the company’s success.
VUB Bank performs analysis of existing gender pay gaps and addresses them also within annual salary revisions and
with EU Directive 2023/970, coming into force in June 2026, the Bank is planning a revision of its pay structures.
The aim is to introduce a policy where employees are made aware of the salary range for their role or Department.
Transparency around pay scales and salary bands is expected to foster trust and reduce feelings of inequity or
favouritism among employees.
All these actions ensure that pay is fair, competitive, and aligned with employees' contributions, fostering an
environment of trust, motivation, and long-term employee satisfaction.
Diversity, Equity and Inclusion (DE&I)
Policies related to DE&I
The VUB Group adopts the Diversity, Equity and Inclusion Principles (hereinafter ‘the DE&I Principles‘) to specify its
commitment to promoting and disseminating, both internally and externally, an inclusive policy that enhances all
forms of diversity. In this sense, in the DE&I Principles, the Intesa Sanpaolo and the VUB Group explicitly states its
inclusive approach to all forms of diversity, based on respect for all people, enhancement of talents, meritocracy and
equal opportunities, also assuming concrete commitments to promote an inclusive environment and deﬁning the
expected behaviours from all the Group's staff. A speciﬁc section is dedicated to gender equity commitments, aimed
at ensuring equal opportunities in hiring processes, promotion to roles of responsibility, appointments to
management and in the succession plan for top roles. The policy explicitly states the principle of zero tolerance for
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317
any discrimination and non-compliance with what is established must be reported to the channel indicated in the
document. Periodic monitoring of the commitments made by the Intesa Sanpaolo Group is entrusted to the Intesa
Sanpaolo DE&I Steering Committee.
The DE&I Principles aim to create a work environment characterized by plurality and respect, protecting every form
of diversity, whether it be gender, gender identity or expression, affective-sexual orientation, marital status and
family situation, age, ethnicity, religious belief, political and trade union afﬁliation, socio-economic status, nationality,
language, cultural background, physical and mental conditions, physical appearance or any other characteristic of
the person, even related to the manifestation of thought. This goal is considered an ethical duty towards all people
in the Intesa Sanpaolo and the VUB Group and towards every stakeholder. It is also a business and sustainability
priority, as the integration of diverse ideas and skills stimulates innovative solutions and more effective decision-
making processes. Furthermore, it enhances the reputation of the corporate brand, improving retention, motivation
of people and attractiveness to the best talents. Moreover, it maximizes the creation of value for stakeholders,
gathering improvement suggestions from certifying bodies, international indices and stakeholders in general, which
contribute to deﬁning best practices in terms of inclusion.
With reference to the commitment to ensuring gender equity, the following principles are taken into consideration:
–
Annual intake balanced by gender;
–
The pools of candidates for ﬁrst appointment in managerial roles, on an annual basis, balanced by gender;
–
The pools of candidates for management on the annual total balanced by gender;
–
The pools of candidates for senior leadership roles (1° line managers and Head of department), foresee at least
one application from the less represented gender for each position.
Additionally, speciﬁc commitments and positive actions are planned to promote inclusion, including:
–
Promoting the accessibility of spaces, communications, information and training;
–
Ensuring equal treatment of same-gender unions in company regulations;
–
Spreading the value of inclusion through training addressed for DEI ambassadors, awareness-raising and the use
of inclusive language;
–
Creating an inclusive environment based on trust, respect and enhancement of cultural and personal diversity;
–
Combating every form of discrimination and harassment;
–
Promoting inclusion also in the territories and socio-economic contexts in which the company operates.
The DE&I Principles apply to everyone within the VUB Group, guiding their interactions with internal and external
stakeholders and to the people who make up the corporate administrative and control bodies. As for the people
who collaborate with the VUB Group without an employment relationship (for example, non-dependent ﬁnancial
agents/consultants, suppliers and sub-suppliers) respect for the values and principles expressed here is required by
taking knowledge of speciﬁc information dedicated to them. The VUB Group also undertakes to support and
promote the adoption of diversity, equity and inclusion values and principles by customers – particularly Business
and Corporate customers – in the context of their ESG policies.
In line with the DE&I Principles, the VUB Group undertakes to intensify dialogue with stakeholders who bring speciﬁc
instances and proposals for improvement, with an approach of openness and constructive exchange, also through
the design and launch of shared actions.
The person holding the role of Head of HR and Organization identiﬁes objectives and strategies for their achievement
and ensures that the commitment of all VUB Group structures is adequate and consistent with what is established
in the DE&I Principles. Additionally, monitoring related to the Principles’ chapter Commitments on gender equity is
carried out on a quarterly basis and on a yearly basis is submitted to the Management Board for the status report
and to set corrective initiatives.
The Rules for Combating Sexual Harassment express the VUB Group's strong commitment to preventing and
combating any form of sexual harassment to ensure full respect and maximum protection of human dignity. They
demonstrate zero tolerance towards any type of harassment. The goal is to create the conditions for episodes of
sexual harassment to be reported, ensuring an effective and detailed process for managing reports that guarantees
maximum rigor and maximum protection of the privacy of those involved.
The aforementioned Rules apply to all dependent staff of the VUB Group in their activities within and outside the
Group; to non-dependent agents and ﬁnancial consultants/collaborators in their interactions with internal and
external interlocutors; to people with a temporary work contract; to participants in internship/traineeship initiatives;
commercial partners of the Group in any activity of contact with the Group.
The Rules also apply on the occasion of social events, business trips, training and activities that take place outside
the usual workplaces but are related to the professional sphere, as well as outside this work context in cases where
both the perpetrator of the sexual harassment and the victim fall within the applicable categories. For the Rules, the
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318
role of guarantor of the complaint management process is entrusted to the Head of the HR and Organization
Department.
The Principles on Diversity, Equity and Inclusion and the Rules for the ﬁght against sexual harassment are also inspired
by the main existing national and international guidelines on corporate social responsibility (e.g. UN Universal
Declaration of Human Rights, UN International Covenant on Civil and Political Rights, Declaration on Fundamental
Principles and Rights at Work (ILO), ILO Convention 190 of 21 June 2019 and ILO Recommendation No. 206 on the
Elimination of Violence and Harassment in the World of Work).
The commitment to the inclusion of people with disabilities is not only a legal obligation but also a core principle of
our corporate culture. VUB Group actively promots an inclusive work environment and implements policies that
support equal opportunities for employees with disabilities. The obligation to employ disabled citizens is regulated
by Act No. 5/2004 Coll. on Employment Services and on Amendments and Additions to Certain Acts, as amended
(hereinafter referred to as the ‘Employment Services Act‘).
Beyond fulﬁlling the legal requirements, the VUB Group is committed to providing meaningful employment
opportunities for people with disabilities, ensuring workplace accessibility, and fostering an inclusive and supportive
environment. We actively engage in initiatives that facilitate professional growth, equal career development, and
workplace adjustments tailored to individual needs.
The Principles on Diversity, Equity and Inclusion and the Rules for combating sexual harassment are published on
intranet page.
Metrics related to diversity by gender and age
In the table below is reported the distribution of employees by age group, in number of people and in percentage,
on the total employees of the VUB Group as of 31 December, 2025.
Distribution of employees by age groups
2025
2025%
2024
2024%
Under 30 years old
371
11%
448
12%
Between 30 and 50 years old
2,162
63%
2,310
64%
Over 50 years old
917
26%
879
24%
In terms of gender distribution among employees at the top management level (managerial level) as of 31 December
2025, the total number of employees is 10, of which 80% are male and 20% are female. In particular, the table
below shows the distribution of employees in top management positions by gender, in number of people and as a
percentage of the total, as of 31 December 2025.
It is speciﬁed that the top management includes CEO, Deputy CEO, Advisor to CEO, Members of Management Board
and Executive Directors of daughter companies.
Number of employees at the top management level
2025
2024
Female
2
2
% of total at the top management level
20%
17%
Male
8
10
% of total at the top management level
80%
83%
Other gender
0
0
% of total at the top management level
0
0
No data
0
0
% of total at the top management level
0
0
Total
10
12
Policies related to equal pay
The VUB Group adopts gender-neutral remuneration and incentive policies which contribute to pursuing complete
parity among staff. They ensure that, for equal work, VUB Group personnel have an equal level of remuneration,
including in terms of conditions for its recognition and payment.
In particular, the VUB Group ensures that the deﬁnition of remuneration and incentive systems and the adoption of
decisions related to remuneration are independent of gender (as well as any other form of diversity such as affective-
sexual orientation, marital status and family situation, age, ethnicity, religious belief, political and trade union
afﬁliation, socio-economic status, nationality, language, cultural background, physical and mental conditions or any
other characteristic of the person also related to the expression of one's thought), are based on merit and
professional skills and are inspired by principles of equity.
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319
In order to make it possible to apply gender-neutral policies and to evaluate their effectiveness, the Intesa Sanpaolo
and VUB Groups adopt:
–
Organizational position measurement systems, taking into account the responsibilities and complexity managed
by the different roles. In particular, for the managerial population, the VUB Group has adopted the Global
Banding system, which is based on the grouping into homogeneous bands of managerial positions that are
comparable in terms of complexity/responsibility levels managed, measured through the international role
evaluation methodology International Position Evaluation (IPE). The non-managerial population is segmented
based on the career title assigned according to certain criteria, including seniority, autonomy, complexity but
also skills, economics, impact and exposure. This segmentation aims to enhance the level of professional
contribution within their operations and the progressive specialization of skills – or the professional ﬁgure of
belonging, also taking into account the role system deﬁned in the second-level collective bargaining;
–
For the managerial population, market salary references are associated with each Global Banding range and
differentiated based on the professional family of belonging and geography. As for the population of non-
managerial positions, career title levels are associated with market trend references differentiated based on the
professional family of belonging and geography;
–
Incentive/reward systems linked to objective parameters that allow merit and performance to be recognized.
The VUB Group adheres to the principle of equal treatment in all aspects of labour relations as established by Act
No. 365/2004 Coll. on Equal Treatment in Certain Areas and on the Protection Against Discrimination and Amending
and Supplementing Certain Laws (the Anti-Discrimination Act). VUB’s obligation regarding non-discriminatory pay
practices is also stipulated in the Collective Agreement. Differences in remuneration must not be based on gender
or other potentially discriminatory factors.
As the VUB Group belongs to Intesa Sanpaolo Group, the VUB Supervisory Board acknowledges on annual basis the
Intesa Sanpaolo Group´s framework on remuneration, composed of Intesa Sanpaolo Group Remuneration Discipline
and the Intesa Sanpaolo Report on the remuneration policy and compensation paid. Both documents have been
prepared in accordance with the sector regulations in force and provide general regulatory framework for the Bank's
remuneration policy.
On an annual basis, the VUB Supervisory Board, with the support of the Remuneration Committee, analyses the
neutrality of the policies with respect to gender and veriﬁes the gender pay gap and its evolution over time according
to the methodology deﬁned by sector regulations. In summary, the gender pay gap is calculated for positions of
equal value and country by country, distinguished by: (i) Risk Takers, excluding members of the Management Bodies;
(ii) the members of the Management Board; (iii) the members of the Supervisory Board; (iv) the remaining staff.
It is important to note that all changes to the remuneration and incentive system of the Bank are subject to
negotiation and ﬁnal approval of the Council of Trade Union Representatives of VUB, a.s.
On an annual basis, the VUB Supervisory Board with the support of the Remuneration Committee analyses the
neutrality of policies with respect to gender and veriﬁes the gender pay gap and its evolution over time according
to the methodology deﬁned by sector regulations. It should be noted that the reasons for the gender pay gap are
properly documented and, where necessary, corrective actions are taken.
For detail on the Policies see Policies related to compensation section.
Metrics related to equal pay and remuneration
Looking at the overall pay differences between men and women across the entire organization, in line with
the methodology required by CSRD the gender pay gap within the VUB group has been calculated, for 2025, to be
at 36,3% (in the year 2024 gender pay gap calculated by the same methodology was 35,4%, while previously
published gender pay gap was 34% ).
CSRD methodology requires to calculate the male-female pay gap – regardless of their roles. No objective factors
are considered within the methodology, therefore a more accurate metric to identify the principle of equal pay for
equal work would be the adjusted pay gap, which is essential to classify employees into homogeneous groups
performing the same work within the same job role, representing work of equal value, and then comparing their
compensation, after accounting for factors such as job role, education, and experience that determine pay. VUB is
and will be part of the Equal Pay project of ISP group in 2025-2027.
As of today, further analysis highlights the following:
–
Employees in both the Retail and Corporate Business Network are paid almost equally, with the percentage of
the pay gap being close to zero;
–
At the Headquarter, there is a slight difference, with men earning moderately more than women. This dynamic
is driven by the structure of Headquarter positions, with a higher percentage of men occupying more specialized
and IT roles.
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–
Among managerial positions, the compensation is nearly balanced between genders.
These observations show that the gender pay gap, as per roles distribution, is to be considered minimal.
In fact, it is crucial to highlight that the composition of the VUB group's workforce is predominantly female,
accounting for 67% (2024: 67%) of the active population.
A signiﬁcant portion of this female workforce, 46% in 2025 (45% in 2024), is employed within the Retail Business
Network branches. These positions, independently from the gender, are generally associated with lower income
levels compared to unique roles at the Headquarter. Furthermore, women represent 83% (2024: 83%) of the Retail
Business Network's population, emphasizing the concentration of female employees in lower-paying roles.
The above mentioned detailed breakdown helps in understanding the nuances and underlying reasons for the overall
gender pay gap within the VUB group. It is crucial to continue monitoring these disparities and implementing
strategies to address and mitigate the pay inequalities effectively.
For the 2025 ﬁnancial year, the VUB Group recorded a total remuneration rate of 27,75 (year 2024 with the same
methodology used represented 22,93, while originally published remuneration ratio was 18,89). This ratio is deﬁned
as the ratio of the total annual remuneration of the person receiving the highest salary to the median total annual
remuneration of all employees (excluding the highest paid individual).
It should be noted that for both metrics represented in this section, no correction factors are applied to the
compensation paid, taking into account the cost of living in the country of reference.
Engagement processes with own workers and their representatives
The workforce engagement process in VUB Group is coordinated by the Director of Human Resources and
Organization and is conducted through multiple complementary channels. These include the involvement of trade
union representatives, ongoing dialogue with internal communities, regular employee satisfaction and engagement
surveys, as well as ad hoc initiatives focused on active listening, including individual meetings, workshops and events
aimed at obtaining employees' opinions and expectations, especially from a diversity and inclusion perspective.
The Director of Human Resources and Organization, in cooperation with the internal communication and CSR
departments, act as internal and external ambassadors who actively support the principles of diversity and inclusion
and raise awareness of their beneﬁts within the organization and towards external stakeholders.
Group-wide surveys are conducted every two years, alternating. First is focused on assessing the overall atmosphere
in the company and employee satisfaction (Corporate Climate Survey, conducted in 2025). The second survey,
without a ﬁxed periodicity, is devoted to the topics of diversity, equality and inclusion (DE&I). In addition, one-off
surveys are also conducted, such as the Short Engagement Survey, feedback from internal events and activities is
regularly evaluated, and targeted surveys are conducted focused on speciﬁc projects or teams.
The DE&I structure is continuously available to internal communities and employees in cases where they have
suggestions or when a topic that directly concerns them is being addressed. In such situations, a preliminary
discussion takes place on the possibilities of their involvement in further steps. Representatives of trade unions are
involved monthly, not only within the scope of collective bargaining topics, but also on issues that are not directly
regulated by the collective agreement.
Individual forms of employee engagement serve as the basis for output reports that assess the level of response and
acceptance of speciﬁc initiatives, projects or events. The results are processed in an aggregated and anonymized
form and used to set future measures.
The DE&I structure remains open to always receiving suggestions, which can also be sent via a dedicated email box.
Additional information is also obtained through regular surveys. Diversity and inclusion are also supported through
internal and external communication channels, with employees having access to relevant information on the intranet,
including an overview of available services and support options.
Remediation processes with own workers and their representatives and channels to raise concerns
Employees of the VUB Group have access to two main processes for reporting concerns, doubts or suspected
violations of rights or conduct: either through the process for reporting breaches of the Code of Ethics and/or
through the whistleblowing process. The objective of both mechanisms is to enable the timely handling of reports
and the remediation of any potential adverse impacts. Further details on these mechanisms are set out in ESRS G1
– Business Conduct.
The Diversity, Equity and Inclusion (DE&I) principles provide for the use of the Code of Ethics mailbox for reporting
breaches related to DE&I matters.
Given the highly sensitive nature of such issues, reports concerning sexual or any other form of harassment are
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handled through the whistleblowing process. Within this framework, the roles and responsibilities of the Ethics
Committee and the cooperating departments are clearly deﬁned, and reports are thoroughly investigated by a
multidisciplinary working group. Where any breach is conﬁrmed, appropriate remedial measures are taken.
The effectiveness of these mechanisms is supported by regular monitoring, timely acknowledgement of reports and
the protection of whistleblowers against any form of retaliation.
Employees also have access to support in relation to disabilities through the Human Resources and Organisation
Department, which acts as a contact point for reporting related concerns. Since 2023, a specialised programme
focused on the employment of neurodivergent individuals has been in place, under which job opportunities have
also been created within the VUB Group for people on the autism spectrum.
Targets related to diversity, equity and inclusion
VUB Group has not set targets yet, as these are deﬁned, approved and monitored at the level of the parent company,
Intesa Sanpaolo, within the framework of the Group’s consolidated strategy and governance structure.
As a subsidiary, VUB Group aligns with these Group-level objectives, ensures their implementation in its operations,
and provides relevant performance data for the purpose of consolidated reporting. The applicable targets,
methodologies, and disclosures on progress are therefore included in the consolidated reporting published at the
Intesa Sanpaolo Group level, of which VUB group forms part.
Actions related to diversity, equity and inclusion
In 2025, VUB Group continued to strengthen its commitment to diversity, equality and inclusion (DE&I) through the
development of policies, targeted programs and a supportive corporate culture. DE&I activities were directed at all
employees without distinction and aimed at ensuring fair conditions, equal opportunities and a respectful working
environment.
Updating the principles and governance framework
During the year, the process of updating the Diversity, Equality and Inclusion Principles continued in line with the
requirements of the Intesa Sanpaolo Group. The updated version of the document brings more precise commitments
in gender equality, for example, adjusting the rule on the representation of the underrepresented gender in the list
of candidates for management positions. Supervision of the fulﬁlment of commitments was strengthened in the
form of regular quarterly reporting to the parent company.
Training, awareness activities and employee development
2025 brought several mandatory and voluntary trainings, supporting a fair and safe working environment.
Mandatory trainings on the Group's Internal Code of Conduct and Whistleblowing Policy were completed by
thousands of employees (more than 98% of employees by 31.12.2025), which contributed to the expansion of
awareness of rights, protection of whistleblowers and prevention of unwanted behavior as a predisposition for
further expansion of DEI initiatives in the Group.
In addition, during 2025, VUB Bank focused on further expanding employee competencies in ESG through webinars
and open dialogues. Diversity and inclusion are an integral part of setting up internal processes and procedures
related to ‘Social & Governance’, therefore the entire chapter was dedicated to understanding the group's operations
in the context of equal employment rights in the approach to performance evaluation, growth and development or
beneﬁts, as well as the bank's socially responsible activities. VUB Bank makes great efforts to ensure a psychologically
safe environment, where every employee has the right to be heard and the right to equal access regardless of their
differences. It makes great efforts to support mental health in the workplace, which was also recognized by receiving
the ‘Zlaté duše’ certiﬁcate from the League for Mental Health (Liga za duševné zdravie) in June 2025. This conﬁrmed
the group's interest in creating a safe environment and developing employees in mental health, raising awareness
and providing effective assistance, for example in the form of a 24/7 accessible helpline. The program also includes
the development of the management population to create an inclusive work environment. The bank implemented
an intensive development program focusing on the management of the sales network, while continuing the
‘Psychological Safety’ (Psychologické bezpečie) program designed for speciﬁc teams. Among other initiatives, it is
worth highlighting participation in the Intesa Sanpaolo group program, which in 2025 was focused on supporting
balance and setting healthy boundaries and kindness or mindfulness towards other people. Together, we promote
the values that are anchored in the basic governing documents and guidelines of VUB, a. s.
The use of gender-inclusive language is considered a standard of communication at VUB both internally and
externally.
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Support for inclusion and disadvantaged groups
The DEI working group implemented several speciﬁc measures in 2025 to support employees with health disabilities.
Based on feedback from a specialized survey, new support mechanisms were introduced – from ergonomics to work
environment adjustments to work ﬂexibility. At the same time, a separate contact point was established for this
topic. The bank also continued to cooperate on the Profesia Lab program, which supports the employment of
neurodivergent colleagues, where it is among the TOP employers on the market.
Equal opportunities
The principles of equality in terms of equal opportunities and remuneration are further reviewed in the context of
local and European regulations. VUB has taken steps to align remuneration in order to reduce the gap between the
wage assessment of men and women. This commitment is supported by a commitment to have a gender-balanced
succession list for senior management positions and a program to speciﬁcally develop women in their leadership
skills so that they are prepared to apply for management positions.
DEI in governance, reporting and CSR
DEI remains an integral part of ESG governance. Responsibilities for data collection, reporting and coordination have
been adjusted for 2025, with the internal communication, CSR and DEI agendas being uniﬁed. The year also included
regular inputs into CSRD reporting, updating internal data and working with internal audit to transparently report
any breaches of desired employee behavior.
Actions related to the inclusion of people with disabilities
The VUB Group supports the inclusion of persons with disabilities through targeted measures aimed at creating an
inclusive and accessible working environment. Particular emphasis is placed on removing barriers, promoting equal
opportunities and accommodating the individual needs of employees.
One of the key initiatives is VUB Bank's participation in the ProfesiaLab project, through which the Bank creates
opportunities for internships and, subsequently, for permanent employment for individuals with neurodivergent
conditions. The project also includes training for managers and employees on topics related to fostering an inclusive
workplace, with the objective of supporting acceptance, understanding and effective collaboration within teams.
Employees with disabilities or with deteriorated health conditions may request specialised work equipment designed
to increase comfort and facilitate job performance. In addition, the VUB Group has introduced the possibility of
remote work of up to 100%, enabling better alignment of work requirements with health-related needs and
expanding employment opportunities for individuals with health limitations.
In the area of employing persons with disabilities, VUB Bank fully complies with all applicable legislative requirements
in the Slovak Republic. At the same time, it ranks among employers that actively create favourable working
conditions for persons with disabilities and support their long-term integration and sustainability in the labour
market.
An integral part of an inclusive and safe working environment is a strong focus on mental health. The VUB Group
systematically develops activities in this area and is among the leaders in the Slovak labour market in implementing
modern tools for the prevention of mental health issues and the promotion of employee well-being.
VUB is an active member of the Employers' Coalition for Mental Health, thereby committing to raising awareness,
reducing stigma and supporting open dialogue about mental health in the workplace. A key element of this strategic
approach is a comprehensive mental health prevention programme, which includes regular lectures, discussions and
expert-led webinars held on a monthly basis and accessible to all employees.
The VUB Group has also implemented the certiﬁed Mental Health First Aid programme, which provides employees
with practical tools to recognise warning signs, support colleagues in challenging situations and guide them towards
professional help. In addition, employees have access to a free 24/7 assistance helpline, through which they can
anonymously use psychological counselling services.
In recognition of its systematic efforts in this area, VUB became the ﬁrst bank in Slovakia to receive the Golden Souls
Certiﬁcate awarded by the League for Mental Health
–
a prestigious recognition for organisations demonstrating an
exceptional approach to caring for employees' psychological well-being.
As psychological safety in the workplace is one of the core pillars of modern inclusive leadership, VUB also addresses
this topic within the training and development of managers. Training programmes focus on building trust, open
communication, mutual respect and a sensitive approach to the individual needs of team members.
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Training and skill development
Policies related to training and development
Training and communication are two fundamental levers for engaging all individuals within the VUB Group in a
process of continuous growth and enhancement with the aim of guaranteeing them the best professional
experience. In line with the Intesa Sanpaolo Group 2022-2025 Business Plan, and VUB Group Strategy, the Intesa
Sanpaolo and VUB Groups continue to invest in its people, creating a unique ecosystem of skills suitable for both
the current context and its future evolution.
In the belief that continuous development and training of its people represent an important distinguishing and value-
enhancing factor, the Intesa Sanpaolo and VUB Group has committed to further strengthening its presence in
compulsory training, thus also responding to the requests of the Supervisory Authorities.
The approach of the VUB Group to the Learning and Development of its employees is integrated to the Bank's
strategy, ensuring employees possess the skills necessary to achieve business objectives and are pivotal in engaging
all employees with VUB’s commitment to Environmental, Social, and Governance (ESG) principles. This approach
caters to various target groups within the organization, fostering an understanding and awareness of these
principles, their signiﬁcance, and alignment with VUB's values and strategic goals.
VUB equips employees with the knowledge and skills to integrate sustainability, agility, innovation, and customer-
centric principles into daily banking operations. The training strategy focuses on sustainable banking proﬁciency,
ensuring employees understand and apply responsible ﬁnancial practices. A strong emphasis is placed on leadership
development programs promoting sustainable banking values, inclusivity, and employee well-being. Digital literacy
and cybersecurity training ensure operational security, aligning with modern banking practices. Additionally,
employees must complete mandatory training ensuring regulatory compliance, professional development, and
adherence to supervisory requirements.
With particular attention to ESG, training follows a phased approach, covering environmental protection,
biodiversity, climate action, and governance topics such as diversity, inclusion, and ethical conduct. The internal
awareness campaign reinforces these principles. Training also ensures compliance with regulations on anti-money
laundering, terrorism ﬁnancing, antitrust, GDPR, and conﬂict of interest management, supporting a zero-tolerance
approach to corruption and reinforcing transparency. In line with the VUB Group's commitment to employee ESG
skill development, various training formats have been implemented, tailored to the speciﬁc needs of the
departments, roles, or management structures involved:
Employee Group
Training Format & Details
All Employees
Voluntary online ESG e-course providing an overview of ESG principles, key
aspects, objectives, and EU guidelines.
Internal campaign on ESG topics
Special Needs Groups
In-depth online or face-to-face training tailored to specific needs.
Workshops and practical problem-solving sessions for employees
responsible for implementing ESG measures.
Professionals and ESG Task Force
Consultations and advisory services for selected groups.
Training ambassadors who mentor others on specific topics such as climate
change and creating an inclusive work environment.
Managerial Population
Focused on leadership culture development.
Emphasizes acquiring ESG knowledge and procedures to ensure
sustainable leadership and effective employee management.
Intesa Sanpaolo Group Rules Concerning Mandatory Training outline the rights, obligations, and conditions for
mandatory training. VUB ensures employees have unlimited access to the training platform and the opportunity to
complete their training during working hours. Retail employees can request two home-ofﬁce days for this purpose.
Line managers are responsible for ensuring their teams fulﬁl training requirements, while HR monitors and reports
on compliance.
In compliance with the Slovak legislation, the VUB Bank provides specialized ﬁnancial education for its branch
network employees and selected positions, certiﬁed for basic and intermediate levels of professional competence.
This training programme is delivered remotely via e-learning courses. Upon successfully completing the requirements
of each module, participants receive a certiﬁcate of completion in specialised ﬁnancial education, valid for one year.
This certiﬁcation ensures that employees are authorised and competent to deliver professional and high-quality
ﬁnancial advice to clients, with all associated costs covered by the Bank.
To ensure comprehensive coverage, training needs are identiﬁed annually through collaboration with relevant
governance structures and HR functions. These needs are regularly reviewed to address new regulations, supervisory
authority ﬁndings, and evolving business priorities. The management of training requests, impacts, risks and
opportunities related to them is ensured through the establishment of comprehensive training priorities. These
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priorities include differentiated training initiatives according to the role, the areas covered and the associated
responsibilities.
The Learning and Development priorities and target groups are deﬁned on an annual basis by the HR and
Organization Department following requests from business and supporting units. The speciﬁc skills or knowledge
development needs are managed on-demand, based on the current needs of teams or individual experts, considering
the rapidly changing environment and these individual requests are deﬁned, managed and monitored through the
involvement of the competent company structures.
The VUB Group also includes into the training plan the interventions of the parent company training plan, indicated
with Group value, integrated with the initiatives deﬁned and implemented independently on the basis of local and/or
sectoral regulations as well as the related business needs.
Engagement processes with own workers and their representatives
The process of analysing needs and the model of training delivery is guaranteed by the HR and Organisation
Department, which interfaces with Bank’s functions and the Intesa Sanpaolo Group's structures for the detection,
analysis and alignment of training needs.
Professional development is managed by line managers, who have access to a dedicated training budget. This allows
them to arrange external training programs or engage internal trainers based on the speciﬁc learning needs of their
teams. All employees have access to a self-service system via LMS VUB Academy. The system allows them to request
training programs from external partners in line with their development plan.
All employees are required to complete mandatory training covering essential knowledge and skills necessary for
their roles. In addition, VUB Bank offers a wide range of both mandatory and voluntary training programs to support
skill enhancement and continuous learning. New employees follow a structured adaptation plan designed to
facilitate a smooth onboarding process.
Strategic skills development, aligned with the Bank’s long-term vision, is targeted at selected employee groups based
on predeﬁned criteria. Additionally, employees can enrol in open internal and external training programs to further
enhance their competencies.
To support continuous learning, all managers have access to the Seduo online platform, which offers a wide range
of soft skills development courses.
Furthermore, all employees have access to VUB Academia and LEA, two digital learning platforms offering various
training programs relevant to their work. Employees can also explore the Learning and Development section, which
provides access to recordings of past webinars and a wealth of development resources for further inspiration.
For any inquiries related to training and development, employees are encouraged to consult with a dedicated
development consultant, who can provide guidance on tailored learning opportunities and address individual
development needs. This ensures that employees receive personalized support when enhancing their skills and career
growth. Additionally, employees may use this channel to voice any concerns or dissatisfaction regarding their
professional development experience.
For technical issues, general inquiries, or speciﬁc requests related to training programs, employees can contact the
dedicated support team via email at akademia@vub.sk or seek assistance from the AI-powered chatbot for
immediate guidance.
Comprehensive information on learning and development opportunities, including training catalogues, guidelines,
and updates, is readily accessible on the dedicated intranet portal under the Learning and Development section.
Targets and metrics related to the development of the VUB Group's people and talent management
The Intesa Sanpaolo and the VUB Group pursues the goal of providing its employees with growth paths based on
training as an engine for the development of the talents present in the Intesa Sanpaolo and VUB Groups, as well as
the ability to attract people from outside. Consequently, it has established qualitative objectives related to the
provision of cross-training hours to all employees, along with speciﬁc learning and collaboration methods.
In this context, the safeguards established by the VUB Group enable continuous monitoring and addressing of these
issues, making it possible to achieve the set objectives even without a precise deﬁnition of quantitative and
measurable targets within a limited time horizon.
Actions related to training and development of VUB Group's people
The VUB Bank recognizes skill development and employee education as the most crucial enabler essential for
achieving its strategic ambitions. Accordingly, continuous education and professional growth are embedded as
integral components of the group’s overarching strategy. The Bank offers a wide range of training formats designed
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to meet the diverse needs and preferences of its employees. The multi-dimensional approach reﬂects VUB Bank’s
commitment to fostering a culture of continuous learning and professional growth. By offering diverse resources
and opportunities, the Bank empowers employees at every level to advance their skills, achieve excellence, and
contribute meaningfully to the organization’s success.
Employees beneﬁt from access to two robust LMS platforms: LEA Platform, managed by the parent company, Intesa
Sanpaolo (ISP) and VUB Academy, the Bank’s primary Learning Management System (LMS). For managers, the LMS
platform offers a comprehensive overview of team training achievements. Managers are empowered to promptly
address skill gaps by leveraging allocated budgets for professional education and requesting external training or
attendance at the conference, when necessary, thereby aligning employee development with evolving organizational
needs.
In addition, the VUB Bank provides managers with access to an advanced online platform containing on demand e-
courses and live webinars, Seduo, designed to enhance personal development and leadership capabilities. For all
employees, the Bank has established specialized intranet pages that serve as a comprehensive hub for training and
development opportunities. These pages offer detailed information about educational programs, curated content
for inspiration, and a regularly updated calendar of training events. Furthermore, employees have the opportunity
to book personalized consultations with development experts, who provide tailored guidance for crafting individual
development plans.
In 2025, the total number of hours of training used was about 164,045 (2024: 170,228) of which 123,965 (2024:
126,083) in digital mode (e-learning).
In today's fast-paced technological world, navigating and leveraging digital processes is crucial. The VUB Bank
focuses on cultivating a digital mindset and enhancing digital skills through its Digital Academy, which offers
specialized training on Ofﬁce 365 tools.
The Digital Academy provides self-paced e-courses and interactive webinars covering Ofﬁce 365 functionalities,
helping employees work more efﬁciently.
In 2025, we launched the Digital and AI Literacy Program, which included initiatives such as the Digital and Power
Platform Skills Academy and the AI Academy. The Data Skills Academy program focused on developing talent and
deepening expertise in key specialist roles. The initiative supports the automation of routine tasks, increased work
efﬁciency, and the development of a digital mindset among employees.
AI is central to VUB Bank's strategy, with Copilot enhancing productivity by assisting in various tasks. The AI Academy
supports the development of an AI mindset and a deeper understanding of artiﬁcial intelligence. The Innovation Fair
event showcases digital solutions for team management and process optimization, fostering engagement with
digital innovation.
To further digital proﬁciency, the VUB Bank promotes continuous learning through internal ambassadors and
monthly DigiTalks on market innovations. AI-powered solutions like My Buddy, SOFIA, at the same time, the bank is
gradually introducing AI-powered digital assistants (chatbots) to streamline both customer-facing and internal
communication.
The VUB Bank addresses emerging technology risks with a special training program on cyber threats. In 2024,
employees completed specialized training on emerging threats. The Cyber Security program offers practical insights
for professional and personal application.
By combining theoretical knowledge with practical applications, the VUB Bank ensures employees are prepared for
digital era challenges and opportunities, driving personal and organizational success.
The VUB Bank has signiﬁcantly strengthened its framework for educating employees on Environmental, Social, and
Governance (ESG) topics. This commitment is evident in the initiatives carried out in 2025 and the planned activities
for 2026, which aim to enhance employee knowledge, foster engagement, and embed ESG principles into the
Bank's practices. The primary objective of ESG education in 2025 was to ensure that VUB employees gained a clear
understanding of the Bank’s ESG strategy and priorities. Employees were encouraged to participate in e-learning
courses available on the LEA platform, addressing fundamental aspects of sustainability, including the Circular
Economy, the EU Taxonomy, and the ‘ISP4ESG: Our Contribution to the Future‘ initiative.
Additionally, a year-long awareness campaign was conducted to reinforce ESG understanding among employees,
utilizing diverse communication channels, educational events, and active encouragement to foster participation and
dialogue. In 2025, the VUB Bank placed a strong emphasis on delivering targeted training programs for teams and
departments directly responsible for implementing the Bank’s ESG strategy. Specialized training programs were
designed for the Credit Risk team, which participated in an advanced program developed by the Bank’s parent
company, Intesa Sanpaolo (ISP). Similarly, tailored training sessions were offered to other support departments,
including Human Resources, Risk Management, and Operations. Employees further strengthened their expertise by
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participating in industry conferences, which provided valuable insights and inspiration for driving innovation and
sustainable business practices.
To support deeper engagement and specialized knowledge sharing, ESG specialists and members of the Bank’s ESG
task force became active participants in the ESG Club, allowing for consultations on highly specialized topics and
the exchange of best practices and experiences with peers from various sectors.
In the Social dimension of ESG, the VUB Bank continued key initiatives aimed at fostering an inclusive and supportive
work environment. These initiatives included Diversity, Equity, and Inclusion (DEI) Training for Ambassadors, ‘First
Aid for Mental Health‘ Program, Psychological Safety Program, Podcast Series: ‘How to Feel Good‘ and Resilience
Academy. In the Governance dimension, the VUB Bank reinforced compliance with regulatory and organizational
standards through structured training programs and leadership development initiatives. Employees participated in
mandatory training on Ethical Code principles, GDPR compliance, Workplace Safety and Fire Protection, Prevention
of Money Laundering and Terrorist Financing (AML), Anti-Corruption Practices, Regulatory frameworks for foreign
banks (embargoes), Fraud Detection, and Cyber Security. These programs ensure that employee behaviours align
with the highest ethical and operational standards.
In 2024, the Bank introduced corrective mechanisms in its incentive system to reinforce the completion of mandatory
training within the required timeframe and continued this practice in 2025. This measure strengthens accountability
and ensures continuous compliance across all levels of the organization.
In total, 3,267 employees completed the mandatory trainings via both the LEA platform and VUB Academia.
As part of the Intesa Sanpaolo Group’s Talent Management strategy, the VUB Bank actively participates in the
‘Leader of the Future‘ program, which is designed to develop a new generation of managers and professionals with
a strong international and cross-functional perspective. This initiative supports the objectives of the Group’s 2022-
2025 Business Plan, ensuring the continuous development of internal talent and the long-term sustainability of
leadership capabilities. The program consists of two key initiatives: International Talent Program, three-year program
aims to foster leadership potential and managerial skills through personalized learning paths (2 VUB employees
participating), and Key People, initiative focusing on strengthening middle management by identifying and
developing high-potential professionals for future leadership roles (6 VUB employees joined this program).
In addition to these key development initiatives, the VUB Bank also focuses on onboarding new employees and
managers, as well as the development of senior managers. The Bank ensures that new hires are welcomed with a
comprehensive introduction to the organization through immersive onboarding programs, while managers beneﬁt
from tailored adaptation plans to equip them with the necessary tools and knowledge for their roles. Furthermore,
senior managers are provided with continuous professional development opportunities, including individualized
coaching, participation in strategic forums or conferences focusing on fostering innovation and leadership within
the Bank.
*The value for 2024 has been adjusted to the above. The original value of 3,331 represented the number of
employees who completed mandatory training on the topic of Anticorruption and Bribery.
Health and safety
Policies related to health and safety
The occupational health and safety structure ensures the monitoring the risk of non-compliance regarding health
and safety at the workplace in accordance with the Slovak legislation 124/2006 Coll.
The principles and procedures to be followed and applied to ensure a safe working environment are regulated by
VUB in the following documents: Guideline to ensure occupational health and safety and Physical security
architecture (reporting of incidents to the Management Board).
The purpose of documents relating to the Policies aim at formalizing, concretizing and disseminating the strong and
shared values of integrity, excellence, transparency, respect for speciﬁcities, equity, value of the person and
responsibility in the use of resources and the principles of conduct that govern the relationship with its stakeholders
outlined in the Code of Ethics and the Internal Code of Conduct.
The VUB Group's rules on health and safety at work summarise the ‘System of Tasks and Responsibilities‘, which
Comparison of training hours
2025
2024
total number of training hours (h)
164,045
170,228
training hours in digital mode (h)
123,965
126,083
employees which completed mandatory trainings via both the LEA platform
and VUB Academia
3,267
3,411*
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327
involves multiple parties based on speciﬁc professional skills or certain functions. These rules also identify the main
activities related to the management of prevention in the workplace.
While the Bank has no certiﬁcation with regard to international standards (e.g. ISO standards), in the ﬁeld of
occupational health and safety, by adopting the Intesa Sanpaolo Group Rules it has effectively implemented the
main principles stemming from said standards.
The responsibility for implementation lies within the Head of Information security, antifraud, BCM, corporate and
physical security Department. The policies are made available through Bank’s intranet.
Engagement processes with own workers and their representatives
The VUB Group is committed to providing all employees with a safe working environment, ensuring compliance with
occupational health and safety regulations, and fostering a culture of wellbeing. Mandatory training in occupational
health and safety and ﬁre protection is delivered through the local LMS VUB Academy platform and must be
successfully completed with a ﬁnal test and certiﬁcation. In addition to mandatory training, the VUB Group also
implements wellbeing and preventive initiatives aimed at supporting employees’ physical and mental health. In
addition to these mandatory trainings, specialized personnel participate in professional training programs and
certiﬁcation courses to stay informed about the latest safety requirements and best practices.
Beyond regulatory training, the Bank offers optional courses on First Aid and Protection Against Active Threats,
allowing employees to voluntarily enhance their preparedness for emergency situations. In times of crisis, the VUB
Bank also provides psychological support through expert consultations, ensuring that employees have access to
professional assistance when needed.
To promote mental well-being in the workplace, the Bank has introduced the Mental Health First Aid program,
creating a network of trained and certiﬁed employees who offer peer support. Additionally, one of the Bank’s core
educational initiatives is Psychological Safety Training, which is conducted at the team level, including managerial
participation. This program aims to foster an inclusive and supportive work environment where every employee feels
valued and accepted.
Through these comprehensive initiatives, the VUB Bank reinforces its commitment to employee safety, resilience,
and well-being, ensuring a healthy and secure workplace for all.
Remediation processes with own workers and their representatives and channels to raise concerns
The management of material impacts on the VUB Group's employees in the area of occupational health and safety
is regulated by speciﬁc internal procedures. These outline the approach to management of identiﬁed deﬁciencies
through control activities and any corrective measures to be implemented.
These regulations also deﬁne the communication channels that are available to employees to receive information
and communicate with the relevant health and safety functions. This process is managed and is the responsibility of
the Security Ofﬁcer function.
In addition to reporting under the Code of Ethics and whistleblowing, a channel is available to all employees to
report risks and incidents through the Physical Security Ofﬁce, as well as through trade unions.
Activities for monitoring and assessing risks to the employees in the ﬁeld of occupational health and safety are in
addition deﬁned in Collective agreement, which also identiﬁes the different structures responsible for these
processes.
Targets related to health and safety
VUB Group has not set targets yet, as these are deﬁned, approved and monitored at the level of the parent company,
Intesa Sanpaolo, within the framework of the Group’s consolidated strategy and governance structure.
As a subsidiary, VUB Group aligns with these Group-level objectives, ensures their implementation in its operations,
and provides relevant performance data for the purpose of consolidated reporting. The applicable targets,
methodologies, and disclosures on progress are therefore included in the consolidated reporting published at the
Intesa Sanpaolo Group level, of which VUB group forms part.
Actions related to health and safety
In the area of occupational health and safety, VUB Bank has for many years implemented a wide range of initiatives
that go beyond statutory requirements and place a strong emphasis on prevention, early diagnosis and the support
of employees’ overall physical and mental well-being. One of the most signiﬁcant instruments is the International
Healthcare Programme, which was renewed again in 2025. The programme offers employees with permanent
employment contracts access to expert medical consultations in the form of a second medical opinion and, in the
case of serious diagnoses, access to treatment at international centres of excellence, including full coverage of
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treatment and related costs. The programme has also been expanded to include support in life-threatening illness
situations, under which the Bank provides 100% income replacement during temporary incapacity for work,
representing substantial support for employees during the most challenging periods of their lives.
An important element of health care provision is the regular organisation of Health Days, which take place several
times a year at VUB and focus on various aspects of prevention. Employees have the opportunity to undergo basic
health screenings, measure stress levels or beneﬁt from professional skin mole checks. Special attention is also given
to speciﬁc health topics
—
activities for women focus on breast cancer prevention, including education on self-
examination techniques and discussions on menopause. In 2025, the entire month of November was dedicated to
men's health, with a focus on testicular cancer prevention and related awareness-raising activities. Preventive support
also includes free inﬂuenza vaccination directly at the workplace, which was extended to include vaccination against
hepatitis A within the branch network, in response to increased incidence of the disease in certain regions.
As already mentioned, systematic care for mental health also plays a key role. VUB addresses this topic through the
comprehensive ‘Banka s dušou’ (Bank with a Soul) programme, which integrates preventive activities, education and
accessible forms of support. Each month, expert lectures and discussions are held in cooperation with the Employers'
Coalition for Mental Health, creating space for dialogue on topics that signiﬁcantly affect employees' lives and their
well-being at work. Within the certiﬁed Mental Health First Aid programme, more than 5% of employees have
already been trained to recognise signs of mental distress among colleagues and to guide them towards appropriate
forms of professional support. A crucial element ensuring the accessibility of support is the free 24/7 assistance
helpline, which employees can use anonymously at any time. In recognition of its activities in this area, VUB became
the ﬁrst bank in Slovakia to receive the prestigious Golden Souls Certiﬁcate awarded by the League for Mental
Health.
Employee health care is further complemented by additional beneﬁts. Through the Employee Discounts programme,
the Bank facilitates preferential prices for medical aids, examinations and services aimed at supporting physical and
mental ﬁtness. Another important measure is the possibility to use additional days off in cases of short-term illness,
allowing employees to recover without unnecessary stress and supporting faster regeneration of the workforce.
All of the above initiatives reﬂect the Bank‘s commitment to creating a working environment that supports not only
physical health but also psychological safety. This is an essential component of an inclusive corporate culture, which
the Bank actively promotes through the development of managers and team collaboration.
Metrics related to health and safety
By 31 December 2025, 100% of employees are covered by the Occupational Health and Safety Management System.
For the VUB Group, the system follows the Intesa Sanpaolo Group Rules, which have been adopted by VUB.
The following table presents the main indicators regarding work-related injuries and fatalities that occurred in the
VUB Group during the year.
2025
2024
Percentage of people in its own workforce who are covered by the health and safety
management system based on legal requirements and (or) recognised standards or
guidelines
100%
100%
Number of fatalities in own workforce as result of work-related injuries and work-related
ill health
0
0
Number of fatalities as result of work-related injuries and work-related ill health of other
workers working on undertaking's sites
0
0
Number of recordable work-related accidents for own workforce
8
6
2025
2024 *
Rate of recordable work-related accidents for own workforce
1,52
1,11
*For 2025, we used a more accurate calculation of worked hours based on actual hours worked, taking into account
vacation and paid leave. The year 2024 was recalculated using the updated, more accurate worked-hours calculation.
The original reported value in 2024 was 0.82.
The number of recordable injuries includes both the injuries that occurred to employees at work and those in transit,
based on the accident reports submitted.
The injury rate is calculated as the number of injuries in the year on the total hours worked, multiplied by a coefﬁcient
equal to 1,000,000.
VUB provides the Trade Union with an overview of all OHS relevant information (e.g. the number of work accidents,
the number of robberies, the number of deﬁciencies at workplaces, the number of deﬁciencies removed, the opex
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329
for protective personal work equipment, the opex for the elimination of deﬁciencies).
Work-life balance and working time
Policies related to work-life balance
In order to ensure a good balance between personal and professional life for its employees, the VUB Bank has
established rules and policies that also serve to manage impacts, risks, and opportunities related to this issue. These
are regulated through the Code of Ethics and the Working Hours Directive with the Smart Work Annex, both aligned
with national and international standards for respecting human rights related to work-life balance (e.g., the
Declaration on Fundamental Principles and Rights at Work).
The Code of Ethics, available on the company website for customers and external stakeholders, addresses the
principle of conduct ‘respect for people‘ and, among other objectives, aims to promote policies that facilitate the
balance between personal and professional life. It encourages ﬂexibility and implements initiatives to reconcile work
and private commitments, recognizing that this balance is fundamental to the well-being of each individual.
The Rules on Flexible Work, as part of the Working Hours Directive with the Smart Work Annex, are available on the
company intranet in the HR regulatory section of the #People portal. These rules summarize all current provisions
related to ﬂexible work and, together with the Code of Ethics, aim to facilitate employees' work-life balance. For
example, VUB Bank introduced ﬂexible work models, redesigned ofﬁce spaces, and piloted a ‘short week‘ with four
nine-hour days. Smart Working 2.0 introduced the possibility to use ﬂexible working arrangements also for
specialised roles within the branch network. The responsibility for implementing the aforementioned policies and
rules lies within the HR and Organisation Department Head and are made available to Bank’s employees through
the intranet.
Policies related to working time
The VUB Group is committed to fostering a work environment that supports both professional achievement and
personal well-being. The Bank recognizes that work-life balance is essential for maintaining motivation, productivity,
and long-term engagement. To this end, VUB has implemented a structured approach that combines ﬂexible
working arrangements, respect for employees’ personal time, and a comprehensive leave policy. VUB's approach to
work-life balance is supported by clear internal regulations that deﬁne working time arrangements and leave policies.
These guidelines are developed in alignment with legal requirements and best practices, ensuring transparency and
consistency in their application.
The management of working time in relation to employee well-being is governed by the Working Time Directive,
along with its annexes Occasional Work and Telework and Smart Work 2. These regulations outline the principles
of ﬂexible work arrangements and remote work opportunities, enabling employees to optimize their professional
and personal commitments. All related policies have been reviewed and approved in consultation with the Council
of Trade Union Representatives of VUB, a.s.. In addition to working time policies, the framework for employee
holiday and additional free days is regulated by the Beneﬁts Directive and the Collective Agreement. These
documents deﬁne the conditions under which employees can access various types of leave, ensuring a structured
and equitable approach to work-life balance across the organization.
All these directives, in compliance with the law, are consistently guided by the aim of avoiding any active or passive
discrimination against the people of the VUB Group. By establishing clear guidelines and engaging in continuous
dialogue with employee representatives, VUB reinforces its commitment to fostering a supportive and sustainable
work environment.
VUB embraces Smart Work as a modern approach to work organization, allowing employees to perform their duties
in a hybrid manner while maintaining efﬁciency and collaboration. This model is based on ﬂexibility, mutual trust,
and a results-oriented mindset, ensuring that employees can effectively manage their professional and personal
commitments.
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Key principles of Smart Work at VUB include:
Key principle of Smart Work at VUB
Description
Hybrid Work Opportunities
Employees can combine remote and in-office work to optimize productivity
and teamwork, up to 100% time of remote work upon approval for 12
months.
Flexible Working Hours
Work schedules can be adjusted within reasonable limits to accommodate
individual needs while ensuring business continuity.
Results-Oriented Approach
Performance is evaluated based on employees’ outcomes rather than time
spent at the workplace.
Right to Disconnect
Employees are not required to engage in work-related communication
outside of designated working hours, except in urgent situations.
Additionally, the VUB Bank offers employees the option of a four-day work week as an alternative to the traditional
ﬁve-day schedule. Employees at the headquarters and selected specialized roles in the retail network can ﬂexibly
choose on a weekly basis whether to work extended hours over four days (9.6 hours per day) or follow the standard
ﬁve-day week (7.75 hours per day). This arrangement provides an additional day off each week, allowing employees
to focus on personal activities and rest. Up to two-thirds of the workweeks in a year can be shortened.
The Bank also supports an extended working hours framework, where employees are required to complete their
7.75 hours of work per day but have the ﬂexibility to distribute these hours according to their agreement with their
manager, respecting ﬁx time between 9.00 and 15.00 o’clock, or opening hours in the network. This means
employees can work in blocks of time that suit their individual schedules, promoting greater autonomy and
efﬁciency.
Furthermore, the VUB Bank allows employees to work from anywhere within Slovakia. This ﬂexibility is particularly
beneﬁcial for those who may need to relocate temporarily or prefer to work from different locations for personal
reasons.
To further support employees’ well-being, VUB offers a structured leave framework that provides ﬂexibility for
personal and family-related matters. The Bank ensures compliance with applicable labour regulations while also
offering additional beneﬁts to promote work-life balance.
Types of leave available at VUB include:
Type of leave
Description
Annual Leave
Employees are entitled to a set number of paid vacation days, which can be scheduled flexibly.
Special Leave
Additional time off is available for parental responsibilities, family care, education, birthday
celebration and personal matters.
Sick Leave
Employees are supported during health-related absences in accordance with legal and
beneficial provisions; above that, the Bank offers up to 6 additional free ‘Sick Days‘ to support
physical and mental health.
Extra Free Days (paid and
unpaid)
In addition to official public holidays, VUB grants additional days of in line with the Slovak
legislation such as for purpose of wedding, funeral, reallocation etc.
Unpaid Leave and Sabbaticals
Employees have the option to take extended leave periods under specific conditions.
All leave policies are reviewed regularly to align with evolving business needs and legislative developments.
Employees have access to up-to-date information through the company intranet, HR portal, dedicated Sharepoint
site and supported by internal campaign to raise awareness of ﬂexibility, ensuring transparency and ease of planning.
VUB continually invests in initiatives that promote a healthy and supportive work environment. This includes well-
being programs focused on mental and physical health, professional development opportunities, and a workplace
culture that respects employees' personal time.
By integrating ﬂexible work arrangements with a comprehensive leave policy, VUB reafﬁrms its commitment to
creating a sustainable and employee-centred work environment.
Human rights policy commitments
All internal regulations of the VUB Group governing ﬂexible forms of work, smart working and access to employee
beneﬁts are implemented in full compliance with applicable human rights legislation and are designed to respect
diversity and the varied needs of employees, without any form of discrimination.
Engagement processes with own workers and their representatives
VUB’s industrial relations model adopted and developed by VUB, in agreement with the Council of Trade Union
Representatives of VUB, a.s. (ROZ) also provides the basis for bilateral discussions related to well-being topics. For
more details, see the section Employment protection and labour relations – Engagement processes with own workers
and their representatives.
Additionally, the Smart Work framework was developed as an employee-driven initiative, ensuring that the needs
and expectations of various employee groups were taken into account. The process began with a survey to
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understand employee expectations, followed by an in-depth analysis of the speciﬁc needs of different target groups,
such as parents, Generation Z, and senior employees. A dedicated working group, composed of employee
representatives, then collaborated to design the framework, laying the foundation for its effective implementation.
Remediation processes with own workers and their representatives and channels to raise concerns
For matters relating to working hours, VUB Group employees can ﬁrst contact their HR manager of reference as well
as use a speciﬁc assistance section within the HR portal to receive technical assistance on the application of the
relevant legislation. Additionally, employees have the option to independently use the various reporting channels
made available to employees, i.e. the so-called active listening systems, which include:
–
The formal report to their manager, to the Personnel Function or to the company ﬁgure of reference for personal
matters;
–
Whistleblowing, for further information please refer to the standard ESRS G1 – Business conduct, section
Policies, objectives and actions related to protection of whistleblowers; all employees receive initial training on
whistleblowing on their ﬁrst day of employment, thereafter, they are required to complete a mandatory e-
learning refresher course every two years;
–
The other procedures dedicated to reporting to the competent structures, including specialised ones, any non-
application or incorrect or discriminatory application of the legislation relating to the employment relationship
(including that relating to working hours) with reference to particular thematic areas such as: the Code of Ethics,
DE&I, sexual harassment, violations of the Employment regulation, etc.
The VUB Bank guarantees whistleblowers from any form of retaliation, discrimination or penalization and ensures
maximum conﬁdentiality, without prejudice to legal obligations.
The handling of complaints/reports by VUB Group’s employees is set out in the relevant company regulations,
including those dedicated to particular channels (see, for example, the Whistleblowing Policy) as well as in the
Group's Internal Code of Conduct. This Code speciﬁes the various ways in which employees can report violations,
non-applications or discriminatory applications of the legislation concerning the employment relationship, including
issues related to working time.
Targets related to work-life balance and working hours
VUB Group has not set targets yet, as these are deﬁned, approved and monitored at the level of the parent company,
Intesa Sanpaolo, within the framework of the Group’s consolidated strategy and governance structure.
As a subsidiary, VUB Group aligns with these Group-level objectives, ensures their implementation in its operations,
and provides relevant performance data for the purpose of consolidated reporting. The applicable targets,
methodologies, and disclosures on progress are therefore included in the consolidated reporting published at the
Intesa Sanpaolo Group level, of which VUB group forms part.
Actions related to work-life balance
The VUB Group supports work–life balance through measures that take into account the diversity of employees’ life
situations and individual needs. The aim is to create ﬂexible working conditions, support recovery and contribute to
the long-term satisfaction and performance of employees.
A core instrument is the Smart Work concept, which introduces ﬂexible forms of work, including the possibility of
reduced working arrangements. Employees may work in either a four-day or ﬁve-day working regime and can divide
their working day into several time blocks according to their needs. The shared core availability time is set between
9:00 a.m. and 3:00 p.m., enabling better alignment of work responsibilities with private life. Smart Work also allows
employees to work from anywhere within Slovakia, either in the form of occasional remote work (up to 10 days per
year) or telework (up to 80% of working time performed remotely). VUB also enables 100% home ofﬁce
arrangements, which are reviewed annually to ensure the employee's health and well-being.
The VUB Group actively promotes planning and regular use of leave. In addition to statutory annual leave, employees
have access to additional beneﬁt days off, such as days for health care, a day for oneself and family, a birthday day
off, or leave related to signiﬁcant life events. Administrative burden has also been reduced in cases of medical
appointments or accompanying a family member. Support for work
–
life balance is further reinforced through
targeted internal communication and expert lectures.
As a preventive measure against burnout, the VUB Group offers the option of a sabbatical, providing employees
with time for rest, recovery and personal development. Sabbatical leave may be taken after ﬁve years of service, for
a duration of one to three months.
An important role is also played by the Care Lab prevention programme, focused on supporting healthy nutrition,
physical activity, emotional well-being and family care. The programme offers practical tools and recommendations,
including access to applications such as #stepbystep or Petit BamBou, which promote mental well-being and healthy
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habits.
Employees may also draw inspiration from colleagues' experiences through the internal podcast
Ako sa mať dobre
(‘How to Feel Well’) or during internal wellbeing conferences, which provide a platform for sharing practical tips and
proven approaches.
To support the reconciliation of work and family responsibilities, the VUB Group organises a children's summer camp
for children up to the age of 13 during the summer months, helping employees arrange childcare during school
holidays.
Support for a healthy lifestyle is further strengthened through sports activities, exercise sessions, lectures and
discussions. Employees can beneﬁt from discounts on sports facilities and recreational activities through beneﬁt
programmes such as MultiSport and UpBalance.
Employee beneﬁts also include a recreation voucher, enabling employees to plan discounted stays focused on rest
and recovery.
Training and Development Supporting Employee Well-being
As part of its commitment to employee satisfaction, VUB Bank provides a range of training programmes aimed at
strengthening professional and personal resilience. A key initiative in this area was the ‘Resilience Skills’ training,
made available to all employees in the form of 30-minute morning kick-off sessions focused on enhancing
adaptability and stress management in the workplace, as well as a resilience programme for managers and teams
offered on demand.
Learning activities also focus on developing leadership competencies that support the principles of Smart Work. As
managers play a key role in overseeing employees’ working time, well-being and the creation of a productive work
environment, managerial training programmes included, in particular:
–
managing hybrid teams to ensure efﬁciency and engagement in ﬂexible working conditions;
–
creating a psychologically safe environment that enables open communication and trust within teams;
–
delegation and empowerment, encouraging employees to take responsibility for their work and fostering a
culture of accountability;
–
building autonomous teams and improving collaboration and decision-making at all levels.
Smart Work and work
–
life balance are closely linked to the effective use of digital technologies. VUB therefore
implements a comprehensive programme focused on developing digital skills and the use of AI technologies,
ensuring that employees can fully leverage modern tools for remote collaboration, efﬁciency and communication.
All of these well-being-related initiatives are aimed at creating positive impacts that ultimately lead to a signiﬁcant
improvement in employees work
–
life balance.
Privacy of the VUB Group’s people
Policies related to privacy of VUB Group’s people
VUB has always maintained a high and constant commitment to the protection of employees' and collaborators'
personal data, ensuring the collection and processing of data in full compliance with current legislative provisions.
The regulatory framework for the protection of personal data is Regulation (EU) 2016/679 (GDPR) which came into
force on 25 May 2018, the new precepts of which have been assimilated by the Bank and formalised in the main
internal governance documents consisting of the Group's Code of Ethics and the Group Internal Code of Conduct
which deﬁne the conduct that the VUB Group's employees and collaborators are required to observe in order to
ensure the correct data processing.
In addition, VUB also requires its suppliers to comply with the policies, regulations and standards relating to the
protection of personal data, deﬁning their subjective role in the processing activities, assessing the existence of the
necessary guarantees, formalising the contractual conditions, and carrying out compliance and adequacy
assessments. In particular, the GDPR has introduced the so-called principle of accountability which requires the
owner of personal data to put in place regulatory, organizational and technological interventions to ensure that the
processing of personal data takes place in accordance with and in the light of the criteria deﬁned in the Regulation
itself such as: privacy by design, privacy by default, appointment of the Data Protection Ofﬁcer (‘DPO’), privacy
impact assessment, register of processing activities, subjective role of Third Parties and management of data
breaches.
VUB also complies with local regulations in accordance with the provisions expressly provided for by them regarding
the protection of personal data. VUB has issued speciﬁc Governance documents that give precise instructions on the
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333
conduct that employees and collaborators must adopt to ensure the correct collection, use and protection of
personal data, in compliance with current national and international legislation and the principles that guide personal
data processing in the VUB Group. These requirements are set out in the Data Processing Policy of VUB.
The Policy deﬁnes the model for managing the risk of non-compliance with regard to the protection of the personal
data of all natural persons with whom VUB interacts, outlining the general principles and setting out the roles and
responsibilities of the corporate bodies and structures involved, the macro-processes of risk oversight and control,
as well as the policy and coordination model of the VUB Group. It is promulgated in full compliance with external
legislation, internal governance documents and in compliance with the provisions of the European Data Protection
Board (EDPB), made up of representatives of the national supervisory authorities on the protection of personal data
of the various European countries. It applies both to VUB and its subsidiaries. As a rule, it is reviewed on an annual
basis and, before being approved by the Management Board, is subjected to a concordance process involving various
company functions.
Pursuant to Article 37 of the GDPR, the Management Board also appoints the Data Protection Ofﬁcer who, in
carrying out his activities, is supported by the IT Security Ofﬁcer (the Privacy Function in VUB is covered by DPO and
IT Security Ofﬁcer).
The Data Protection Ofﬁcer, supported by IT Security Ofﬁcer, is entrusted with the following tasks:
–
Monitoring compliance with the GDPR;
–
Prior veriﬁcation of the compliance of new products, initiatives and services involving the processing of personal
data;
–
Risk assessment for the rights and freedoms of individuals when starting or changing any processing of personal
data (Privacy Impact Assessment), in accordance with Article 35 of the GDPR;
–
Evaluation of the subjective privacy role played by the Suppliers/Third Parties and drafting of the appointment
letter;
–
Management of customer requests regarding the exercise of the rights of data subjects;
–
Management of feedback to the Data Protection Authority and data subjects following reports or complaints
submitted to the Authority itself;
–
Role of guidance, coordination and control over the companies belonging to VUB Group;
–
Keeping and updating the Records of Processing Activities, as required by Article 30 of the GDPR, in which all
the personal data processing activities carried out are tracked. It indicates the purposes of each processing, the
method of data storage, the security measures applied and other information on the processing activities carried
out;
–
Assessment of non-compliance events and data breaches;
–
Updating the list of third parties that process personal data of employees;
–
Supervision of training courses on Privacy.
Data Processing Policy of VUB also details the topics and provisions relating to the activities carried out by all parties
authorised to process data, providing precise operating instructions to comply with the provisions of the GDPR. The
Policy applies to VUB and according to the guidance, coordination and control model VUB shall ensure that all its
subsidiaries implement the ISP Guidelines on the Protection of Personal Data of Natural Persons and provides
guidance on their coordination.
The internal regulatory documents, including the VUB Data Processing Policy, are published in a special internal VUB
portal to which all employees and collaborators have access.
Engagement processes with own workers and their representatives
The adoption and governance mechanisms deﬁned in the Code of Ethics are aimed at integrating company
strategies, policies and procedures with ethical principles and values through the maximum sharing and
dissemination of the contents of the Code itself, monitoring knowledge and awareness. As a rule, the involvement
of workers takes place indirectly and is guaranteed through trade union representations and regulated by sector
provisions and the protocol of Industrial relations.
In the area of privacy, employees are involved directly when the employment relationship is established, through the
provision of the privacy policy by HR and Organisation Department and made available on the VUB website and VUB
internal portal. As required by the legislation and the VUB Data Processing Policy, the information is drawn up in a
concise, transparent, intelligible, easily accessible form and in simple and clear language to communicate to the data
subjects the information necessary to ensure correct and transparent processing. If it is updated, the information is
made available on the VUB website as well as in VUB internal portal in its new version and the data subject is asked
to read it. All documents that fall within the scope of privacy protection are available on the VUB internal portal and
can be consulted by all VUB Group employees at any time.
The effectiveness of the involvement of its employees is also assessed through the provision of compulsory training
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courses administered in e-learning mode on data protection issues to allow staff to learn the regulations in practice
and continuously update. At the end of the courses, a ﬁnal test is scheduled and the Bank monitors both the
completion rates and passing percentages.
Remediation processes with own workers and their representatives and channels to raise concerns
The VUB Group has adopted a model for the management of critical events that precisely deﬁnes the activities aimed
at efﬁcient incident management, providing for the involvement of different functions depending on the nature of
the speciﬁc case. In this scenario, the Data Protection Ofﬁcer manages non-compliance events by providing assistance
and collaboration to ensure that actions are identiﬁed and implemented to eliminate or mitigate the effects of the
event. If the event constitutes a data breach, the Data Protection Ofﬁcer is called upon to assess the impacts in terms
of concrete risk to the rights and freedoms of natural persons: if the risk is high, he notiﬁes the Authority and, in
the event of a particularly high risk, also notiﬁes the data subjects.
VUB adopted speciﬁc Governance documents that give precise instructions on the conduct that employees and
collaborators must adopt to ensure the correct collection, use and protection of personal data, in compliance with
current national and international legislation and the principles that guide VUB Group, formalized in the Code of
Ethics and in the Group's Internal Code of Conduct.
In 2024, VUB Data Processing Policy was updated, which outlines the model for managing the risk of non-compliance
in the ﬁeld of personal data protection by establishing the general principles and setting out the roles and
responsibilities of the corporate bodies and structures involved.
Failure to comply with external or internal legislation relating to the protection of privacy by an authorised person
will result in the activation of a process aimed at verifying the actual unlawful conduct. In the event of ascertained
and unjustiﬁed violations, the departments in charge are always informed for the initiation of disciplinary proceedings
which normally ends with the imposition of one of the measures provided for by the Disciplinary Code against the
defaulting party.
In the event of reports relating to privacy issues or requests to exercise rights, data subjects may contact the Data
Protection Ofﬁcer, with the contact details both in the information provided to all data subjects and on the VUB
website.
Requests can be transmitted electronically (email, certiﬁed email, or through a special form available on the website
that transmits the request directly to the Privacy function) or on paper; in both cases, an adequate level of
conﬁdentiality and protection of data of data subjects involved is guaranteed. The monitoring of the receipt of
requests is the responsibility of the Privacy function, which manages the reports and requests received and ensures
their timely processing according to the terms provided for by the legislation.
As part of the integrated system of internal controls, the Control Functions carry out checks with different depths
and periodicities, relating to the compliance of the activities with the regulatory requirements on the protection of
personal data and the correct fulﬁlment of the measures issued by the Data Protection Authority on these issues.
The results are reported to the Management Board.
In this context, the Chief Audit Ofﬁcer carries out periodic audit activities deﬁned, as well as on the basis of speciﬁc
regulatory obligations on the subject, from a risk-based perspective, also taking into account the evidence reported
by the other corporate control functions.
In general terms, the independent Internal Audit checks are aimed at ascertaining the completeness, adequacy and
functionality of the data protection risk management model, reporting any irregularities relating to the processing
of personal data to the responsible corporate structures, to the Data Protection Ofﬁcer and reporting them to the
Management Board. The Data Protection Ofﬁcer, in compliance with the GDPR and the VUB Data Processing Policy,
is responsible for preparing a report, at least annually, to report to the Management Board on data protection issues
of particular importance. This commitment allows, through the adoption of appropriate measures, the mitigation of
reputational and non-compliance risks in the context of the processing of personal data also with reference to the
lawfulness and correctness of the processing, the purposes of the processing and the relevance, completeness and
compliance with the principle of data minimisation of the data collected.
Targets related to privacy of VUB Group's people
VUB Group has not set targets yet, as these are deﬁned, approved and monitored at the level of the parent company,
Intesa Sanpaolo, within the framework of the Group’s consolidated strategy and governance structure.
As a subsidiary, VUB Group aligns with these Group-level objectives, ensures their implementation in its operations,
and provides relevant performance data for the purpose of consolidated reporting. The applicable targets,
methodologies, and disclosures on progress are therefore included in the consolidated reporting published at the
Intesa Sanpaolo Group level, of which VUB group forms part.
ESRS S1 – Own Workforce
335
Actions related to privacy of VUB Group’s people
Privacy supervision is ensured by the Data Protection Ofﬁcer, identiﬁed according to the criteria of Article 37 of the
GDPR and appointed by the Management Board and by the IT Security Ofﬁcer.
The Data Protection Ofﬁcer monitors, according to a risk-based approach, the risk of non-compliance by ensuring
the application of the principles of Privacy by Design, i.e. data protection already in the initial stage of the project,
and Privacy by Default, i.e. standard data protection, to ensure that the risk of non-compliance with privacy
legislation is monitored both in the design or substantial modiﬁcation phases of the processing of personal data,
and during processing by adopting, by default, the appropriate technical and organisational measures to ensure an
adequate level of security.
In 2025, awareness-raising activities aimed at Group's employees and relating to data protection issues continued.
This awareness takes place through the provision of compulsory training courses in e-learning mode that include a
ﬁnal test and the provision of new modules to allow staff to learn the legislation in practice and continuously update.
VUB and its subsidiaries monitor both the completion rates and passing percentages.
In addition to mandatory e-learning training, the Privacy Function provides training and education in data protection
area to employees of individual departments and through the projects on which the Privacy Function works. This
education is applied in practice in such a way that after writing a statement on individual cases or answering
questions regarding data protection, the issue is explained. It always reﬂects on the understanding of the employees
to whom the issue is explained and ensures that they understand the topic. For this purpose, if necessary, the
principles of the GDPR in accordance with Art. 5, the legal bases in accordance with Art. 6 of the GDPR, the
provisions relating to the e-privacy directive in the case of marketing processing issues, or other information related
to the given project / statement are explained.
This ongoing training is repeated, and the results can be gradually seen. In the case of projects or questions to the
Privacy function where the issue is similar or the same, the responsible employees have basic knowledge in the ﬁeld
of data protection and use the knowledge gained from previous communication.
336
ESRS S3 – Affected Communities
Interests and views of stakeholders
In 2025, we conducted a survey aimed at assessing the signiﬁcance of impact among organisations supported by
grants within the programmes of the VUB Foundation, with the objective of obtaining relevant feedback. At the
same time, we collected unstructured qualitative feedback through sectoral meetings, conferences, individual
consultations with organisations, as well as through our engagement in professional associations.
Materiality process on impacts, risks and opportunities and their interaction with strategy and
business model
The methods for identifying material topics for the VUB Group is described in detail in the chapter ESRS 2 – General
Disclosures – Double Materiality Assessment. The impacts, risks and opportunities within the ESRS S3 – Affected
Communities are identiﬁed by taking into account the speciﬁcities of the VUB Group. In particular, the mapping of
such impacts, risks and opportunities was carried out on the basis of an analysis of the initiatives implemented by
the VUB Group to support, protect and enhance the Community of the territory in which it resides and operates, as
well an analysis of the programs and controls put in place in order to minimize the negative impacts connected to
the topic in question, with reference to its own operations and to the upstream and downstream value chain, in
addition to an assessment of the risks linked to the aspects of the Community of the territory to which the VUB
Group could be exposed.
VUB Group identiﬁes affected communities as companies and individuals impacted by its operations, including
customers and stakeholders beneﬁting from or inﬂuenced by its activities. The VUB Foundation further supports
communities through targeted ﬁnancial aid for social, environmental, and cultural initiatives.
For the purposes of impact materiality, the assessment of the identiﬁed impacts was conducted through interviews
with internal structures and external stakeholders, as well as through a detailed qualitative-quantitative analysis,
carried out on the basis of the criteria required by the reference legislation (i.e. scale, scope, irremediable nature of
the impact and probability). In particular, with reference to:
Value Chain
Scope & Assessment Method
Identified Impacts
Own Operations
Qualitative drivers linked to initiatives
supporting communities via
protection/enhancement of their
territory
Material
Support for communities through the development of locally
supported infrastructure and services (housing support, initiatives
to promote access to food resources and hygiene/health
conditions, economic and educational development and increased
security of the territories)
Upstream Value Chain
Analysis of VUB Group's business
context and supplier categories
-
Downstream Value Chain
Analysis of indirect impacts via VUB
Group's portfolio exposures to
sectors affecting community impact
-
For the purposes of determining ﬁnancial materiality, the relevance of risks and opportunities was assessed using a
dual approach, quantitative and qualitative, applied to the identiﬁed perimeters.
With reference to risks, the following analyses were conducted for the various reference perimeters identiﬁed with
regard to:
Value Chain
Scope & Assessment Method
Identified Risks
Own Operations
An in-depth analysis via a survey
and qualitative dialogue
Material
Increased stakeholder trust resulting from the definition of targets on
economic, social and cultural rights of communities
Upstream Value Chain
-
Downstream Value
Chain
-
VUB Group focuses on supporting Slovak non
‑
governmental and non
‑
proﬁt organizations, schools and leisure
‑
time
centres, as well as local municipalities, towns, and other public institutions. The Group's attention to the interests of
communities is reﬂected in the importance attributed to the social needs of the community within the VUB Group
strategy and the Intesa Sanpaolo Group 2022-2025 Business Plan. In this regard, the VUB Group has deﬁned
objectives to support communities, to address their social needs, combat inequalities and promote their social,
ESRS S3 – Affected Communities
337
educational and cultural inclusion. The essential rights of every citizen, such as the availability of food and housing,
access to care and medicines, and educational opportunities, including ﬁnancial ones, are supported by the Intesa
Sanpaolo and VUB Group through an extensive policy of investments in the community. The territorial initiatives
have the dual objective of generating a positive impact, responding to the needs of stakeholders, and pursuing
signiﬁcant opportunities with a view to positioning themselves among the leading companies in terms of social
impact, also through collaborations with Third Sector entities.
These initiatives, particularly those supporting vulnerable groups, have a meaningful impact across short, medium,
and long-term horizons. VUB continuously assesses community needs to ensure its support effectively contributes to
social well-being, reinforcing its commitment to ethical and responsible business practices.
No changes to material impacts, risks or opportunities have been identiﬁed in 2025, compared to 2024.
Communities affected by own operations
Policies related to communities affected by own operations
The VUB Foundation is a non-governmental organization focused on support within its strategic areas, one of which
is the promotion of social objectives and initiatives in line with the values of the Intesa Sanpaolo Charitable Fund. It
operates independently from VUB Bank’s business activities, it receives funding primarily through the state’s 2% tax
allocation mechanism. In addition, the Bank contributes to the Foundation’s initiatives by providing creative, design,
and marketing services through subcontracted agencies, helping to promote its projects and increase their impact.
The Equator Principles (EP) are international guidelines to which the Intesa Sanpaolo and VUB Groups have voluntarily
adhered since 2007, applicable to the ﬁnancing of infrastructure and industrial projects that could have negative
impacts on the environment and people. These pay particular attention to the consultation of local communities,
the protection of the rights of indigenous peoples and the preservation of local cultural heritage.
These principles are based on the Performance Standards (PS) on environmental and social sustainability of the
International Finance Corporation of the World Bank, and on its guidelines dedicated to Environment, Health and
Safety (EHS Guidelines).
The Equator Principles Guidelines apply to ﬁnancial products
16
supporting the development of new projects issued
by the VUB Group and are valid in all countries in which the Group operates and for all countries in which the Group
carries out ﬁnancing activities.
The function responsible for the implementation of the Equator Principles, responsible for reviewing and monitoring
their application, is the structure that is organisationally located within Chief Risk Ofﬁcer Area.
In addition to what is established by the Equator Principles, the Group also regulates these issues through internal
policies such as Group Guidelines for the Governance of environmental, social and governance (ESG) risks and the
Rules on ESG & Reputational risk clearing process. For further details on the Guidelines and the process mentioned
above, please refer to the E1 standard – Climate Change.
The application of the Equator Principles includes assessing social risks, ensuring respect for the rights of local
communities and indigenous peoples in the context of funded projects. The VUB Bank, in assessing the projects,
assigns a risk assessment that takes into account the impacts on human rights and the potential critical issues related
to the aspects considered by the IFC's Performance Standards (so-called sensitive issues) that speciﬁcally refer to
respect for indigenous communities. Based on the risk assigned, in addition to providing the necessary
documentation, the client is required to involve the community, indigenous peoples, workers and stakeholders
through a continuous, structured and culturally appropriate process. In addition, the client is required to report
assessments of the potential negative impacts and human rights risks identiﬁed, in accordance with the United
Nations Guiding Principles. For projects affecting indigenous peoples, VUB's application of the Equator Principles
requires that the client's engagement process ensures the project's development fully respects their human rights,
dignity, aspirations, culture and livelihoods based on the natural resources. In addition, if mitigation and
compensation measures are implemented, they will have to take into account the laws, institutions and customs of
these communities.
The VUB Group not only provides ﬁnancial support to community initiatives but also actively engages its employees
in various projects, including volunteering, expert volunteering, donations, and collections, strengthening its
commitment to social responsibility.
16
The EPs apply, regardless of the industrial sector in which the customer operates, to the financial products listed below when they are used to
support the development of new projects and meet specific criteria: Project Finance Advisory Services, Project Finance, Loans to businesses linked
to projects (Project-Related Corporate Loans), Bridge Loans, Refinancing and Acquisition operations linked to Projects.
ESRS S3 – Affected Communities
338
The VUB Group, through its VUB Foundation, undertakes not only to comply with the relevant laws and legal norms
of the Slovak Republic but also to go beyond the law and follow the principles that give an ethical dimension to its
activities and outcomes.
The VUB Group selected three areas for the VUB Foundation to dedicate the ﬁnancial and human resources
effectively and achieve signiﬁcant impact:
–
Art and preservation of cultural heritage;
–
Environment;
–
Classical charity and philanthropy.
VUB Group’s commitment to community rights
The VUB Group recognises its commitment to human rights through the Code of Ethics, which is also inspired by
the main national and international guidelines on corporate social responsibility, including: the UN Universal
Declaration of Human Rights; the Declaration on Fundamental Principles and Rights at Work (ILO) and other
fundamental labour conventions, in particular the right of association and collective bargaining, the prohibition of
forced and child labour, non-discrimination in employment; the Organisation for Economic Co-operation and
Development (OECD) Guidelines for Multinational Enterprises and the anti-corruption principles established by the
United Nations. This commitment is formally outlined in the Code of Ethics.
The VUB Group plays an active role primarily in Slovakia, with the Code of Ethics serving as a regulatory reference
point for its relationship with local communities. The Code deﬁnes principles for addressing key impacts and
opportunities, such as adequate housing, nutrition, and territorial development. It guides the activities of the VUB
Group in promoting social cohesion, inclusion of disadvantaged groups, and protection of cultural and artistic
heritage. Additionally, it deﬁnes commitments to third-sector organizations through partnerships that support social
enterprises, solidarity, and economic support for local communities.
The principles apply to all initiatives dedicated to communities, youth, and vulnerable groups, as well as collaboration
with voluntary associations, foundations, and non-proﬁt entities.
Further information on the application of the Code of Ethics and its alignment with main existing national and
international corporate social responsibility guidelines can be found in the standard ESRS G1 – Business conduct,
section Policies related to corporate culture.
The Group also collects reports on all cases of non-compliance related to communities. In the reported year, no cases
concerning the relevant communities were recorded. Additionally, no serious incidents in the area of human rights
occurred.
VUB bases its relationship with the community on the principles of listening and dialogue with the various areas of
civil society, in fact the Company encourages constant dialogue with community representative organisations,
recognising their strategic importance for developing its activities in a sustainable way. For this reason, it undertakes
to:
–
Maintain a constant channel of communication with organizations representing the interests of stakeholders
and promote a structured dialogue with the aim of cooperating in respect of mutual interests;
–
Listen to and take into account the expectations and propositions expressed by the different components of civil
society;
–
Analyse needs and identify areas of intervention with a high social, cultural and civil impact for communities;
–
Deﬁne actions consistent with the listening and dialogue activities developed.
With speciﬁc reference to the support of initiatives with social value, the VUB Group is engaged in charitable activities
and charitable donations, which are based on the careful selection of beneﬁciary entities and contributions to the
community, in particular regarding respect for human rights.
In line with its human rights commitments, the Group monitors compliance with OECD international guidelines and
the principles enshrined in the ILO's core conventions, committing itself to protecting human rights in accordance
with the principles of the Universal Declaration. The Group also collects reports on any episodes of non-compliance
involving communities. No cases involving the communities concerned were detected in the reporting year.
Furthermore, there have been no serious human rights incidents in this area.
Engagement processes with affected communities
The VUB Group carefully considers the opinions of the affected communities, supporting structured and continuous
dialogue and discussion with stakeholders and community representatives, including entities of the civil economy
operating in reference areas. All this is aimed at identifying areas of intervention and initiatives with high social,
cultural, and civic impact, combating inequalities, and supporting young people and employability.
ESRS S3 – Affected Communities
339
The Group's engagement with communities is carried out both indirectly through membership in dedicated
professional associations, and directly through meetings, event organization, and through the activation of
collaborations, partnerships, listening campaigns, and information exchange with local stakeholders. Additionally,
the VUB Foundation serves as the primary vehicle for the Group’s initiatives in these areas. The meetings and
interactions do not have a set periodicity and are conducted continuously and on a need to basis.
The implementation of initiatives takes place in cooperation with third sector entities. Supported NGOs are required
to submit a report detailing the project's implementation, including achieved qualitative and quantitative goals,
along with a ﬁnancial report documenting expenditures. Selected projects undergo additional monitoring through
site visits to ensure alignment with agreed objectives.
The VUB Group and its parent company, Intesa Sanpaolo, ensure that affected communities and other stakeholders
have access to conﬁdential and secure channels to report concerns related to potential violations of the Code of
Ethics.
Reports
can
be
submitted
via
dedicated
email
addresses
(etickykodex@vub.sk
or
codice.etico@intesasanpaolo.com), with a guarantee of conﬁdentiality and protection against retaliation.
At the local level, reports are handled by the Internal Communication & CSR Ofﬁce, while at the Group level, the
ESG Steering structure oversees the process. The Chief Audit Ofﬁcer ensures the effective functioning of the
reporting system. These mechanisms allow stakeholders, including employees, suppliers, and community members,
to raise concerns, which are then assessed and addressed through established procedures.
The VUB Group ensures transparency by publishing information on the reporting channels on its corporate website
and intranet portal. Safeguards are in place to protect whistleblowers from retaliation or discrimination. Each report
is veriﬁed by the relevant structures, ensuring that concerns are addressed appropriately.
The Group protects anyone reporting cases of non-compliance in good faith from any form of retaliation,
discrimination or penalisation, and ensures maximum conﬁdentiality, except in cases otherwise indicated by law.
The Group promotes continuous listening and dialogue with its stakeholders, including communities, to ensure their
expectations are understood and integrated into responsible decision
‑
making.
Within the portfolio of the VUB Group the Bank receives speciﬁc documentation to support the performance of
these engagement activities and monitors the correctness of the customer's actions with respect to the obligations
connected to the application of the Equator Principles. If the communities impacted by the ﬁnanced project need to
report serious problems or negative impacts on them, the Bank interfaces directly with its customer to verify that the
implementation and effectiveness of the necessary remedial measures is ensured.
VUB Group is committed to monitoring, analysing and appropriately addressing the reports that arrive through
sharing reports or direct communications from non-governmental organizations or other entities acting as
representatives of the communities concerned.
For further information on the Code of Ethics reporting channel, please refer to the standard ESRS G1 – Business
conduct, Policies, objectives and actions relating to corporate culture.
Targets related to communities affected by own operations
The VUB Group focuses on qualitative rather than quantitative targets. Qualitative targets allow us to effectively
direct assistance to where it is currently needed, without the limitations that strict quantitative targets might impose.
The VUB Group's support for territories and communities occurs through multiple methods, in terms of tools and
initiatives.
In its 2025 strategy, the VUB Group aimed to strengthen support in all the pillar of Hope, focusing on charity and
social assistance. As a result, a signiﬁcant portion of the resources – 51% – as directed toward charitable initiatives,
ensuring greater impact in assisting those in need.
Actions related to communities affected by own operations
Social impact on the community
The VUB Group, in collaboration with Third Sector Entities, promotes the well-being of communities through
initiatives aimed at generating a positive impact. The purpose of the collaboration between the VUB Bank and the
VUB Foundation, and non-proﬁt organizations is to promote the well-being of communities and social inclusion and
cohesion through initiatives aimed at generating a positive impact. The Bank and the Foundation thus demonstrate
its commitment to inclusiveness, supporting projects that aim to combat poverty in its various dimensions, reduce
inequalities and encourage youth employability and in general to promote sustainable and inclusive development.
In this way, it offers concrete support to the communities involved, while helping to strengthen the Group's
reputation.
ESRS S3 – Affected Communities
340
The VUB Foundation is the key tool of the VUB Group for support of the affected communities.
Volunteer Days
VUB employees also contribute to various communities through the annual Volunteer Days initiative. In May 2025,
212 employees participated in volunteer activities across four Slovak cities, covering 16 different locations. Their
efforts included:
–
Cleaning national parks and protected areas;
–
Maintaining hiking trails and rivers;
–
Assistance work in a rehabilitation and family center;
–
Supporting community gardens and vineyards.
Financial literacy and educational volunteering
VUB expert volunteers actively support ﬁnancial literacy projects, educating primary and secondary school students
in a ﬁeld that is insufﬁciently covered by the national education system.
Key educational activities of 2025 in collaboration with Museo di Risparmio, Turin, Italy:
–
Cybersecurity Lab: Internet and Payment Security Lectures: Focused on educating primary school students;
–
Money Master Challenge: A ﬁnancial quiz conducted in two series;
–
S.A.V.E. Ambassadors: Promoted circular economy education for high school students.
These projects reached a total of 4,323 students, with the support of 95 VUB Bank colleagues acting as educators
and mentors.
Charity allowance
VUB Group, through its Foundation, provided ﬁnancial support to various charitable initiatives in 2025, with a
particular focus on social assistance, education, and healthcare.
Commitment to culture
The VUB Group and the VUB Foundation are committed to promoting initiatives that enhance access to art and
culture, recognizing the value that these elements bring not only to the individual, but to society as a whole. Through
active collaboration with cultural bodies and institutions, the company aims to enrich the social context and promote
the well-being of the community of reference, creating opportunities for dialogue, learning and collective growth.
The effectiveness of the actions undertaken is assessed through ongoing dialogue with the communities and
stakeholders involved. The supported actions not only speciﬁcally respond to the needs of the communities in the
respective areas but also represent an opportunity to enhance the reputation of the VUB Group.
As quantitative information on the actions towards communities impacted by the companies in the portfolio is not
yet available or can be found, the VUB Group has not set speciﬁc objectives in this regard. However, monitoring the
effectiveness of the actions undertaken is strictly connected with the application of the Equator Principles according
to the methods described above.
341
ESRS S4 – Consumers and end-users
Interests and views of stakeholders
The VUB Group integrates the interests, views and human rights of its consumers and end
‑
users into its strategy and
business model through continuous dialogue, robust data
‑
protection and consumer
‑
protection measures, and
systematic assessment of risks, opportunities and customer feedback.
Materiality process on impacts, risks and opportunities and their interaction with strategy and
business model
The methods for identifying material topics for the VUB Group is described in detail in the chapter ESRS 2 – General
Disclosures – Double Materiality Assessment. The impacts, risks and opportunities in the ESRS S4 – Consumers and
end-users are identiﬁed by taking into account the speciﬁcities of the VUB Group. In particular, the mapping of such
impacts, risks and opportunities was carried out on the basis of an analysis of the internal protection measures,
policies and measures aimed at safeguarding/protecting and guaranteeing the conﬁdentiality of customer data, also
in order to minimize the negative impacts associated with the topic in question. This analysis was carried out with
reference to its own operations and to the upstream and downstream value chain, as well as including an assessment
of the risks and opportunities related to the aspects of consumers and end-users to which the VUB Group could be
exposed.
As part of the double materiality analysis, the VUB Group has taken into consideration all categories of consumers
and end-users, who suffer or could suffer signiﬁcant impacts from the VUB Group itself and its products.
Consumers and end-users, who may be impacted in various ways, include institutional, corporate and retail
customers, including private individuals.
The assessment of the identiﬁed impacts was conducted through interviews with dedicated internal structures and
external stakeholders (i.e. surveys, questionnaires conducted with retail clients – Green Manifest and corporate
clients – dedicated online ESG Questionnaire), as well as through a detailed qualitative-quantitative analysis, carried
out on the basis of the criteria required by the reference legislation (i.e. scale, scope, irremediable nature of the
impact and probability). In particular, with reference to:
Value Chain
Scope & Assessment Method
Identified Impacts
Own Operations
qualitative drivers, including
internal protection policies
aimed at data confidentiality,
and safeguarding customers'
health and physical safety.
Material
Contribution to the protection and safeguarding of customers through suitable
safeguards (cybersecurity and health and safety measures, effective channels for
involving and managing complaints, protection from possible bank robberies)
Contribution to corporate integrity by ensuring the security of the Bank's IT and
network systems for the benefit of customers through the implementation of
cybersecurity policies and safeguards
Upstream Value
Chain
in-depth analyses with
dedicated structures
-
Downstream Value
Chain
Considered consumer
protection and safeguarding in
product/service offerings (e.g.,
website accessibility, fair
treatment, ethical business
practices), and
investment/financing criteria.
Material
Protecting customer rights through easy and transparent access to clear and
complete information
Increased access to products and services also thanks to digital innovation,
financial education and the definition of an offer to support the productive and
economic fabric, in compliance with fair, inclusive treatment of all social
categories and non-discriminatory treatment of customer
Increased ease of access to quality and non-misleading information, including
through ethical and transparent business practices
Contribution to the protection and safeguarding of customers through suitable
safeguards
ESRS S4 – Consumers and end-users
342
Changes to materiality of impacts in 2025
Changed to:
Sub/sub-sub
topic
Value chain
Description
Reasoning
New Material
Impact
Privacy
own operation
Contribution to corporate integrity by
ensuring the security of the Bank's IT
and network systems for the benefit
of customers through the
implementation of cybersecurity
policies and safeguards
Magnitude of the Risk increased for 2025,
which made an identified risk material.
For the purpose of determining ﬁnancial materiality, the relevance of risks and opportunities was assessed through
a dual approach (quantitative and qualitative), in line with the standard perimeter-based methodology outlined
above. The analysis determined that in the own operations, the operational risk related to privacy is signiﬁcant.
Consequently, a potential reputational risk stemming from this operational risk could have a material impact on the
VUB Group's image over short- and medium-term time horizons.
Value Chain
Identified Risks
Own Operations
Material
Operational Risk from potential impacts related to information for consumers and end users
Reputational risk from the limitation of access to clear and non-misleading information regarding the
product/service offered, from the potential violation of privacy and from the limitation of the freedom of
expression of customers and/or final consumers
There were no changes to materiality of risk or opportunities in 2025 when compared to 2024 reporting period. The
double materiality assessment did not reveal any mapped opportunities as material.
The VUB Group is committed to protecting customers' personal data in full compliance with legislation. A critical
event management model mitigates reputational risks related to data processing, ensuring lawfulness, accuracy, and
transparency. The Group values customer feedback, including complaints, to improve products and services. In this
process, by allocating adequate capacity to evaluate each single input, the VUB Group is able identify characteristics,
context and activities that may increase the risk of harm to certain consumers, ensuring that its offerings remain
safe, accessible and respond to their needs.
The Group's commitment to human rights
The VUB Group is committed to upholding human rights across all products and services, ensuring fairness,
transparency, and respect in its relationships with customers. These commitments align with the UN Guiding
Principles on Business and Human Rights, OECD Guidelines for Multinational Enterprises, and the ILO (International
Labour Organization) Declaration on Fundamental Principles and Rights at Work, as embedded in the Code of Ethics,
corporate regulations, and the Group’s strategic framework.
To support these principles, the Group ensures the following:
–
Ongoing dialogue with customers, consumer associations, and representative bodies to understand expectations
and enhance ﬁnancial inclusion;
–
Protection of privacy and personal data, applying privacy by design principles, assessing risks, and ensuring
compliance with national and international regulations;
–
Non-discrimination, ensuring equal access to ﬁnancial services regardless of gender, age, ethnicity, religion,
political afﬁliation, or other personal characteristics;
–
Security and data protection, implementing safeguards to ensure reliability, conﬁdentiality, and business
continuity;
–
Timely response to queries and complaints, strengthening customer trust and service quality.
The Group also requires stakeholders to comply with its data protection policies and integrates human rights
principles into its governance and business practices. Through these commitments, the VUB Group fosters ethical
business conduct, minimizes risks, and strengthens long-term stakeholder trust.
The Group monitors compliance with the OECD Guidelines for Multinational Enterprises and ILO fundamental
conventions, ensuring alignment with Slovak regulations and international human rights standards. It is committed
to identifying, mitigating, and preventing human rights violations, guided by the Universal Declaration of Human
Rights.
To ensure accountability, the Group has established reporting mechanisms for non-compliance. In the reporting
year, no cases involving customers were detected, and no serious human rights violations occurred. These
commitments are embedded in the VUB Code of Ethics, reinforcing fairness, transparency, and non-discrimination.
ESRS S4 – Consumers and end-users
343
A compliance framework is in place to address privacy, security, and ethical concerns, ensuring transparency and fair
treatment in all customer interactions and monitor incidents. During the reporting period, no severe human rights
issues related to consumers or end-users were identiﬁed.
Information-related impacts for consumers and/or end-users
Policies related to Access to (quality) information and Freedom of expression
In the context of correct and transparent relationships between VUB Group and customers, the VUB Group ensures
that information intended for customers is presented clearly and understandably at all stages of the relationship,
through simple language, transparent information and the alignment of conditions within the different documents
referring to the same product/service.
The main documents of the offer, drafted according to the requirements of clarity and comprehensibility, are present,
in addition in the branch, also on the institutional website of the VUB Group, in the ‘Information services‘ and ‘Legal
information‘, as well as dedicated product and service-related sections, which contain information sheets, speciﬁc
guides and information documents of the conditions offered to the customers.
Respect for customer rights in all stages of the contractual relationship is also ensured through organizational and
compliance control measures with the regulations on customer protection (e.g. consumer protection/investor
protection), and through behaviours characterized by transparency and correctness in the marketing stage,
contractual stage and during the relationship as well.
In the area of investments, the VUB Bank offers customers the high level of protection. With respect to transactions
relating to ﬁnancial products or investment services, personalized recommendations under investment advisory
service are formulated that are consistent with the ﬁnancial proﬁle of the customer. In this sense, a system of speciﬁc
rules is fully operational to which the VUB Bank’s personnel must refer, in particular, Policy for providing advisory
service and other investment services, which identify the behaviours to be followed, and the safeguards applied in
the provision of the advisory service to customers and other investment services.
Furthermore, the drafting of this policy was carried out in coherence and alignment with the European Directives
(MiFID II) and with the national regulatory framework for their implementation. Finally, this policy is available to
employees through the VUB Intranet. The policy was approved by the Management Board and owner of the policy
is the Compliance and AML Department.
Since MiFID II entered into force, the regulatory framework for investor protection has been signiﬁcantly
strengthened. VUB Group has therefore introduced requirements for the management of ﬁnancial instruments, the
professional competence of persons providing investment services and obligations to inform clients about costs, fees
and incentives. The advisory model has been updated to also include sustainability (ESG) preferences in accordance
with ESMA recommendations. Clients receive information on the ESG characteristics of ﬁnancial instruments and
these elements are part of regular reports. All new products, services and their subsequent changes go through the
Product Governance process, in which the relevant departments of VUB Group are involved. The aim is to ensure
that each product complies with legislation, has a clearly deﬁned target group and that the interests of clients are
protected.
The process includes the phases of concept, feasibility analysis, approval and follow-up monitoring. Compliance
ensures that all internal and external regulations, including ESG criteria, are adhered to. Regular monitoring after
the product is launched on the market veriﬁes that the product still meets the target group and the deﬁned
parameters.
The Client Complaints Resolution Process is based on the principles of transparency, fairness and compliance with
legislative deadlines. The Bank reviews all circumstances reported by the client and the conduct of the staff to ensure
a fair resolution of the complaint. The procedure is published in the ‘Legal Information’ section of the Bank's website,
along with information on how the client can ﬁle a complaint and within what time frame they will receive a
response.
Subsequent assessments are based on legal regulations, internal rules and the principles of the Code of Ethics.
The Customer Care and Complaints Department submits a summary report at least once a year on the status of
complaint handling, types of submissions, as well as the adequacy of processes and measures taken.
Freedom of expression – Customer engagement processes
The Group has adopted a service model focused on business areas, with an organizational structure that ensures
coverage in Slovakia and in the Czech Republic where it operates. This model aims to enhance service quality through
various channels, in order to make the commercial offer more effective for the different types of customers.
ESRS S4 – Consumers and end-users
344
Customer satisfaction and the quality of the service offered are monitored and overseen by the structures that deal
with Customer Satisfaction and Customer Experience in the various functions, with a focus on the VUB Bank.
In this regard, in order to ensure a high level of customer satisfaction, PR & Corporate Communication, together
with parent company, and Retail and Corporate & SME Divisions, has developed a listening system, capable of
promptly detecting areas for improvement and activating concrete actions. This system is based on these key tools:
–
NPS (Net Promoter Score): Measures the customer's propensity to recommend the Bank in a concise and effective
way through a survey aimed at speciﬁc segments;
–
ECSI (European Customer Satisfaction Index): Measures the level of customer satisfaction with regard
to the most important moments of their interactions with the Bank;
–
ESG Pulse Check: A tool designed to provide a general overview of clients' strengths and weaknesses, to identify
their ‘ESG story‘, interests and needs.
All three surveys are performed with annual frequency.
In addition, the customer also has the opportunity to contact the Bank through the contact channels available in the
speciﬁc section of Internet Banking and website ‘Contact‘ and indicated in the information sheets provided to
customers and in the contracts (email address, certiﬁed email, ordinary mail, fax).
The management of complaints, the drafting and updating of such documents and the contents of the site are
regulated by speciﬁc internal regulations.
Effectiveness of the engagement is assessed through a trend analysis of NPS, ECSI and ESG Pulse Check results,
leading to adjustments in survey methods and customer communication strategies. Heads of the Retail and
Corporate and SME Divisions oversee the engagement processes and ensure that results are integrated into business
and service strategies.
Freedom of expression – Remediation processes and channels to raise concerns
Complaints are managed through a dedicated internal procedures, which describes in full detail the whole process
of handling complaints – starting from registering complaints (the client can ﬁle a complaint with the Bank in person
through retail/corporate branches, by calling the digital branch, by ﬁlling out the contact form on the Bank's website
or by e-mail at: kontakt@vub.sk or rieseniepodnetov@vub.sk), informing customer about taking the complaint
for investigation, process of investigation with all involved parties, preparing the response with result of investigation
for customer. Every complaint is held in ‘complaint register‘ in complaints system. Via the complaints system it is
possible to trace all the steps of the complaint management process and to monitor compliance with current
legislation with reference to response times.
Each complaint is carefully investigated, taking into consideration all the facts the customer mentioned, and all the
facts and data gained in the process of investigation. The response is prepared in simple, clear and understandable
language, and transmitted promptly, in any case respecting the time periods provided by legislation. Upon receipt
of the complaint, the customer receives a communication conﬁrming that the report is being addressed of. If the in-
depth information necessary for the preparation of the response makes it impossible to comply with the regulatory
deadlines, the customer is promptly informed by means of speciﬁc communication.
At the end of the complaint procedure, the Bank sends the complainant a written response. This feedback always
includes:
–
If the complaint is deemed unfounded: A clear and exhaustive explanation of the reasons for the rejection;
–
If the complaint is considered well-founded or partially founded: A description of the measures taken in favour
of the customer, with detailed indications on the methods and times necessary for the recognition of any refunds
or compensation.
For more information on the processes by which VUB Group promotes and supports the availability of channels for
its clients to raise concerns, as well as the policies adopted to protect individuals from retaliation when using these
channels, please see the standard ESRS G1 – Business conduct, section Policies related to corporate culture.
Targets related to Access to (quality) information and Freedom of expression
VUB Group has not set targets yet, as these are deﬁned, approved and monitored at the level of the parent company,
Intesa Sanpaolo, within the framework of the Group’s consolidated strategy and governance structure.
As a subsidiary, VUB Group aligns with these Group-level objectives, ensures their implementation in its operations,
and provides relevant performance data for the purpose of consolidated reporting. The applicable targets,
methodologies, and disclosures on progress are therefore included in the consolidated reporting published at the
Intesa Sanpaolo Group level, of which VUB group forms part.
ESRS S4 – Consumers and end-users
345
Actions related to Access to (quality) information and Freedom of expression
One of the fundamental aspects of the culture of quality concerns the continuous process of improving the customer
experience.
The VUB Group has therefore deﬁned a series of actions, as well as policies, to protect the quality of the services
provided, which allow for the implementation of continuous monitoring and addressing of the issue, allowing for
the achievement of high standards in terms of quality of the services offered.
Furthermore, the VUB Group uses key tools such as the NPS and ECSI in its customer engagement process, as
represented in the section Customer engagement processes, to monitor the effectiveness of its actions.
The Complaints Handling Ofﬁce monitors customer complaints and repetitions. To promptly intercept any emerging
phenomena, this structure sends regular reports to the identiﬁed business owners monthly, to receive feedback on
the actions activated or to be activated to mitigate the critical issues encountered by customers.
The actions implemented include customer recontact initiatives, which allow the relationship to be strengthened,
the NPS, ECSI and ESG Pulse Check data collected to be valorised and the risk of dissatisfaction and complaints to
be reduced thanks to active listening. These actions are part of a continuous improvement cycle, with periodic
reviews aligned with the VUB Risk Appetite Framework.
In 2025, the VUB Bank conducted Mystery shopping at its branches to gather valuable information about the quality
of customer service. The survey was repeated a year later to assess improvements in the speciﬁed areas compared
to the previous year. The results were positive; we achieved improvements in the client greeting phase and approach
to the client. We also improved in offering additional products to clients. The results from the mystery shopping are
a valuable source of information for the next year, so we can continue to improve our products and services for our
customers.
Regarding the management of complaints, periodic training activities are carried out for both the staff of the
Complaints Management Ofﬁce and the network staff.
The Complaints Management Ofﬁce prepares a regular report on the overall situation of complaints, disallowances,
complaints to supervisory authorities and appeals to alternative dispute resolution bodies as well as the trend in
customer complaints for the Management board on a semi-annual basis.
The dynamics of the complaints are also monitored monthly, to verify compliance with the early warning thresholds,
deﬁned on an annual basis in the VUB ‘Risk Appetite Framework‘. The processing times of the complaints are
constantly monitored by the function responsible for overseeing compliance with the reference regulatory provisions
and are reported in the aforementioned report, as well as reported in the following section Metrics – Response to
customer complaints.
Complaint processing times are continuously monitored by the Complaints Management Ofﬁce. Average resolution
times are reported in the monthly complaint statement.
Metrics related to Access to (quality) information and Freedom of expression
Number of branches
The number of branches divided by segment/geographical area is shown below:
Geography
Segment
# of branches 2025
# of branches 2024
Slovakia
Retail
121
123
Corporate
30
30
Czech Republic
Corporate
1
1
Response to customer complaints
Average times for resolving complaints are constantly monitored and are mostly in line with the deadlines set by
legislation. The main reasons for the extension of deadlines are mainly the time needed to obtain expert opinions.
At the VUB level, they are represented below in four types of complaints – Investment Services, Insurance Services
and Products, Payment Systems and Banking Services, whose average time for resolving a complaint in relation to
the reference legislation is calculated using the average of the days between the date of resolution of the complaint
and the date of its submission to the client. This time is calculated in calendar days (in this regard, it should be noted
that the maximum deadline set by the reference legislation is set in calendar days, with the exception of payment
services, for which business days are indicated).
ESRS S4 – Consumers and end-users
346
Type of complaint
Average processing times (calendar days)
Maximum deadline provided for by
the legislation (calendar days,
working days for Payment Services)
2025
2024
Banking services
10
9
60
Investment services
14
14
45
Insurance services and
products
11
13
15
Payment systems
12
10
60
Surveys in the bank are an important tool for obtaining feedback from customers with the aim of improving products
and services. Surveys are carried out in the form of online questionnaires, telephone interviews and focus groups.
We carry out ad hoc surveys, surveys in cooperation with the parent company, but also through external research
companies. Based on the survey results, VUB Bank implements the necessary changes, such as product adjustments,
improved customer service or new marketing strategies.
Policies related to Privacy
The VUB Group is committed to ensuring the highest level of protection for customers’ personal data and assets,
maintaining compliance with Regulation (EU) 2016/679 (GDPR), national laws, and anti-fraud frameworks. The
Group’s Code of Ethics outlines the principles and values on which the Group basis its choices and activities, Internal
Code of Conduct deﬁnes the conduct that the Group’s employees and collaborators are required to observe to
ensure the correct processing of data, Group’s Data Processing Policy deﬁnes governance principles for privacy risk
management, while the Fraud Risk Charter outlines measures to prevent fraud related to payment cards, remote
services, and personal data misuse.
To uphold these commitments, VUB:
–
Monitors compliance with external and internal regulations, including GDPR, the European Data Protection
Board (EDPB) guidelines, and ISP Group’s governance frameworks;
–
Implements safeguards such as privacy by design, privacy by default, and fraud detection systems to protect
customer data and assets;
–
Conducts regular risk assessments, internal audits, and compliance reporting to identify and mitigate potential
risks.
These policies apply to VUB and its subsidiaries, covering all personal data processing and fraud risk management
activities. The Group also ensures supplier compliance, requiring third parties to adhere to strict data protection and
security standards.
The Data Protection Ofﬁcer (DPO) supported by the IT Security Ofﬁcer, oversees privacy protection measures. The
Chief Operating Ofﬁcer is accountable for cybersecurity and fraud prevention, ensuring the Fraud Risk Charter is
implemented and regularly updated.
VUB’s customer protection policies align with internationally recognized standards, including:
–
GDPR (Regulation (EU) 2016/679);
–
European Data Protection Board (EDPB) guidance;
–
OECD Guidelines for Multinational Enterprises;
–
UN Guiding Principles on Business and Human Rights;
–
ILO Fundamental Conventions;
–
Payment Services Directive (PSD2) in relation to fraud prevention.
–
Privacy and Electronic Communications Directive 2002/58/EC and its implementation into the Slovak legal order
through Act No.
452/2021 Coll. on Electronic Communications.
VUB integrates customer rights and security into its policies by ensuring transparency in data processing and
customer communication, providing effective complaint resolution mechanisms, and implementing fraud prevention
measures to enhance digital trust and ﬁnancial security.
The Data Processing Policy and Fraud Risk Charter are available internally via the company intranet and are regularly
updated. Customers can access Claim Guidelines and privacy-related information on the Bank’s website, including
details on how to submit queries and complaints.
The VUB Bank enforces GDPR compliance through structured governance processes that ensure continuous
monitoring, risk management, and accountability (for example trainings and regular audits). Furthermore, the Bank
has established internal disciplinary mechanisms, in line with the ISP Group framework, which among others include
the processes of investigation and implementation of remediation actions.
ESRS S4 – Consumers and end-users
347
Privacy – Human rights commitments
According to Article 8 of the Charter of Fundamental Rights of the European Union, ‘
Everyone has the right to the
protection of personal data concerning him or her. Such data shall be processed properly for speciﬁed purposes on
the basis of the consent of the person concerned or on another legitimate basis laid down by law. Everyone has the
right of access to data concerning him or her which have been collected and the right to have them rectiﬁed.
Compliance with these rules shall be subject to control by an independent authority
.’
Based on the above, other legal regulations have been adopted that expand this right in a more detailed manner,
including, for example, the General Data Protection Regulation and Directive 2002/58/EC and its implementation
into the Slovak legal order in the form of the Electronic Communications Act No. 452/2021 Coll. These legal
regulations deﬁne in more detail the rights of natural persons referred to as data subjects, whether they are clients,
employees, or any persons concerned by the right to privacy and protection of personal data.
The rights relating to privacy and protection of personal data themselves are enshrined primarily in the principles of
these legal provisions. Articles 12-22 of the General Data Protection Regulation No. 2016/679 enshrine the rights of
natural persons relating to transparency, as well as other requirements in relation to personal data processed about
them. Natural persons have the right to request from those entities that process personal data about them
information to a speciﬁed extent, or to request the deletion of this data unless there is a legal or other justiﬁed
requirement for their further storage, and they also have the right to object to the processing of this data, or to their
transfer or restriction.
Directive 2002/58/EC as well as the Electronic Communications Act reﬂect modernization and newer technologies
and therefore regulate privacy from the perspective of requirements for the processing of cookies and regulate more
detailed rules for the marketing processing of personal data of natural persons and their addressing for this purpose.
Privacy – Customer engagement processes
The VUB Group makes the privacy policy available to all natural persons with whom it interacts. In fact, the privacy
policy for customers is available on the VUB Group’s website, which provides all the information necessary to ensure
correct data processing. These include the categories of data processed, the purposes and legal basis of the
processing, storage times, the recipients of the data, the rights of the data subjects and the methods of exercise, as
well as the DPO's contacts.
A special privacy policy was designed for the users of VUB mobile application, as well as users of DSS mobile
application ‘Dôchodok (Pension)‘. All the information necessary is therefore available directly in the mobile
application. For customers interacting with the Bank in branches, privacy policy is available in branches.
In the event of reports relating to privacy issues or requests to exercise rights, data subjects may contact the Data
Protection Ofﬁcer, using the channels described in the paragraph Remediation processes and channels to raise
concerns.
Privacy – Remediation processes and channels to raise concerns
The VUB Group has adopted a model for the management of critical events that precisely deﬁnes the activities aimed
at efﬁcient incident management, providing for the involvement of different functions depending on the nature of
the speciﬁc case, contributing to the mitigation of reputational risks related to the processing of personal data, also
with reference to the lawfulness, correctness and purpose of the processing, as well as relevance, completeness and
non-excess of the data collected.
In this scenario, the Data Protection Ofﬁcer manages non-compliance events by providing assistance and
collaboration to ensure that actions are identiﬁed and implemented to eliminate or mitigate the effects of the event.
If the event constitutes a data breach, the Data Protection Ofﬁcer is required to assess the impacts in terms of
concrete risk to the rights and freedoms of natural persons: if the risk is high, he/she notiﬁes the Data Protection
Authority and, in the event of a particularly high risk, also notiﬁes the data subjects. For more details on this, please
refer to the Metrics related to customer privacy section.
In 2024, the VUB Data Processing Policy was updated to outline the model for managing the risk of non-compliance
with regard to the protection of personal data, establishing the general principles and setting out the roles and
responsibilities of the corporate bodies and structures involved.
In the event of reports relating to privacy issues or requests to exercise rights, data subjects can contact the Data
Protection Ofﬁcer, with the contact details both in the information provided to all data subjects and on VUB Bank
and VUB Generali website.
Requests can be transmitted electronically (email, certiﬁed email, or through a special form available on the website
that transmits the request directly to the Privacy function) or on paper. In both cases, an adequate level of
conﬁdentiality and protection of the data of the data subjects who use it is guaranteed. The monitoring of the receipt
ESRS S4 – Consumers and end-users
348
of requests is the responsibility of the Privacy function in charge, which manages the reports and requests received
and ensures their timely processing according to the terms provided for by the legislation.
The careful and timely management of requests to exercise rights is of crucial importance to consolidate the
relationship of trust and address critical situations. VUB has structured itself to respond quickly to customer requests
in accordance with the requirement set out in Article 12 of the GDPR, which requires the data controller to take
appropriate measures to provide the data subject with all information relating to the processing, without undue
delay and, in any case, at the latest within one month of receipt of the request itself, or within two months in the
cases envisaged, informing the data subject.
VUB treats data subjects who lodged a data subject request according to GDPR fairly. The response to the requests
is provided free of charge while Article 12 of the GDPR allows the data controller to charge a reasonable fee taking
into account the administrative costs of providing the information or communication or taking the action required
where requests from a data subject are manifestly unfunded or excessive, in particular because of their repetitive
character.
As part of the Integrated System of Internal Controls, the Control Functions carry out checks with different depths
and periodicities, relating to the compliance of activities with the regulatory requirements on the protection of
personal data and the correct fulﬁlment of the provisions issued by the Data Protection Authority on these issues.
The results are reported to the Management Board.
In this context, the Chief Audit Ofﬁcer carries out periodic control activities that are deﬁned based on speciﬁc
regulatory obligations on the subject, from a risk-based perspective, also taking into account the evidence reported
by the other corporate control functions.
In general terms, the independent Internal Audit checks are aimed at ascertaining the completeness, adequacy and
functionality of the data protection risk management model, reporting any irregularities relating to the processing
of personal data to the responsible corporate structures, to the Data Protection Ofﬁcer and reporting them
to the Management Board.
The Data Protection Ofﬁcer, in compliance with the GDPR and the guidelines, has the task of preparing a report, at
least annually, to report to the Management Board on data protection issues of particular importance. This
commitment allows, through the adoption of appropriate measures, the mitigation of reputational and non-
compliance risks in the context of the processing of personal data also with reference to the lawfulness and
correctness of the processing, the purposes of the processing and the relevance, completeness and compliance with
the principle of data minimisation of the data collected.
For more information on how the VUB Group promotes and supports the availability of channels for its clients to
raise concerns, as well as the policies adopted to protect individuals from retaliation when using these channels,
please see the standard ESRS G1 – Business conduct, section Policies related to corporate culture.
Targets related to Privacy
VUB Group has not set targets yet, as these are deﬁned, approved and monitored at the level of the parent company,
Intesa Sanpaolo, within the framework of the Group’s consolidated strategy and governance structure.
As a subsidiary, VUB Group aligns with these Group-level objectives, ensures their implementation in its operations,
and provides relevant performance data for the purpose of consolidated reporting. The applicable targets,
methodologies, and disclosures on progress are therefore included in the consolidated reporting published at the
Intesa Sanpaolo Group level, of which VUB group forms part.
Actions related to Privacy
The VUB Group has prepared a series of policies and actions to protect customer data, which allow for continuous
monitoring and addressing of this issue, allowing for the achievement of high standards in terms of customer
protection, even without a precise deﬁnition of quantitative and measurable targets.
In addition, the Group has equipped itself with a model for the management of critical events that the activities
aimed at efﬁcient management of incidents and solutions that provide for continuous analysis of the events that
have occurred and threats, using metrics to evaluated the performance and effectiveness of its actions (represented
in the sections Metrics related to customer privacy and Metrics related to anti-fraud customer protection).
Privacy supervision is ensured by the Data Protection Ofﬁcer, identiﬁed according to the criteria of Article 37 of the
GDPR and appointed by the Management Board, and by the IT Security Ofﬁcer.
The Data Protection Ofﬁcer monitors the risk of non-compliance using a risk-based approach, ensuring the
application of the principles of Privacy by Design and Privacy by Default. This involves integrating data protection
into the design and substantial modiﬁcation phases of personal data processing, as well as during the processing
ESRS S4 – Consumers and end-users
349
itself. By adopting appropriate technical and organizational measures by default, the Data Protection Ofﬁcer aims to
maintain an adequate level of security and monitor compliance with privacy legislation effectively.
In 2025, awareness-raising activities aimed at VUB Group employees and relating to data protection issues
continued. This activity takes place through the provision of compulsory training courses in e-learning mode that
include a ﬁnal test and the provision of new modules to allow staff to learn the legislation in practice and
continuously update. VUB monitors the percentage of use of the courses and the passing of the related tests.
In 2025, monitoring of third parties continued, through the administration of self-assessment questionnaires
distributed to individual suppliers. Overall, the activity recorded a positive outcome with most suppliers obtaining a
medium/high level of supervision.
In 2025, the periodic updating of the Records of Processing Activities continued.
In relation to the activity of guidance, coordination and control special meetings with the representatives of the
Privacy function of Intesa Sanpaolo were held which were dedicated to the presentation of privacy processes, the
discussion of relevant issues and the sending and analysis of periodic information ﬂows. In relation to the activity of
guidance, coordination and control, special meetings with the representatives of the Privacy function of VUB were
held for individual VUB Group entities.
The fraud trend in 2025 highlights the use of increasingly advanced and complex techniques by fraudsters, including:
–
Frauds involving the use of mixed techniques of Phishing and Social Engineering aimed at stealing customer data
in order to carry out fraudulent provisions, mainly impacting Retail customers;
–
Fraud perpetrated through the use of malicious software (Malware), especially to allow NFC tunnelling;
–
Fraud, i.e. manipulations carried out by the fraudster to the detriment of the payer in order to induce him to
carry out a payment transaction in favour of a beneﬁciary that he considers legitimate but which later turned
out to be fraudulent;
To combat the above-mentioned fraudsters, the Bank uses speciﬁc solutions which, in summary, provide for
continuous analysis of events and threats to understand the risks and types of fraud in order to increase the ability
to detect and prevent the phenomena; and initiatives and limitations to protect the customers most at risk. The main
activities that were carried out during the year include:
–
Carrying out a behavioural analysis (Behavioural Customer Monitoring – BCM) which assesses the riskiness
of the Client's transaction based on its ﬁnancial habits. This activity will continue in 2026;
–
Implementation of a solution that progressively eliminates the use of SMS in favour of QR code and deep link
that are more complicated to be stolen by fraudsters;
–
Conducting an analysis of fraudulent phenomena with monitoring and insertion of ad-hoc rules aimed at
preventing the malicious action of fraudsters (Rules Optimization);
–
The initiative for implementation of data analytics logics and the use of machine learning and AI tools in
collaboration with the parent company. These activities will continue in 2026.
–
Participation on common initiative to implement solution allowing data exchange related to fraudulent
operations among Slovak banks under Slovak Bank Association
–
Various activities and campaigns in media to increase clients awareness about current frauds and scams schemes
For more details on blocked fraudulent transactions, please see the Metrics related to Privacy (Fraud prevention)
section.
Metrics related to Privacy
In 2025, 4 cases of loss or theft of VUB customer data were reported to and assessed by the VUB Data Protection
Ofﬁcer (4 case also reported in 2024). The cases assessed were conﬁrmed as data incidents and were handled in
accordance with VUB Data Processing Policy. Following the full analysis of the cases, measures were taken to prevent
similar cases in the future.
Metrics related to Privacy (Fraud prevention)
During 2025, in the face of attempted attacks involving the ﬁnancial system, Bank stopped fraudulent transactions
for approximately 2,7 million euros for private and corporate customers. Thanks to the countermeasures taken, fraud
rate was at 0.0016% in 2025.
ESRS S4 – Consumers and end-users
350
fraudulent transactions blocked
2025
2024
2.7 mln/€
2.5 mln/€
fraud rate
0.0016%
0.0017%
Personal safety of consumers and/or end-users
Policies related to Health and safety (including security of a person)
The protection of the safety of customers, their assets and their information is not only a primary duty of the VUB
Group but is also the basis of the relationship of trust that we want to continuously develop over time, as required
by the Code of Ethics.
VUB protects the right to health and safety of people, including customers or suppliers, by acting on two distinct
but complementary levels. Operational Health and Safety (OHS) at the VUB Group is implemented on operation level
(operational safety of premises – against injuries such as falls, slips and others), as well as for external incidents
(bomb threats, robberies and others).
To this end, VUB Bank has issued internal guidelines – Guideline to ensure occupational health and safety and
Incidents in physical security, issued by Logistics Department. The aforementioned internal regulations are inspired
by the constitutional principles and regulatory provisions that underline the value and dignity of work and
of the person and are published on Bank’s intranet.
Health and safety (including security of a person) – Customer engagement processes, Remediation processes and
channels to raise concerns
Among the principles and reference values of the Code of Ethics, the value of the person stands out: the Group
takes care of the health and safety of people for the purpose of a professional experience that respects physical and
psychological well-being.
In particular, the VUB Group protects the health and safety of all the people who work and pass through it by
implementing operational rules and technological security measures, supported by information and culture
dissemination tools on the subject. The protection of people is essential and therefore the issues of corporate and
physical security play an indispensable role, regulated by speciﬁc guidelines and internal rules that also protect
customers, allowing everyone to operate in full effectiveness, efﬁciency and safety.
To this end, the Code of Ethics provides for the possibility of sending reports of alleged non-compliance with what
it establishes also by customers through a speciﬁc email address, ensuring timely feedback on questions and
complaints and aiming for a substantial and not formal resolution of disputes
Speciﬁcally for physical safety, the VUB Group identiﬁed a series of actions aimed at overseeing and monitoring the
health and safety of the customers in VUB premises, as explained in the dedicated section. In the case of Operational
Health and Safety incident, it is also reported to and dealt with the appropriate function – Physical Safety. The Head
of Physical Safety Ofﬁce ensures engagement with customers on health and safety matters. The effectiveness of
engagement is assessed through incident reporting, internal evaluations, and follow-ups on customer safety
concerns.
For more information on how the VUB Group promotes and supports the availability of channels for its clients to
raise concerns, as well as the policies adopted to protect individuals from retaliation when using these channels,
please see the standard ESRS G1 – Business conduct, section Policies related to corporate culture.
Targets related to Health and safety (including security of a person)
VUB Group has not set targets yet, as these are deﬁned, approved and monitored at the level of the parent company,
Intesa Sanpaolo, within the framework of the Group’s consolidated strategy and governance structure.
As a subsidiary, VUB Group aligns with these Group-level objectives, ensures their implementation in its operations,
and provides relevant performance data for the purpose of consolidated reporting. The applicable targets,
methodologies, and disclosures on progress are therefore included in the consolidated reporting published at the
Intesa Sanpaolo Group level, of which VUB group forms part.
Actions related to Health and safety (including security of a person)
The VUB Group has prepared a series of policies and actions to protect customer health and safety, which allow
for continuous monitoring and addressing of this issue, even without a precise deﬁnition of quantitative and
measurable targets.
ESRS S4 – Consumers and end-users
351
With regard to actions aimed at the safety of personnel and assets, but which also have a potential indirect effect
on customer protection, the VUB Group develops its actions starting from risk analysis, an activity conducted by
the function responsible for corporate and physical security, on the basis of the applicable regulation.
These analyses allow the deﬁnition of prevention strategies and adequate measures, ranging from training and
organizational interventions to the use of advanced technological solutions.
Evaluating the effectiveness of actions is an integral part of the process. The VUB Group tracks data relating to all
criminal events, committed and attempted, on the Slovak and Czech Republic territory. The data for the current year
show substantial stability in these events compared to previous years, demonstrating the positive impact of the
measures adopted.
Additionally, in 2024, the VUB Bank, in cooperation with the Slovak Banking Association and the Police Force,
introduced the categorization of email threats. Three categories of threats and corresponding countermeasures for
the banking sector have been deﬁned. The aim is to respond appropriately to threats and thus protect employees
and clients.
Social inclusion of consumers and/or end-users
Policies related to products and services, Non-discrimination and Responsible marketing practices
The VUB Group is committed to building relationships with its customers based on trust and meeting their
expectations, offering high-quality products and services, with an approach based on constant listening and
dialogue. The VUB Group values inclusion and accessibility, avoiding any form of discrimination and promoting
solutions suitable for all social groups.
Access to credit and ﬁnancial inclusion are fundamental tools for social progress. The VUB Group is committed to
supporting vulnerable customers and encouraging the creation of new entrepreneurial activities, promoting
economic and social growth in the countries in which it operates, supporting innovation, ecological and digital
transition, and the development of sustainable projects.
With the launch of speciﬁc initiatives, the VUB Group also aims to promote gender equality and inclusion,
recognizing the social and productive value of the role of women in the economic context. Initiatives such as these,
aimed at reducing inequalities and supporting equality, contribute to strengthening the Intesa Sanpaolo Group's
role as a point of reference in social sustainability at the European level.
Furthermore, the VUB Group is committed to ensuring an inclusive and personalized experience for its customers,
promoting the use of digital channels and ensuring a transparent and proactive consultancy service.
The Intesa Sanpaolo Group 2022-2025 Business Plan is in line with what is outlined above. The Intesa Sanpaolo and
VUB Groups have reafﬁrmed their commitment to create sustainable and inclusive economic values, allocating
signiﬁcant funds to social lending to facilitate access to credit for vulnerable categories.
On the basis of speciﬁc internal VUB Group regulations relating to credit products and credit transactions classiﬁed
as ‘sustainable‘, this paragraph illustrates products and offers related to sustainability. These include, for example,
loans to support socio-economic advancement and empowerment. These internal regulations apply to VUB Bank, as
well as the Group’s companies (as applicable).
The deﬁnition of products and services aimed at customers is the result of a collaborative process between various
departments and regulatory principles, with the aim of ensuring respect for rights, transparency, and privacy. These
departments are called upon to evaluate and validate the proposals of product/service owners, ensuring that they
comply with internal regulations and processes.
Credit products and transactions are deﬁned according to speciﬁc classiﬁcation processes, which include the
assessment of the purposes of the underlying investment, as well as any applicable conventions, covenants, and
KPIs, distinct for each Business Division. These products and credit transactions are carried out in accordance with
the ESG framework, which provides for speciﬁc classiﬁcation categories, including ‘social sustainability‘. In particular,
credit products are classiﬁed as sustainable when they are recognized as such by special working groups and
approved by the Credit Risk Governance Committee, while credit transactions can be classiﬁed as sustainable if one
of the following conditions is met:
–
The credit intervention is intended for investment in a speciﬁc economic activity falling within the classiﬁcation
categories;
–
The credit intervention involves the achievement of sustainability objectives, linked to speciﬁc KPIs, which are
in line with the company's sustainability strategies.
ESRS S4 – Consumers and end-users
352
The sustainability attribute is assigned during the investigation phase. After the disbursement of the loan, verification
and monitoring of the sustainability attribute, if relevant, is conducted by the operational and business functions for
the entire duration of the loan.
The VUB Group considers investments to be a priority as well, with a view to offering opportunities to its customers,
providing specialized solutions through dedicated business units that meet the needs of investments and private
banking. The Bank and VUB Generali are committed to the offer of innovative financial products and services,
together with increasingly targeted ESG advice, to support informed investment decisions and promote sustainable
well-being for families and businesses in the long term.
Access to products and services, Non-discrimination and Responsible marketing practices – Customer engagement
processes
The VUB Group is committed to promoting clear and transparent access to its channels, encouraging customer
awareness in economic and ﬁnancial management. Through organisational structures and in collaboration with trade
associations, it develops products and services capable of responding to the needs of customers in continuous
evolution.
To best respond to customer needs, advanced listening tools are adopted, deepening emerging needs and assessing
the level of satisfaction with existing products and services to maintain an offer that is always in line with the
expectations of companies and individuals. In the design of agreements, loans, and other initiatives in favor of
customers, moments of direct engagement with beneﬁciaries are organized, integrating feedback and suggestions
to continuously improve their initiatives. By way of example, the Bank helps organize and participates in various
conferences, seminars, and workshops with clients, facilitating both face-to-face and remote sessions to discuss and
better represent the non-economic effects of the interventions implemented by the VUB Group.
The analysis of end-customer needs is based on market surveys (e.g. Eurostat) and the support of research institutes
with speciﬁc focus groups.
From the product design stage, customer behaviour and market benchmarks are analysed to identify potential needs.
Annual customer satisfaction surveys and ongoing customer experience surveys following interactions at physical
and digital locations highlight areas of satisfaction and dissatisfaction, allowing immediate action to be taken to
optimize the offering.
Listening to customers is enriched by the contribution of feedback from branches, who provide feedback on
processes and services, suggesting improvements for a more immediate usability and a more transparent
relationship.
Customer engagement is overseen by the Management Board members responsible for Retail, and Corporate and
SME Division
,
ensuring insights inform the Bank’s approach.
Access to products and services, Non-discrimination and Responsible marketing practices – Remediation processes
and channels to raise concerns
The VUB Group maintains a constant dialogue with customers to guarantee an excellent service. Each customer has
the opportunity to submit a complaint in different ways, such as the online format, paper mail, or e-mail, through
the Call Centre. Timely and careful handling of complaints is crucial to building trust and resolving any critical issues.
The regulations in force require that the Customer Complaints function in charge provide periodic information,
on the management of selected client complaints and the effectiveness of the procedures adopted.
Furthermore, the Code of Ethics provides for the possibility of addressing reports of alleged non-compliance with
what it establishes also by customers through a speciﬁc email address, ensuring timely feedback on questions and
complaints and aiming for a substantial and not formal resolution of disputes.
Targets related to Access to products and services, Non-discrimination and Responsible marketing practices
VUB Group has not set targets yet, as these are deﬁned, approved and monitored at the level of the parent company,
Intesa Sanpaolo, within the framework of the Group’s consolidated strategy and governance structure.
As a subsidiary, VUB Group aligns with these Group-level objectives, ensures their implementation in its operations,
and provides relevant performance data for the purpose of consolidated reporting. The applicable targets,
methodologies, and disclosures on progress are therefore included in the consolidated reporting published at the
Intesa Sanpaolo Group level, of which VUB group forms part.
While the VUB Group did not set any speciﬁc quantitative targets for 2025 year related to social inclusion, it actively
contributed through its incentivized ﬁnancing to social and environmental sustainability and is committed to
enhancing and expanding its offerings in the future.
ESRS S4 – Consumers and end-users
353
Actions related to Access to products and services, Non-discrimination and Responsible marketing practices
The VUB Bank repeatedly launches campaigns for its products, which can be supported by favourable ﬁnancing if
project/loan is provided for sustainable purposes, or if speciﬁc sustainability KPIs are used. Through campaigns, the
clients are made aware of the ESG theme, the options for transitioning to a sustainable business, and is provided
with advice and discounted ﬁnancing according to their speciﬁc needs.
Likewise, corporate sector conferences such as ATLAS or conferences for speciﬁc sectors (AGRO, Municipality, etc.)
are regularly organized, where clients are informed about the trends in sustainability, the need for transformation,
they are familiarized with the various surveys, market opportunities as well as product offerings in the ﬁeld of
sustainability.
The VUB Bank provides targeted ﬁnancial support through products designed to enhance social inclusion. The social
aspect of these products is deﬁned by fulﬁlling speciﬁc sustainability features, such as submission of relevant
documentation or by meeting clearly deﬁned conditions or criteria (e.g., client’s age). Within this scope, targeted
groups include young clients purchasing their ﬁrst home or clients with children.
Mortgages for young clients beneﬁt from reduced interest rates in the initial repayment period, supporting ﬁnancial
accessibility for younger demographics. Due to strong demand, additional sales incentives for this product are
currently not required.
Mother loans offer favourable interest rates and fee structures to support parents facing increased childcare expenses
when returning to work. These products are structured to provide ﬁnancial relief and encourage long-term ﬁnancial
stability for eligible clients.
As regards the SME and Corporate clients, the VUB Bank provides a wide range of credit products, with the aim of
helping to ﬁnd solutions in the ESG ﬁeld. In relation to social inclusion issues, VUB can provide loans based on rules
of sustainable credit transactions in areas such as: Affordable Basic Infrastructure, Access to Essential Services aimed
at infrastructure of the communities, access to education & culture, proper integration of disadvantages groups,
Affordable Housing, Job creation and preservation, Food Security and sustainable food systems including reduction
of food losses and resilient agricultural practices, waste, socioeconomic advancement, projects focused on vulnerable
groups etc.
With a focus on community support or employee well-being, VUB offers the S-LOAN loan with a preferential interest
rate (details below).
The VUB Bank supports EU targets through Bridge Loans with EU Funds, helping SMEs and corporates access non-
repayable ﬁnancial contributions for social projects within the current operational programs/instruments. The main
objective is to support education, employment, social inclusion, and vulnerable groups in the labour market.
The VUB Bank also collaborates with the European Investment Bank Luxembourg to ﬁnance corporate and public
sector projects, supporting business development, climate action, and social projects while reducing regional
disparities in line with EU cohesion policy. Loans allocated from the MBIL facility focus on energy infrastructure,
renewables, energy efﬁciency, and environmental sustainability. Allocations follow internal VUB procedures.
To achieve ESG targets, the VUB Bank introduced the TERRA product line, offering loans with preferential interest
rates to support sustainability.
With the focus on Community Support or Employees Welfare, VUB offers S-LOAN with preferential interest rate
These sustainability-linked are provided to clients who meet speciﬁc sustainability targets, in area of community
support or employee welfare. Compliance is monitored and disclosed in ﬁnancial statements.
These ﬁnancing solutions align with VUB’s ESG strategy and support sustainable business practices.
Furthermore, as illustrated above, in the current context it is essential to support initiatives that contribute to
supporting the productive fabric, as well as the economic and social growth of the areas in which the VUB Group
operates, through the offer of products and services in the ﬁeld of environmental, social and other sustainability (for
which please refer to the section Actions related to Access to products and services, Non-discrimination and
Responsible marketing practices – Actions related to sustainability-conscious investments for details). For a complete
representation of the range of products and services offered for this purpose, with particular reference to
climate/environmental issues, see also the standard ESRS E1 – Climate Change, section Actions and resources related
to climate change.
ESRS S4 – Consumers and end-users
354
Metrics related to Access to products and services, Non-discrimination and Responsible marketing practices
For the purpose of greater internal and external transparency regarding products and operations considered
sustainable, the VUB Group has decided to draw up speciﬁc rules for the classiﬁcation of credit products and
sustainable credit operations. From 2024, reporting conforms to these rules, including the classiﬁcation ﬁnancing
falling under the categories of environmental sustainability, social sustainability, and other sustainability.
In particular:
Sustainability
Category
Description
Included Products/Credit Operations
Environmental
sustainability
Products and credit operations classified as
sustainable based on environmental criteria.
Financing for Private Individuals, Companies, Third Sector, Corporate
& Project Finance, SME, Corporate
Social sustainability
Products and credit operations considered
sustainable under the social category.
Anti-usury loans, products for vulnerable social classes, financing for
the Third Sector, other social loans, SME, Corporate
Other forms of
sustainability
Activities not directly purpose-driven but
linked to sustainability-related covenants or
KPIs involving ESG aspects.
Credit exposures with covenants including environmental, social, or
governance aspects; related to Companies, Third Sector, Corporate &
Project Finance; not eligible under EU Taxonomy, SME Corporate
Sustainable loans disbursed in the reporting year
Below is a summary of the total amount disbursed during the 2025 ﬁnancial year, broken down by type of ﬁnancing.
Retail
Type of funding
2025 disbursed amount (€ mln)
2024 disbursed amount (€ mln)
Financing in the field of environmental sustainability
712.3
599.2
Financing in the field of social sustainability
267.5
182.7
Total amount disbursed
979.8
781.9
Corporate
Type of funding
2025 disbursed amount (€ mln)
2024 disbursed amount (€ mln)
Financing in the field of environmental sustainability
306.9
187.4
Financing in the field of social sustainability
22.9
7.6
Financing falling under the category 'other sustainability'
158.9
233.2
Total amount disbursed
488.7
428.3
355
Governance Information
ESRS G1 – Business Conduct
Materiality assessment process on impacts, risks and opportunities related to business conduct
matters
The methods for identifying material topics for the VUB Group is described in detail in the chapter ESRS 2 – General
Disclosures – Double Materiality Assessment.
The impacts, risks, and opportunities within the scope of ESRS G1 – Business Conduct are identiﬁed taking into
account the VUB Group's speciﬁcities. In particular, the mapping of such impacts, risks, and opportunities was carried
out on the basis of the context in which the VUB Group deﬁnes and implements its business activities and
relationships, and the internal safeguards in this area, with reference to its own operations and the value chain
upstream and downstream, in addition to an assessment of the risks to which the VUB Group may be exposed.
For the purposes of impact materiality, the assessment of the identiﬁed impacts was conducted through interviews
with internal structures and external stakeholders (i.e. dedicated questionnaire involving selected suppliers, clients,
investors, NGOs, etc.), as well as through detailed qualitative-quantitative analysis, carried out on the basis of the
metrics required by the reference legislation (i.e. scale, scope, irremediable nature of the impact and probability). In
particular, with reference to:
Value Chain
Scope & Assessment Method
Identified Impacts
Own Operations
Qualitative drivers based on internal
controls, including dissemination of
corporate culture (e.g., ethical and
responsible practices).
Material
Promotion of an ethical corporate culture
Prevention of corruption phenomena through the adoption of
internal policies and strategies aimed at it (e.g. obtaining ISO
37001 certification)
Contribution to the protection of individuals who report violations
(whistle-blowers)
Promotion of ethical and responsible practices through lobbying
activities carried out according to the adopted ethical principles
that can generate benefits for the community
Upstream Value Chain
Analysis of ESG questionnaire
responses from suppliers and their
feedback.
Material
Contribution to the diffusion of ethical practices through the
definition of internal policies and strategies aimed at promoting
dialogue and compliance with payment deadlines towards direct
suppliers and sub-suppliers
Downstream Value Chain
Analysis of indirect impacts through
exposures in VUB Group's portfolios,
considering sectors with high
corporate ethics impact (e.g., human
rights, anti-tax evasion, anti-money
laundering, anti-competitive
behaviour).
-
Changes to materiality of impacts in 2025
Changed to:
Sub/sub-sub
topic
Value chain
Description
Reasoning
Non-
Material
Corporate
culture
Own operations
Positive impact on corporate
integrity by ensuring the
security of the Bank's IT and
network systems for the
benefit of customers through
the implementation of
cybersecurity policies and
safeguards
The impact was reclassified to the S4 DMA
assessment and became non
‑
material, as its
likelihood decreased following
re
‑
evaluation. This is due to the VUB
Group’s robust IT and client
‑
security
policies, protocols, and controls, which
prevent the impact from being material
under current conditions.
For the purposes of determining ﬁnancial materiality, the relevance of risks and opportunities was assessed through
a dual approach, quantitative and qualitative, applied to the perimeters identiﬁed above.
ESRS G1 – Business Conduct
356
Speciﬁcally, with reference to risks, the following analyses were conducted:
Value Chain
Scope & Assessment Method
Identified Risks
Own Operations
Assessed operational risk, non-compliance risk, reputational
risk, especially cybersecurity and potential sanctions linked
to VUB Group’s operations. Internal policies and strategies
supporting corporate culture, integrity principles,
whistleblowing, political engagement, lobbying and the
fight against corruption were also taken into account.
Material
Reputational risk arising from inadequate
development and promotion of corporate
culture (e.g. image damage linked to a lack
of corporate values in employee behaviour
or business practices (e.g. failure to establish
safeguards against tax risk, money
laundering) (also covering Ustream Value
Chain)
Upstream Value Chain
Assessed reputational risk from suppliers potentially having
less structured controls (e.g., Code of Ethics, anti-corruption
policies), feedback from the ESG questionnaire); ethical
policies and procedures in managing relationships with
suppliers and responsible management of payment practices
were also assessed.
-
Downstream Value Chain
Assessed credit risk, market risk, strategic risk, and
reputational risk related to commercial relations with
counterparties, exposure to sectors with high ethical impact
(human rights, compliance, anti-tax evasion and anti-money
laundering) was taken into account; investment/financial
criteria and strategies were evaluated.
-
Changes to materiality of risks in 2025
Changed to:
Sub/sub-sub
topic
Value chain
Description
Reasoning
Material risk
merged
Management
of relationships
with suppliers
including
payment
practices
downstream
Credit Risk – exposure to
counterparties with
inadequate
supply
‑
relationship
management and poor
payment practices, which
may disrupt the value chain
and impair their ability to
repay debt.
These risks were assessed as irrelevant
because effective safeguards, internal
policies, and legal compliance mechanisms
are already in place; if any of these risks
were to materialize, it would indicate that
the VUB Group’s controls or policies had
fallen below legally mandated minimum
standards required for its operation. One
reputational risk was retained as material,
specifically the potential inadequate
development and promotion of corporate
culture, which encompasses and
sufficiently covers the underlying risks
identified.
Material risk
merged
Corruption
and bribery
upstream and
downstream
Reputational Risk – absence
or failure of policies to
prevent and detect active or
passive bribery, including
violations of anti
‑
bribery and
anti
‑
corruption procedures.
Material risk
merged
Corporate
culture
own operation
Operational Risk –
inadequate cybersecurity
safeguards that may
compromise the security of
the Bank’s computer and
network systems for
customers and stakeholders.
Material risk
merged
Protection of
whistleblowers
Upstream and
own operation
Reputational Risk –
insufficient safeguards for
whistleblower protection,
potentially reducing
employee trust and
discouraging reporting of
misconduct.
It should be noted that, speciﬁcally in the process of identifying and assessing risks related to business conduct,
the VUB Group has adopted an integrated approach that considers speciﬁc criteria relating to the location, type of
activity, sector and structure of the operations performed. In particular, in relation to own operations, potential
sanctions arising from violations of regulations and procedures are monitored. For relation to the upstream value
chain, suppliers are monitored and selected according to criteria that promote corporate solidity and compliance
with ethical standards via dedicated ESG questionnaire for suppliers, the results of which are part of the evaluation
process of the suppliers. In relation to the downstream value chain, compliance of counterparties with regulations is
checked prior to the activation of products and services, as part of the client evaluation procedure, business relation
and the speciﬁc trade. The analyses just mentioned took into consideration the countries and areas of activity in
which the VUB Group mainly operates, its suppliers and the counterparties ﬁnanced and in which it invests.
Regarding the ﬁnancial relevance of the opportunities, the analyses focused on the company's own operations in
terms of business conduct. The materiality analysis did not reveal the mapped opportunities to be material in 2025
when compared to 2024.
ESRS G1 – Business Conduct
357
Policies, targets and actions related to corporate culture
The corporate culture of the VUB Group is systematically supported through clearly deﬁned policies aimed at
ensuring consistent, ethical and responsible behaviour across the entire organization. The cornerstone of these
policies consists of the Code of Ethics and the Internal Code of Conduct of the VUB Group, which together establish
a framework for decision-making, everyday employee behaviour, and relationships with all stakeholders.
Policies Related to Corporate Culture
The Code of Ethics represents the fundamental policy governing corporate culture. It deﬁnes the values, principles
and standards of conduct that are binding for all companies within the Group and guide relationships with
employees, customers, business partners, shareholders and society as a whole. The Code is aligned with key national
and international corporate social responsibility frameworks, including:
–
the OECD Guidelines for Responsible Business Conduct and Multinational Enterprises,
–
the United Nations principles on combating corruption,
–
the Council of Europe Convention on preventing and combating violence against women (the Istanbul
Convention),
–
the Charter of Fundamental Rights of the European Union.
Through this alignment, the Code ensures a consistent approach to issues such as human rights, decent working
conditions, environmental protection and the prevention of corruption.
The Internal Code of Conduct builds upon the Code of Ethics by translating its principles into concrete rules and
expectations for everyday behaviour. It serves as a practical guide that helps employees and collaborators identify
appropriate conduct, prevent conﬂicts of interest, and act professionally, honestly and responsibly within their roles.
Both documents are regularly updated in line with changes to the overarching Code of Ethics of the Intesa Sanpaolo
Group, as well as developments in the legislative and regulatory environment. Updates are promptly implemented
into local documentation and transparently communicated to relevant stakeholders, ensuring consistency of rules
across the Group.
Responsibility for the implementation and monitoring of compliance with the Code of Ethics lies with the Human
Resources and Organization Department, in cooperation with Internal Audit. Compliance is reviewed through regular
annual audits planned on the basis of risk assessments.
Targets Related to Corporate Culture
VUB Group has not set targets yet, as these are deﬁned, approved and monitored at the level of the parent company,
Intesa Sanpaolo, within the framework of the Group’s consolidated strategy and governance structure.
As a subsidiary, VUB Group aligns with these Group-level objectives, ensures their implementation in its operations,
and provides relevant performance data for the purpose of consolidated reporting. The applicable targets,
methodologies, and disclosures on progress are therefore included in the consolidated reporting published at the
Intesa Sanpaolo Group level, of which VUB group forms part.
Actions Related to Corporate Culture
The objective of the Code of Ethics and the Internal Code of Conduct is to shape, over the long term, a corporate
culture founded on trust, transparency and responsibility. Through these policies, the Group seeks to:
–
ensure the consistent application of ethical principles across the organization,
–
promote responsible decision-making at all levels of management,
–
prevent unethical behaviour and reputational risks,
–
strengthen employee awareness of expected conduct and personal accountability,
–
create a safe and inclusive working environment based on mutual respect.
To ensure the effective application of the Code of Ethics and the Internal Code of Conduct, the VUB Group carries
out a range of supporting activities. A key instrument is a mandatory training programme that provides employees
with practical knowledge of ethical principles, standards of conduct and mechanisms for their application in everyday
work.
Implementation is further supported by oversight and control mechanisms that enable monitoring of compliance
with the Codes and identiﬁcation of potential risks. Employees and other stakeholders have access to secure channels
for reporting violations (etickykodex@vub.sk or codice.etico@intesasanpaolo.com). The Group ensures the
protection of whistleblowers and the conﬁdentiality of reported cases.
The principles of the Codes are also actively promoted through internal communication, which ensures their regular
reinforcement and clear explanation. Through these measures, the values of the Code of Ethics and the Internal
ESRS G1 – Business Conduct
358
Code of Conduct are integrated into the organization’s daily operations and contribute to a sustainable corporate
culture over the long term.
In line with the values and principles set out in the Code of Ethics and the Internal Code of Conduct, the VUB Group
has implemented a mandatory training programme designed to ensure that all employees understand the expected
standards of behaviour and are able to apply these principles in their day-to-day practice. The programme is delivered
digitally through two online learning platforms – VUB Academy and LEA – Learning Everyday Anywhere.
The VUB Academy platform is primarily used for the delivery of periodic mandatory training. It currently offers nine
compulsory courses that provide detailed explanations of the rules and procedures arising from the Code of Ethics
and the Internal Code of Conduct. These courses are regularly refreshed at one- to two-year intervals to ensure the
continued relevance of the content and the long-term reinforcement of ethical principles within the organization.
Overall, in 2025, 98% of individuals working for the VUB Group, including employees engaged under non-standard
employment arrangements (temporary or part-time contracts), successfully completed the mandatory training
delivered via the VUB Academy platform.
The second learning platform, LEA – Learning Everyday Anywhere, is used to assign mandatory training to employees
on an annual basis for each calendar year. New employees are required to complete not only the current year’s
mandatory courses but also all relevant training from previous periods, ensuring a consistent level of knowledge and
awareness across the entire organization.
The thematic focus of mandatory training is continuously updated in line with the Group’s priorities. In 2024, the
primary emphasis was placed on the Code of Ethics, while in 2025 the training activities focus mainly on the Internal
Code of Conduct and related topics, including the whistleblowing process and reporting mechanisms. The objective
is to strengthen employee awareness of available protection tools and of their personal responsibility in identifying
and reporting potential breaches.
To ensure a high level of familiarization with the Codes, completion of selected mandatory training courses is linked
to the remuneration system. In cases where prescribed training deadlines are not met, sanctioning measures are
applied in accordance with the Group’s internal regulations. This approach reinforces employee accountability and
underlines the importance of ethical principles as an integral part of the corporate culture.
Training programmes covering the Code of Ethics, the Internal Code of Conduct, anti-corruption prevention and
whistleblower protection are systematically reviewed and enhanced. Through these measures, the VUB Group
consistently strengthens the values that underpin its corporate culture and ensures their uniform application across
all processes and initiatives.
Policies, targets, actions and metrics related to the prevention of corruption and bribery
Policies related to the prevention of corruption and bribery
Internal Audit (Whistleblowing Team) performs an initial check to conﬁrm the relevance and completeness of the
report and informs the Designated Person of its receipt. The Designated Person oversees the integrity of the process
and decides on the further course of action. Relevant reports are then assigned—based on their subject matter—to
the competent department, which carries out the investigation while ensuring conﬁdentiality of all involved. The
investigating function gathers facts, evaluates evidence, consults Legal Department and HR if needed, and prepares
a formal recommendation for the Ethics Committee. The Ethics Committee reviews the ﬁndings and decides on the
outcome, including any disciplinary or corrective actions. The whistleblower receives feedback within the legally
required timeframe.
The VUB Group carries out its activities with the aim of providing banking and ﬁnancial services to its customers in
compliance with the value of integrity, which in turn is expressed in the principles of professionalism, diligence,
honesty, fairness and responsibility, and in line with the values and restrictions contained in the Code of Ethics and
the Code of Conduct.
In this context, the Anti-Corruption Guidelines establish the principles, identify the sensitive areas and deﬁne the
roles, responsibilities and macro processes for managing the risk of corruption and deﬁne the commitment to comply
with the regulatory provisions aimed at combating corruption in all its forms (the principle of ‘zero tolerance’).
Moreover, the VUB Group, in the context of its active collaboration in the ﬁght against corruption and in order toto
safeguard its image among all key stakeholders, monitors the operations in which it takes part as a mere executor
of customer instructions. This is achieved with an anti-money laundering and terrorist ﬁnancing risk control system,
provided for the management of the obligations arising from the applicable legal framework, such as Slovak Act No.
91/2016 Coll. on corporate criminal liability and on modiﬁcation and amendment of certain acts.
ESRS G1 – Business Conduct
359
In particular, the Anti-Corruption Guidelines deﬁne the areas in which the risk is the highest, i.e. which may be
instrumental in the commission of corrupt conduct:
–
Gifts and entertainment expenses;
–
Charities and sponsorships;
–
Relations with third parties (suppliers and other parties that collaborate with the VUB Group);
–
Purchase, management and sale of shareholdings and other assets;
–
Hiring of personnel;
–
Purchase, management and sale of real estate.
Furthermore, the aforementioned Guidelines offer the opportunity to deepen the knowledge of the counterparts
with whom the VUB Group engages in its activities, while simultaneously safeguarding the maintenance of credibility
and trust towards all stakeholders.
The monitoring process of the principles of the Anti-Corruption Guidelines is developed in the following activities:
–
Analysis of the evolution of the regulatory context;
–
Risk assessment;
–
Deﬁnition of ﬁrst and second level controls;
–
Veriﬁcation of the application of the Guidelines;
–
Quality assurance.
The principles and provisions of the Anti-Corruption Guidelines must be respected by the VUB Group’s Ofﬁcers and
all the personnel of the VUB Group. Also required to observe the principles contained in this document, if applicable,
are the external stakeholders (suppliers, agents, consultants, professionals, business partners, self-employed or quasi-
employees, etc.) that assist the Group in the execution of its activities (‘third parties’). For this reason, the Group
transmits the principles to all relevant stakeholders in a bilateral way, during the commercial relationship set-up and
before any contract signing. In any case, the compliance with anti-corruption principles is part of the General
conditions, which represent an integral part of the contract.
The Management Board is responsible, within its competences and prerogatives, for ensuring adequate control of
non-compliance risks to which the VUB Group is or may be exposed. Its tasks and responsibilities are deﬁned in the
relevant regulations and the internal control system, under the oversight of the Supervisory Board and the Audit
Committee. The Head of Compliance and AML Department prepares and proposes to the Management Board the
Anti-Corruption Guidelines and ensures supervision of the risk of corruption through the AML Ofﬁce which provides
support in control, governance and reporting activities with the task of overseeing corruption risk at the VUB Group
level. To this end, the Ofﬁce is independent of the operating units, given its reporting to the Deputy CEO, and has
qualitatively and quantitatively adequate ﬁnancial and human resources for its duties. The Head of AML Ofﬁce is
assigned the role of Group Head of Anti-Corruption.
At the operational level, VUB Group personnel must immediately report violations of the provisions of the Guidelines
to their Manager; the latter, in turn, is obliged to transmit the report received to the VUB Group Head of Anti-
Corruption and the Internal Audit for the appropriate assessments. This is without prejudice to the possibility of
using the reporting systems provided for by the Whistleblower policy.
In this context, it should be noted that the Intesa Sanpaolo and VUB Group's approach to combating corruption is
inspired by the founding principles contained in the relevant conventions as well as by international best practices
(OECD, ‘Convention on Combating Bribery of Foreign Public Ofﬁcials in International Business Transactions’, United
Nations Organization, ‘Convention Against Corruption, Global Compact’; Council of Europe, ‘Criminal Law
Convention on Corruption’ and ‘Civil Law Convention on Corruption’, Council of the European Union). Moreover,
the areas at greatest risk of corruption are also deﬁned according to the approach advocated by the ISO 37001:2016
Anti-bribery management systems standard as well as taking into consideration the ﬁndings of the annual corruption
risk assessment.
Targets related to the prevention of corruption and bribery
VUB Group has not set targets yet, as these are deﬁned, approved and monitored at the level of the parent company,
Intesa Sanpaolo, within the framework of the Group’s consolidated strategy and governance structure.
As a subsidiary, VUB Group aligns with these Group-level objectives, ensures their implementation in its operations,
and provides relevant performance data for the purpose of consolidated reporting. The applicable targets,
methodologies, and disclosures on progress are therefore included in the consolidated reporting published at the
Intesa Sanpaolo Group level, of which VUB group forms part.
ESRS G1 – Business Conduct
360
Actions related to the prevention of corruption and bribery
The main actions taken in the context of corruption prevention consist of the constant revision of the Intesa Sanpaolo
Group Anti-Corruption Guidelines, the updating of the Intesa Sanpaolo Group Rules on the management of gifts
and entertainment expenses, and the planning of the adaptation to the recommendations of the certiﬁcation body
for the purposes of ISO 37001:2016. Intesa Sanpaolo Group obtained the renewal of the aforementioned
certiﬁcation in 2025. VUB Group is part of this certiﬁcation as it is a subsidiary of Intesa Sanpaolo and was audited
in connection with this certiﬁcation in 2025.
Updated version of these documents were approved by the Management Board and implemented in 2025. The
review of the Anti-Corruption Guidelines takes place annually, typically in December.
Aligned with the Parent Company methodology, the VUB Group adopts a risk assessment model considering the
operational and business peculiarities of the individual companies, based on a qualitative/quantitative methodology
that derives from an assessment of the residual risk in relation to the risk inherent risk in the vulnerability of the
organizational system and controls:
–
The assessment of the inherent risk is based on seven risk factors consistent with the areas identiﬁed by the
Guidelines, as well as the geographic factor, assessed on the basis of a set of quantitative indicators (e.g. amount
of orders to third parties);
–
The assessment of the vulnerability of the organizational system and controls is based on thirteen categories of
vulnerability developed on the basis of a qualitative questionnaire that recalls the macro-processes deﬁned in
the Anti-Corruption Guidelines and a set of quantitative indicators developed by correlating the risk mitigation
elements (e.g. number of employees who have completed training courses).
For the purposes of issuing the aforementioned ISO 37001:2016 certiﬁcation, checks were conducted on the areas
at higher risk of corruption by the Head of Compliance and AML Department, which include both ﬁrst-level controls
(including enhanced due diligence activity) and second-level controls.
In addition, VUB Bank monitors the operations in which it intervenes as an executor of customer provisions, making
use of the system to monitor the risk of money laundering and terrorist ﬁnancing.
The VUB Group is committed to protecting those who in good faith report a violation of the Code of Ethics from
retaliation, discrimination or punishment, and to ensure the utmost possible discretion, unless otherwise required by
law. In this regard, the Whistleblower Policy provides that the function responsible for investigation (mostly Internal
Audit) is determined based on the decision of the Designated person, a function directly required by the Slovak law
and appointed by the Management Board (currently assigned to the Chief Operating Ofﬁcer).
The results of the investigation, formalized in the ﬁnal report, are then submitted to the Ethics Committee (composed
by Designated person, the Head of Human Resources and Organization, member of the Management Board not
managing the division to which a report pertains) which ultimately decides on the outcome of the report and
subsequent corrective actions taken.
The reporting to the Management Board on anti-corruption matters is an integral part of the reports prepared by
the Compliance and AML Department. These include, on an annual basis, the identiﬁcation and assessment of risks
of non-compliance and the scheduling of management interventions and, on a half-yearly basis, reports of actual
results, a description of the activities performed, critical issues noted, and remedies identiﬁed.
Furthermore, the Bank implements speciﬁc training initiatives on the subject for company representatives and staff
members who are most exposed to the risk of corruption.
The planned initiatives include mandatory Anti-Corruption and Anti-Bribery trainings for all employees are mandatory
and traceable and aim to (a) grasp the salient aspects of the regulatory provisions aimed at combating corruption
and (b) apply the Guidelines, acting in accordance with the provisions contained therein.
E-learning and certiﬁcation are renewed annually and in occasion of substantial revisions of the Anti-Corruption
Guidelines, by providing speciﬁc refreshed content, and by preferring the digital channel, which guarantees the
achievement of the perimeters and functions/resources of the VUB Group. Speciﬁc provisions established that failing
to meet the expected levels for the timely participation in mandatory training in the reference period may affect the
determination of the amount of the annual performance bonus.
The training contents incorporate the regulations in force at a general level (Guidelines) and in response to the
operations of the Business Units (Rules and Processes); in the case of updates during the year, the necessary additions
are made available.
As part of the management of corruption risk, the Bank provides training to 100% of the structures involved in the
sensitive areas identiﬁed as having the highest risk of corruption. These include External Communication
Department, Real Estate and Logistics Department, HR and organization Department, Procurement Department.
ESRS G1 – Business Conduct
361
The Anti-Corruption and Anti-Bribery annual training courses dedicated to employees are also available for the
members of the Management Board.
Metrics related to the prevention of corruption and bribery
As of December 31, 2025, there were no convictions and/or sanctions against the Bank for violation of anti-
corruption and anti-bribery laws and consequently the total of sanctions is zero, same as in 2024. No actions were
needed to address breaches.
Policies, targets and actions related to protection of whistleblowers
Policies related to protection of whistleblowers
VUB Whistleblowing policy is governed by Act No. 54/2019 Coll. on Protection of Whistleblowers and on
amendments to certain acts (Act on Whistleblowing; notiﬁcation about serious or other anti-social activity, incl.
crimes and corruption). It describes the methods and channels of communication that the whistleblower may use as
well as the reporting process that takes place when a report is submitted. It also indicates the various stages of the
process, the persons involved, including their roles and responsibilities as well as reporting.
According to this Policy, an individual who can ﬁle a report on a breach (whistleblower) is a natural person who, in
good faith, makes a notiﬁcation to the authority responsible for receiving the notiﬁcation or to the employer. In this
context, the system is intended for: employees and self-employed workers who carry out or have carried out their
work at the VUB Group; workers or collaborators who supply goods or services or who carry out works for third
parties and carry out or have carried out their work at the VUB Group; freelancers and consultants who carry out or
have carried out their work at the Group; volunteers and trainees; shareholders (natural persons); persons with
administrative, control, supervisory or representative functions. The Policy includes queries by employees about
mobbing, bossing, sexual harassment and queries of third parties in connection with the procurement as well.
The Policy is disclosed and available to all persons who work in the VUB Group via intranet. Additionally, the
information about the reporting channel for potential whistleblowers is also disclosed on the VUB Bank's website.
The process of handling queries under Whistleblowing is overseen by the Designated person (a Management Board
Member), appointed by Management Board. The Ethics Committee (composed of Designated person, Head of
Human resources and additional independent Management Board Member) acts as a collective body. It makes
decision on resolution of queries based on results of investigations. Internal Audit (Whistleblowing Team) is
responsible for organizing, handling, and maintaining records of whistleblowing complaints.
Time periods for investigation and communication to whistleblower in compliance with the Act on Whistleblowing
is as follows:
–
Notice upon receiving report – within 7 days ‘acknowledgement of receipt’;
–
Feedback to whistleblower – within 90 days from acknowledgement of receipt; or
–
In the absence of such notice – within 90 days from expiry of 7 days from the submission of the report.
Whistleblowing allows the VUB Group’s employees and third parties to report violations using an e-mail
podnety@vub.sk
, with absolute conﬁdentiality. The VUB Group puts in place special safeguards to protect all those
involved. In particular, it ensures the conﬁdentiality of the information received and the identity of the whistleblower
and the identity of the person concerned, which is known only to those authorized to access the dedicated channels
and can only be revealed with his/her consent. It protects the whistleblower and concerned person from retaliatory
or discriminatory conduct, even if only attempted or threatened, resulting from the report.
Reporting violation through channels is available 24 hours a day (by e-mail or by post to the attention of the
Designated person and/or the VUB Bank’s Head of Internal Audit dept.). Apart from main dedicated e-mail channel
managed by Internal Audit, there are also in place backup channels in case of any conﬂict of interest (e.g. if a query
is concerning Head of Internal Audit or speciﬁc Management Board member). The whistleblower may also request
a personal meeting to make the report. Submission of anonymous report is also possible.
The subjects who manage the reports are the recipients of speciﬁc training initiatives on the subject.
Targets related to protection of whistleblowers
VUB Group has not set targets yet, as these are deﬁned, approved and monitored at the level of the parent company,
Intesa Sanpaolo, within the framework of the Group’s consolidated strategy and governance structure.
As a subsidiary, VUB Group aligns with these Group-level objectives, ensures their implementation in its operations,
and provides relevant performance data for the purpose of consolidated reporting. The applicable targets,
methodologies, and disclosures on progress are therefore included in the consolidated reporting published at the
ESRS G1 – Business Conduct
362
Intesa Sanpaolo Group level, of which VUB group forms part.
Actions related to protection of whistleblowers
The ISP and VUB Groups have adopted rules, procedures, and behaviours regarding internal reporting systems for
violations. Additionally, it conducts mandatory training on reporting potential violations. Furthermore, the VUB
Group manages the follow-up activities related to the reports and provides feedback within the established timelines,
ensuring the protection of the whistleblower from possible retaliation. Finally, although there is no precise deﬁnition
of quantitative targets within a speciﬁc time frame, the set of policies and actions implemented by the VUB Group
proves effective and aligned with the goal of protecting whistleblowers and handling reports efﬁciently.
In 2024, the VUB Bank’s Whistleblower policy was updated to ensure compliance with the Parent Company update
of Group Rules on Internal System for Reporting Violations (Whistleblowing). It was approved by Bank's Corporate
Bodies and implemented.
In 2025, 277 newcomers (including temporary workers) completed mandatory training on Whistleblowing policy.
Additionally, 3,166 employees completed the mandatory training on Ethical Code, which includes also section on
Whistleblowing policy.
2025
2024
newcomers which completed mandatory training on Whistleblowing policy (including
temporary workers)
277
437
employees which completed the mandatory training on Ethical Code
3,166
3,287
Policies, targets, actions and metrics related to management of relationships with suppliers
Policies related to management of relationships with suppliers
With regard to the strategy and actions related to supply chain management, the VUB Group highlights several
policies and rules that apply in a timely manner.
Through this Code of Ethics, the VUB Group aims to guide behaviours consistent with the highest international and
national ethical standards in the performance of its activities and in business management. The Code also includes
and recognizes sustainability principles as fundamental to guide the VUB Group strategy and have a positive impact
on the future of the planet and society, with the awareness that consideration of social and environmental issues
also contributes to minimizing exposure to risks and strengthening reputation, in line with the principles of
sustainable development and adhering to important international initiatives (for example, UN Global Compact).
The Internal Code of Conduct emphasizes the set of values and principles set out in the Code of Ethics aimed at
guiding the behaviour of the suppliers, as well as the ways in which the suppliers intend to pursue their mission in
compliance with legal and social obligations. It deﬁnes the standards of behaviour that the suppliers are required to
observe both in the workplace and externally, pursuing the interests of the VUB Group with professionalism,
diligence, honesty and fairness, acting in any case with transparency and in full respect for the dignity and integrity
of individuals. The exercise of decision-making powers and activities must, therefore, always be based on the values
and principles following traceability criteria.
The processing of invoices by the VUB Group is governed by the internal procedure Operational accounting. The
procedure, together with the principles deﬁned in Code of Ethics, ensures that all invoices are processed on-time
and without discriminating any supplier.
Targets related to management of relationships with suppliers
VUB Group has not set targets yet, as these are deﬁned, approved and monitored at the level of the parent company,
Intesa Sanpaolo, within the framework of the Group’s consolidated strategy and governance structure.
As a subsidiary, VUB Group aligns with these Group-level objectives, ensures their implementation in its operations,
and provides relevant performance data for the purpose of consolidated reporting. The applicable targets,
methodologies, and disclosures on progress are therefore included in the consolidated reporting published at the
Intesa Sanpaolo Group level, of which VUB group forms part.
Actions related to management of relationships with suppliers
The suppliers registered in the Intesa Sanpaolo Group's Supplier Register are also evaluated in relation to their ESG
propensity, thanks to the completion of a speciﬁc ESG questionnaire, established in 2022. During 2025, the mapping
of suppliers in terms of social, environmental and governance sustainability continued to strengthen the criteria for
evaluating and choosing the best suppliers. The completion of the questionnaire is mandatory for all new suppliers.
The ESG score, which results from the completion of the questionnaire and the possession of certain certiﬁcations
ESRS G1 – Business Conduct
363
in line with the ISP Group's criteria, expresses the quality of the supplier on ESG issues and can inﬂuence the choice
of the best suppliers, in relation to speciﬁc purchasing needs. It follows that, in relation to speciﬁc product categories
with a greater environmental or social impact, suppliers who do not comply with the minimum requirements may
be excluded from negotiation events.
For further information, reference is made to the standard ESRS E1 – Climate change, section Strategy for combating
climate change.
Metrics related to management of relationships with suppliers
During the 2025 ﬁnancial year, the VUB Group recorded a weighted average time of 10 days (2024: 16 days) for
the payment of invoices for which it is responsible. This ﬁgure represents the average number of days that have
elapsed from the start of the contractual or legal payment term until the actual settlement.
Absence of a single payment standard: for the VUB Group, the practice provides that payments are subject to
negotiation in the contract and, only where otherwise speciﬁed, the payment in 30 days is entered into the registry.
It should also be noted that during 2025 (same as in 2024), all payments were processed with full compliance with
contractual terms and as of 31/12/2025, the VUB Group was not involved in any legal proceedings concerning late
payments of invoices for which it is responsible.
It was considered appropriate to use a sample of internal bank accounting that processes the majority of the
operational agenda of incoming invoices. This sample was deemed representative of the VUB Group, covering most
of the volumes in terms of both the number and the amount of invoices.
Policies, objectives, actions and metrics related to political influence and lobbying activities
Policies related to political inﬂuence and lobbying activities
The VUB Group adheres to strict internal policies regarding corporate political engagement and institutional
relationships. As speciﬁed in the Anti-Corruption Guidelines, the VUB Group does not conduct its own lobbying
activities and maintains a neutral stance towards political parties, prohibiting any form of donations, sponsorships,
or ﬁnancial support to political entities.
While the VUB Group does not engage in lobbying, it monitors regulatory developments that could impact its
business operations. In this regard, the VUB Group ensures that its institutional relations remain transparent,
structured, and aligned with legal requirements. This approach is supported by internal policies that govern
interactions with regulatory bodies, supervisory authorities, and ﬁnancial market institutions.
The VUB Group represents its corporate interests and perspectives exclusively through ofﬁcial/recognized trade
associations (as a member), which are subject to appropriate internal rules. For example, the VUB Group participates
in consultations and initiatives within the Slovak Banking Association, ensuring that its engagement in regulatory
matters is conducted through ofﬁcial, transparent channels.
The monitoring of compliance with policies set is in responsibility of the Compliance and AML Department.
Targets related to political inﬂuence and lobbying activities
VUB Group has not set targets yet, as these are deﬁned, approved and monitored at the level of the parent company,
Intesa Sanpaolo, within the framework of the Group’s consolidated strategy and governance structure.
As a subsidiary, VUB Group aligns with these Group-level objectives, ensures their implementation in its operations,
and provides relevant performance data for the purpose of consolidated reporting. The applicable targets,
methodologies, and disclosures on progress are therefore included in the consolidated reporting published at the
Intesa Sanpaolo Group level, of which VUB group forms part.
Actions related to political inﬂuence and lobbying activities
The Bank plays a proactive role in regulatory processes, monitoring regulatory proposals (and, where appropriate,
actively participating in the related discussions through ofﬁcial associations, mainly within Slovak Banking
Association) for issues that may have direct and indirect repercussions for the Bank group, with reference to banking
and ﬁnancial regulations.
As mentioned in the previous section the Bank does not conduct its own lobbying activities. It should be noted that
the Bank represents and promotes its interests and opinions exclusively through ofﬁcial associations (as a member),
which are regulated by appropriate internal rules.
ESRS G1 – Business Conduct
364
Metrics related to political inﬂuence and lobbying activities
The Bank is not registered in the EU Transparency Register; however Intesa Sanpaolo Group is registered in the EU
Transparency Register, with registration identiﬁcation code 24037141789-48.
The Bank emphasizes that no members of administrative, management and supervisory bodies has held a position
in the public administration in the two years prior to taking up his current mandate, comparable to a position in
administrative, management and control bodies.
The Bank does not provide any kind of ﬁnancial or in-kind political contributions.
365
Disclosure requirements in ESRS
Disclosure requirement
Section
Page
General information
ESRS 2 General disclosure
ESRS 2 BP-1 – General basis for preparation of sustainability statements
Basis for preparation and methodology
244
ESRS 2 BP-2 – Disclosures in relation to specific circumstances
Basis for preparation and methodology (Time
horizons)
245
ESRS 2 GOV-1 – The role of the administrative, management and
supervisory bodies
Role and composition of the administrative,
management and supervisory bodies and the
governance of sustainability
266
ESRS 2 GOV-2 – Information provided to and sustainability matters
addressed by the undertaking’s administrative, management and
supervisory bodies
The governance of sustainability
270
ESRS 2 GOV-3 – Integration of sustainability-related performance in
incentive schemes
Integration of sustainability-related performance in
incentive schemes
273
ESRS 2 GOV-4 – Statement on due diligence
Statement on due diligence
247
ESRS 2 GOV-5 – Risk management and internal controls over sustainability
reporting
Risk management and internal controls over
sustainability reporting
275
ESRS 2 SBM-1 – Strategy, business model and value chain
Strategy, business model and value chain
247
ESRS 2 SBM-2 – Interests and views of stakeholders
Strategy, business model and value chain – Strategy
Engaging with the VUB Group's stakeholders
247
253
ESRS 2 SBM-3 – Material impacts, risks and opportunities and their
interaction with strategy and business model
Consolidating the list of material sustainability topics
for the VUB Group
259
ESRS 2 IRO-1 – Description of the processes to identify and assess material
impacts, risks and opportunities
Double materiality assessment
252
ESRS 2 IRO-2 – Disclosure requirements in ESRS covered by the
undertaking’s sustainability statement
List of datapoints in cross-cutting and topical
standards that derive from other EU legislation
371
Environmental information
Disclosures pursuant to Article 8 of Regulation (EU) 2020/85
Disclosures pursuant to Article 8 of Regulation (EU) +
Annex – Taxonomy Templates
278
375
E1 Climate change
ESRS 2 GOV-3 – Integration of sustainability-related performance in
incentive schemes
Integration of climate-related performance in
incentive schemes
285
E1-1 – Transition plan for climate change mitigation
GHG emissions reduction targets
288
ESRS 2 SBM-3 – Material impacts, risks and opportunities and their
interaction with strategy and business model
Materiality assessment process on impacts, risks and
opportunities related to climate change
281
ESRS 2 IRO-1 – Description of the processes to identify and assess material
climate-related impacts, risks and opportunities
Materiality assessment process on impacts, risks and
opportunities related to climate change
281
MDR-P – Policies adopted to manage material sustainability matters
E1-2 – Policies related to climate change mitigation and adaptation
Policies related to climate change mitigation and
adaptation
286
MDR-A – Actions and resources in relation to material sustainability matters
E1-3 – Actions and resources in relation to climate change policies
Actions and resources related to climate change
289
MDR-T – Tracking effectiveness of policies and actions through targets
GHG emissions reduction targets
288
E1-5 – Energy consumption and mix
Metrics on energy consumption
292
E1-6 – Gross Scopes 1, 2, 3 and Total GHG emissions
Metrics on GHG emissions
294
E2 Pollution
ESRS 2 IRO-1 – Description of the processes to identify and assess material
pollution-related impacts, risks and opportunities
Materiality assessment process on impacts, risks and
opportunities related to pollution
298
E3 Water and marine resources
Disclosure requirements in ESRS
366
Disclosure requirement
Section
Page
ESRS 2 IRO-1 – Description of the processes to identify and assess material
water and marine resources-related impacts, risks and opportunities
Materiality assessment process on impacts, risks and
opportunities related to water and marine resources
300
E4 Biodiversity and ecosystems
ESRS 2 IRO-1 – Description of processes to identify and assess material
biodiversity and ecosystem-related impacts, risks and opportunities
Materiality assessment process on impacts, risks and
opportunities related to biodiversity and ecosystems
302
E5 Resource use and circular economy
ESRS 2 IRO-1 – Description of the processes to identify and assess material
resource use and circular economy-related impacts, risks and opportunities
Materiality assessment process on impacts, risks and
opportunities related to resource use and circular
economy
304
MDR-P – Policies adopted to manage material sustainability matters
E5-1 – Policies related to resource use and circular economy
Policies related to resource use and circular economy
305
MDR-A – Actions and resources in relation to material sustainability matters
E5-2 – Actions and resources in relation to resource use and circular
economy
Actions related to resource use and circular economy
306
MDR-T – Tracking effectiveness of policies and actions through targets
Targets related to resource use and circular economy
306
Social information
S1 Own workforce
ESRS 2 SBM-2 – Interests and views of stakeholders
Strategy, business model and value chain – Strategy
Interests and views of stakeholders
247
253
ESRS 2 SBM-3 – Material impacts, risks and opportunities and their
interaction with strategy and business model
Materiality process on impacts, risks and
opportunities and their interaction with strategy and
business model
308
MDR-P – Policies adopted to manage material sustainability matters
S1-1 – Policies related to own workforce
VUB Group’s Commitment to Human Rights
Policies related to employment protection and labour
relations
Policies related to compensation
Policies related to DE&I
Policies related to equal pay
Policies related to training and development
Policies related to health and safety
Policies related to work-life balance
Policies related to working time
Policies related to privacy of VUB Group’s people
311
313
313
316
318
323
326
329
329
332
S1-2 – Processes for engaging with own workers and workers’
representatives about impacts
Working conditions – Engagement processes with
own workers and their representatives
Diversity, Equity and Inclusion (DE&I) – Engagement
processes with own workers and their
representatives
Training and skill development – Engagement
processes with own workers and their
representatives
Health and safety – Engagement processes with own
workers and their representatives
Work-life balance and working time– Engagement
processes with own workers and their
representatives
Privacy of the VUB Group’s people – Engagement
processes with own workers and their
representatives
315
320
324
327
330
333
S1-3 – Processes to remediate negative impacts and channels for own
workers to raise concerns
Working conditions – Remediation processes with
own workers and their representatives and channels
to raise concerns
Diversity, Equity and Inclusion (DE&I) – Remediation
processes with own workers and their
representatives and channels to raise concerns
Health and safety – Remediation processes with own
workers and their representatives and channels to
raise concerns
315
320
327
331
Disclosure requirements in ESRS
367
Disclosure requirement
Section
Page
Work-life balance and working time – Remediation
processes with own workers and their
representatives and channels to raise concerns
Privacy of the VUB Group’s people – Remediation
processes with own workers and their
representatives and channels to raise concerns
334
MDR-A – Actions and resources in relation to material sustainability matters
S1-4 – Taking action on material impacts on own workforce, and
approaches to mitigating material risks and pursuing material opportunities
related to own workforce, and effectiveness of those actions
Actions related to employment protection and
labour relations
Actions related to diversity, equity and inclusion
Actions related to the inclusion of people with
disabilities
Actions related to training and development of VUB
Group’s people
Actions related to health and safety
Actions related to work-life balance
Actions related to privacy of VUB Group’s people
316
321
322
324
327
331
335
MDR-T – Tracking effectiveness of policies and actions through targets
Targets related to employment protection
Targets related to diversity, equity and inclusion
Targets and metrics related to the development of
the VUB Group's people and talent management
Targets related to health and safety
Targets related to work-life balance and working
hours
Targets related to privacy of VUB Group's people
315
321
324
327
331
334
S1-6 – Characteristics of the undertaking’s employees
Characteristics and composition of the VUB Group’s
employees
310
S1-8 – Collective bargaining coverage and social dialogue
Metrics related to collective bargaining and social
dialogue
315
S1-9 – Diversity metrics
Metrics related to diversity by gender and age
318
S1-10 – Adequate wages
Metrics related to adequate wages
315
S1-14 – Health and safety metrics
Metrics related to health and safety
328
S1-16 – Compensation metrics (pay gap and total compensation)
Metrics related to equal pay and remuneration
319
S1-17 – Incidents, complaints and severe human rights impacts
Human rights metrics in the workforce
312
S3 Affected communities
ESRS 2 SBM-2 – Interests and views of stakeholders
Materiality process on impacts, risks and
opportunities and their interaction with strategy and
business model
336
ESRS 2 SBM-3 – Material impacts, risks and opportunities and their
interaction with strategy and business model
Materiality process on impacts, risks and
opportunities and their interaction with strategy and
business model
336
MDR-P – Policies adopted to manage material sustainability matters
S3-1 – Policies related to affected communities
Policies related to communities affected by own
operations
337
S3-2 – Processes for engaging with affected communities about impacts
Engagement processes with affected communities
338
S3-3 – Processes to remediate negative impacts and channels for affected
communities to raise concerns
Engagement processes with affected communities
338
MDR-A – Actions and resources in relation to material sustainability matters
S3-4 – Taking action on material impacts on affected communities, and
approaches to managing material risks and pursuing material opportunities
related to affected communities, and effectiveness of those actions
Actions related to communities affected by own
operations
339
MDR-T – Tracking effectiveness of policies and actions through targets
Targets related to communities affected by own
operations
339
S4 Consumers and end-users
ESRS 2 SBM-2 – Interests and views of stakeholders
Materiality process on impacts, risks and
opportunities and their interaction with strategy and
business model
341
ESRS 2 SBM-3 Material impacts, risks and opportunities and their
interaction with strategy and business model
Materiality process on impacts, risks and
opportunities and their interaction with strategy and
business model
341
Disclosure requirements in ESRS
368
Disclosure requirement
Section
Page
MDR-P – Policies adopted to manage material sustainability matters
S4-1 – Policies related to consumers and end-users
The Group's commitment to human rights
Policies related to Access to (quality) information and
Freedom of expression
Policies related to Privacy
Policies related to Health and safety (including
security of a person)
Policies related to products and services, Non-
discrimination and Responsible marketing practices
342
343
346
350
351
S4-2 – Processes for engaging with consumers and end-users about impacts
Freedom of expression – Customer engagement
processes
Privacy – Customer engagement processes
Health and safety (including security of a person) –
Customer engagement processes, Remediation
processes and channels to raise concerns
Access to products and services, Non-discrimination
and Responsible marketing practices – Customer
engagement processes
343
347
350
352
S4-3 – Processes to remediate negative impacts and channels for consumers
and end-users to raise concerns
Freedom of expression – Remediation processes and
channels to raise concerns
Privacy – Remediation processes and channels to
raise concerns
Health and safety (including security of a person) –
Customer engagement processes, Remediation
processes and channels to raise concerns
Access to products and services, Non-discrimination
and Responsible marketing practices – Remediation
processes and channels to raise concerns
344
347
350
352
MDR-A – Actions and resources in relation to material sustainability matters
S4-4 – Taking action on material impacts on consumers and end-users, and
approaches to managing material risks and pursuing material opportunities
related to consumers and end- users, and effectiveness of those actions
Actions related to Access to (quality) information and
Freedom of expression
Actions related to Privacy
Actions related to Health and safety (including
security of a person)
Actions related to Access to products and services,
Non-discrimination and Responsible marketing
practices
345
348
350
353
MDR-T – Tracking effectiveness of policies and actions through targets
Targets related to Access to (quality) information and
Freedom of expression
Targets related to Privacy
Targets related to Health and safety (including
security of a person)
Targets related to Access to products and services,
Non-discrimination and Responsible marketing
practices
344
348
350
352
Governance information
G1 Business conduct
ESRS 2 GOV-1 – The role of the administrative, supervisory and
management bodies
Policies related to corporate culture
357
ESRS 2 IRO-1 – Description of the processes to identify and assess material
impacts, risks and opportunities
Materiality assessment process on impacts, risks and
opportunities related to business conduct matters
355
MDR-P – Policies adopted to manage material sustainability matters
G1-1 – Business conduct policies and corporate culture
Policies related to corporate culture
Policies related to the prevention of corruption and
bribery
Policies related to protection of whistleblowers
Policies related to management of relationships with
suppliers
Policies related to political influence and lobbying
activities
357
358
361
362
363
G1-2 – Management of relationships with suppliers
Policies related to management of relationships with
suppliers
362
MDR-A – Actions and resources in relation to material sustainability matters
Actions related to corporate culture
Actions related to the prevention of corruption and
bribery
Actions related to protection of whistleblowers
Actions related to management of relationships with
suppliers
Actions related to political influence and lobbying
activities
357
360
362
362
363
Disclosure requirements in ESRS
369
Disclosure requirement
Section
Page
G1-3 – Prevention and detection of corruption and bribery
Actions related to the prevention of corruption and
bribery
360
MDR-T – Tracking effectiveness of policies and actions through targets
Targets related to corporate culture
Targets related to the prevention of corruption and
bribery
Targets related to protection of whistleblowers
Targets related to management of relationships
with suppliers
Targets related to political influence and lobbying
activities
357
359
361
362
363
G1-4 – Confirmed incidents of corruption or bribery
Metrics related to the prevention of corruption and
bribery
361
G1-5 – Political influence and lobbying activities
Metrics related to political influence and lobbying
activities
364
G1-6 – Payment practices
Metrics related to management of relationships with
suppliers
363
Disclosure requirements in ESRS
370
Entity-specific disclosures
Chapter
Page
No. of people completed mandatory internal trainings
S1 – Own Workforce – Actions related to training and
development of VUB Group’s people
324
No. of branches
S4 – Consumers and end-users – Metrics related to
Access to (quality) information and Freedom of
expression – Number of branches
345
Average days/response time to customer complaints: Investment
products and services / Insurance products and services/Payment
services/Ordinary services
S4 – Consumers and end-users – Metrics related to
Access to (quality) information and Freedom of
expression – Response to customer complaints
345
€/million fraudulent transactions blocked
S4 – Consumers and end-users – Metrics related to
Privacy (Fraud prevention)
349
No. of reported cases of customer data loss or theft
S4 – Consumers and end-users – Metrics related to
Privacy
349
Social sustainability financing: Retail
S4 – Consumers and end-users – Metrics related to
Access to products and services, Non-discrimination
and Responsible marketing practices
354
Social sustainability financing: Corporate
S4 – Consumers and end-users – Metrics related to
Access to products and services, Non-discrimination
and Responsible marketing practices
354
‘Other sustainability’ financing: Corporate
S4 – Consumers and end-users – Metrics related to
Access to products and services, Non-discrimination
and Responsible marketing practices
354
Environmental sustainability financing: Retail
E1 – Climate Change – Climate change actions and
resources at the portfolio level
S4 – Consumers and end-users – Metrics related to
Access to products and services, Non-discrimination
and Responsible marketing practices
290
354
Environmental sustainability financing: Corporate
E1 – Climate Change – Climate change actions and
resources at the portfolio level
S4 – Consumers and end-users – Metrics related to
Access to products and services, Non-discrimination
and Responsible marketing practices
290
354
371
List of datapoints in cross-cutting and topical
standards that derive from other EU legislation
Disclosure Requirement and related datapoint
SFDR
17
Pillar 3
18
Benchmark
Regulation
19
EU Climate
Law
20
Page
ESRS 2 GOV-1
Board's gender diversity paragraph 21 (d)
x
x
267
ESRS 2 GOV-1
Percentage of board members who are independent
paragraph 21 (e)
x
267
ESRS 2 GOV-4
Statement on due diligence paragraph 30
x
247
ESRS 2 SBM-1
Involvement in activities related to fossil fuel activities
paragraph 40 (d) i
x
x
x
250
ESRS 2 SBM-1
Involvement in activities related to chemical
production paragraph 40 (d) ii
x
x
250
ESRS 2 SBM-1
Involvement in activities related to controversial
weapons paragraph 40 (d) iii
x
x
250
ESRS 2 SBM-1
Involvement in activities related to cultivation and
production of tobacco paragraph 40 (d) iv
x
250
ESRS E1-1
Transition plan to reach climate neutrality by 2050
paragraph 14
x
No transition
plan yet
ESRS E1-1
Undertakings excluded from Paris-aligned Benchmarks
paragraph 16 (g)
x
x
No transition
plan yet
ESRS E1-4
GHG emission reduction targets paragraph 34
x
x
x
288
ESRS E1-5
Energy consumption from fossil sources disaggregated
by sources (only high climate impact sectors)
paragraph 38
x
293
ESRS E1-5 Energy consumption and mix paragraph 37
x
293
ESRS E1-5
Energy intensity associated with activities in high
climate impact sectors paragraphs 40 to 43
x
293
ESRS E1-6
Gross Scope 1, 2, 3 and Total GHG emissions
paragraph 44
x
x
x
294
ESRS E1-6
Gross GHG emissions intensity paragraphs 53 to 55
x
x
x
297
ESRS E1-7
GHG removals and carbon credits paragraph 56
x
Non-material
ESRS E1-9
Exposure of the benchmark portfolio to climate-
related physical risks paragraph 66
x
Unreported
information
for 2025
ESRS E1-9
Disaggregation of monetary amounts by acute and
chronic physical risk paragraph 66 (a)
x
Unreported
information
for 2025
17
Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability-related disclosures in the
ﬁnancial services sector (Sustainable Finance Disclosures Regulation) (OJ L 317, 9.12.2019, p. 1).
18
Regulation (EU) No 575/2013 of the European Parliament and of the Council of 26 June 2013on prudential requirements for credit institutions
and investment ﬁrms and amending Regulation (EU) No 648/2012 (Capital Requirements Regulation ‘CRR’) (OJ L 176, 27.6.2013, p. 1).
19
Regulation (EU) 2016/1011 of the European Parliament and of the Council of 8 June 2016on indices used as benchmarks in ﬁnancial instruments
and ﬁnancial contracts or to measure the performance of investment funds and amending Directives 2008/48/EC and 2014/17/EU and Regulation
(EU) No 596/2014 (OJ L 171, 29.6.2016, p. 1).
20
Regulation (EU) 2021/1119 of the European Parliament and of the Council of 30 June 2021establishing the framework for achieving climate
neutrality and amending Regulations (EC) No 401/2009 and (EU) 2018/1999 (‘European Climate Law’) (OJ L 243, 9.7.2021, p. 1).
List of datapoints in cross-cutting and topical standards that derive from other EU legislation
372
Disclosure Requirement and related datapoint
SFDR
17
Pillar 3
18
Benchmark
Regulation
19
EU Climate
Law
20
Page
ESRS E1-9
Location of significant assets at material physical risk
paragraph 66 (c)
x
Unreported
information
for 2025
ESRS E1-9 Breakdown of the carrying value of its real
estate assets by energy-efficiency classes paragraph 67
(c)
x
Unreported
information
for 2025
ESRS E1-9
Degree of exposure of the portfolio to climate- related
opportunities paragraph 69
x
Unreported
information
for 2025
ESRS E2-4
Amount of each pollutant listed in Annex II of the E-
PRTR Regulation (European Pollutant Release and
Transfer Register) emitted to air, water and soil,
paragraph 28
x
Non-material
ESRS E3-1
Water and marine resources paragraph 9
x
Non-material
ESRS E3-1
Dedicated policy paragraph 13
x
Non-material
ESRS E3-1
Sustainable oceans and seas paragraph 14
x
Non-material
ESRS E3-4
Total water recycled and reused paragraph 28 (c)
x
Non-material
ESRS E3-4
Total water consumption in m3 per net revenue on
own operations paragraph 29
x
Non-material
ESRS 2 – SBM 3 – E4 paragraph 16 (a) i
x
Non-material
ESRS 2 – SBM 3 – E4 paragraph 16 (b)
x
Non-material
ESRS 2 – SBM 3 – E4 paragraph 16 (c)
x
Non-material
ESRS E4-2
Sustainable land / agriculture practices or policies
paragraph 24 (b)
x
Non-material
ESRS E4-2
Sustainable oceans / seas practices or policies
paragraph 24 (c)
x
Non-material
ESRS E4-2
Policies to address deforestation paragraph 24 (d)
x
Non-material
ESRS E5-5
Non-recycled waste paragraph 37 (d)
x
Non-material
ESRS E5-5
Hazardous waste and radioactive waste paragraph 39
x
Non-material
ESRS 2- SBM3 – S1
Risk of incidents of forced labour paragraph 14 (f)
x
Non-material
ESRS 2- SBM3 – S1
Risk of incidents of child labour paragraph 14 (g)
x
Non-material
ESRS S1-1
Human rights policy commitments paragraph 20
x
311
ESRS S1-1
Due diligence policies on issues addressed by the
fundamental International Labor Organisation
Conventions 1 to 8, paragraph 21
x
313
ESRS S1-1
processes and measures for preventing trafficking in
human beings paragraph 22
x
Non-material
ESRS S1-1
workplace accident prevention policy or management
system paragraph 23
x
326
ESRS S1-3
grievance/complaints handling mechanisms paragraph
32 (c)
x
312
331
ESRS S1-14
Number of fatalities and number and rate of work-
related accidents paragraph 88 (b) and (c)
x
x
328
List of datapoints in cross-cutting and topical standards that derive from other EU legislation
373
Disclosure Requirement and related datapoint
SFDR
17
Pillar 3
18
Benchmark
Regulation
19
EU Climate
Law
20
Page
ESRS S1-14
Number of days lost to injuries, accidents, fatalities or
illness paragraph 88 (e)
x
Unreported
information
for 2025
ESRS S1-16
Unadjusted gender pay gap paragraph 97 (a)
x
x
319
ESRS S1-16
Excessive CEO pay ratio paragraph 97 (b)
x
319
ESRS S1-17
Incidents of discrimination paragraph 103 (a)
x
312
ESRS S1-17 Non-respect of UNGPs on Business and
Human Rights and OECD paragraph 104 (a)
x
x
312
ESRS 2- SBM3 – S2
Significant risk of child labour or forced labour in the
value chain paragraph 11 (b)
x
Non-material
ESRS S2-1
Human rights policy commitments paragraph 17
x
Non-material
ESRS S2-1 Policies related to value chain workers
paragraph 18
x
Non-material
ESRS S2-1Non-respect of UNGPs on Business and
Human Rights principles and OECD guidelines
paragraph 19
x
x
Non-material
ESRS S2-1
Due diligence policies on issues addressed by the
fundamental International Labor Organisation
Conventions 1 to 8, paragraph 19
x
Non-material
ESRS S2-4
Human rights issues and incidents connected to its
upstream and downstream value chain paragraph 36
x
Non-material
ESRS S3-1
Human rights policy commitments paragraph 16
x
338
ESRS S3-1
non-respect of UNGPs on Business and Human Rights,
ILO principles or and OECD guidelines paragraph 17
x
x
338
ESRS S3-4
Human rights issues and incidents paragraph 36
x
338
ESRS S4-1 Policies related to consumers and end-users
paragraph 16
x
342
ESRS S4-1
Non-respect of UNGPs on Business and Human Rights
and OECD guidelines paragraph 17
x
x
342
ESRS S4-4
Human rights issues and incidents paragraph 35
x
342
ESRS G1-1
United Nations Convention against Corruption
paragraph 10 (b)
x
358
ESRS G1-1
Protection of whistle-blowers paragraph 10 (d)
x
361
ESRS G1-4
Fines for violation of anti-corruption and anti-bribery
laws paragraph 24 (a)
x
x
361
ESRS G1-4
Standards of anti-corruption and anti-bribery
paragraph 24 (b)
x
358
374
Annexes
375
Annex – Taxonomy templates
Template for the KPIs of credit institutions
Annex – Taxonomy templates
376
Template 1: Assets for the calculation of GAR stock (Turnover)
Stock in Million EUR
Total
[gross]
carrying
amount
Of which
Taxonomy-
eligible
Of which
Taxonomy-
aligned
Substantial contribution to environmental objectives
Of which
Use of
Proceeds
Of which
transitional
Of which
enabling
Non-
assessed
exposures
Of which
financing
nonmaterial
activities of
counterparties
(4)
Of which
exposures
financing
counterparties
reporting in
accordance
with Article
7(9)
Of which not
assessed
considered non-
material by the
credit institution
(5)
Climate
Change
Mitigation
(CCM)
Climate
Change
Adaptation
(CCA)
Water
and
marine
resources
(WTR)
Circular
economy
(CE)
Pollution
(PPC)
Biodiversity
and
Ecosystems
(BIO)
1
GAR - Covered assets in both numerator and denominator
2
Loans and advances, debt securities and equity instruments not HfT
eligible for GAR
calculation
15,455
11,680
1,766
1,677
89
-
-
-
-
1,434
136
137
387
-
-
387
3
Financial undertakings
1,149
593
68
68
-
-
-
-
-
-
4
49
-
-
-
-
4
Loans and advances
867
552
55
55
-
-
-
-
-
-
1
44
-
-
-
-
5
Debt securities, including UoP
282
40
13
13
-
-
-
-
-
-
4
5
-
-
-
-
6
Equity instruments
1
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
7
Non-financial undertakings
1,948
1,044
263
174
89
-
-
-
-
-
131
88
-
-
-
8
Loans and advances
1,440
627
207
147
60
-
-
-
-
-
104
70
-
-
-
9
Debt securities, including UoP
508
417
56
27
29
-
-
-
-
-
27
18
-
-
-
10
Equity instruments
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
11
Households
12,128
10,043
1,434
1,434
-
-
1,434
-
-
158
-
158
12
of which loans collateralised by residential immovable property
10,001
10,001
1,434
1,434
-
-
1,434
-
-
-
-
-
13
of which building renovation loans
43
43
-
-
-
-
-
-
-
-
-
-
14
of which motor vehicle loans
158
-
-
-
-
-
-
-
158
-
158
15
Local governments financing
230
-
-
-
-
-
-
-
-
-
-
-
230
-
230
16
Housing financing
-
-
-
-
-
-
-
-
-
-
-
-
17
Other local government financing
230
-
-
-
-
-
-
-
-
-
-
-
230
-
230
18
Collateral obtained by taking possession: residential and commercial immovable properties
-
-
-
-
-
-
-
-
-
-
-
-
19
Exposures included on a volutary basis
-
-
-
-
-
-
-
-
-
-
-
20
Total GAR assets
15,455
387
387
21
Assets not covered for GAR calculation
11,232
22
Central governments and Supranational issuers
3,067
23
Central banks exposure
1,820
24
Trading book
164
25
Undertaking and entities not subject to CSRD
5,327
26
SMEs and undertakings (other than SMEs) not subject to CSRD disclosure obligations
4,627
27
Loans and advances
4,576
28
of which loans collateralised by commercial immovable property
1,083
29
of which building renovation loans
49
30
Debt securities
51
31
Equity instruments
-
32
Non-EU country counterparties not subject to CSRD disclosure
obligations
350
33
Loans and advances
350
34
Debt securities
-
35
Equity instruments
-
36
Derivatives
89
37
On demand interbank loans
42
38
Cash and cash-related assets
288
39
Other categories of assets (e.g. Goodwill, commodities etc.)
435
40
Total assets
26,687
Off-balance sheet exposures (stock) to Undertakings subject to CSRD disclosure obligations and local governments
41
Financial guarantees
455
115
35
35
-
-
-
-
-
-
6
20
-
-
-
-
42
Assets under management
409
173
32
31
-
-
1
-
-
-
5
18
-
-
-
-
43
Of which debt securities
116
35
12
12
-
-
-
-
-
-
4
6
-
-
-
-
44
Of which equity instruments
293
138
20
18
-
-
1
-
-
-
1
13
-
-
-
-
Annex – Taxonomy templates
377
Template 1: Assets for the calculation of GAR stock (CapEx)
Total
[gross]
carrying
amount
Of which
Taxonomy-
eligible
Of which
Taxonomy-
aligned
Substantial contribution to environmental objectives
Of
which
Use of
Proceeds
Of which
transitional
Of which
enabling
Non-
assessed
exposures
Of which
financing
nonmaterial
activities of
counterparties
(4)
Of which
exposures
financing
counterparties
reporting in
accordance with
Article 7(9)
Of which not
assessed
considered
non-material by
the credit
institution (5)
Climate
Change
Mitigation
(CCM)
Climate
Change
Adaptation
(CCA)
Water
and
marine
resources
(WTR)
Circular
economy
(CE)
Pollution
(PPC)
Biodiversity and
Ecosystems (BIO)
1
GAR - Covered assets in both numerator and denominator
2
Loans and advances, debt securities and equity instruments not HfT eligible for GAR calculation
15,455
11,992
1,938
1,904
34
-
-
-
-
1,434
85
314
387
-
-
387
3
Financial undertakings
1,149
608
145
144
-
-
-
-
-
-
2
118
-
-
-
-
4
Loans and advances
867
573
135
135
-
-
-
-
-
-
1
113
-
-
-
-
5
Debt securities, including UoP
282
35
10
10
-
-
-
-
-
-
2
4
-
-
-
-
6
Equity instruments
1
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
7
Non-financial undertakings
1,948
1,340
359
325
34
-
-
-
-
-
83
197
-
-
-
-
8
Loans and advances
1,440
880
276
253
24
-
-
-
-
-
83
129
-
-
-
-
9
Debt securities, including UoP
508
460
83
72
11
-
-
-
-
-
-
67
-
-
-
-
10
Equity instruments
0
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
11
Households
12,128
10,043
1,434
1,434
-
-
1,434
-
-
158
-
-
158
12
of which loans collateralised by residential immovable property
10,001
10,001
1,434
1,434
-
-
1,434
-
-
-
-
-
-
13
of which building renovation loans
43
43
-
-
-
-
-
-
-
-
-
-
-
14
of which motor vehicle loans
158
-
-
-
-
-
-
158
-
-
158
15
Local governments financing
230
-
-
-
-
-
-
-
-
-
-
-
230
-
-
230
16
Housing financing
0
-
-
-
-
-
-
-
-
-
-
-
-
17
Other local government financing
230
-
-
-
-
-
-
-
-
-
-
-
230
-
-
230
18
Collateral obtained by taking possession: residential and commercial
immovable properties
0
-
-
-
-
-
-
-
-
-
-
-
-
19
Exposures included on a volutary basis
0
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
20
Total GAR assets
15,455
-
-
-
-
-
-
-
-
-
-
-
387
-
-
387
21
Assets not covered for GAR calculation
11,232
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
22
Central governments and Supranational issuers
3,067
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
23
Central banks exposure
1,820
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
24
Trading book
164
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
25
Undertaking and entities not subject to CSRD
5,327
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
26
SMEs and undertakings (other than SMEs) not subject to CSRD disclosure obligations
4,627
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
27
Loans and advances
4,576
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
28
of which loans collateralised by commercial immovable property
1,083
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
29
of which building renovation loans
49
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
30
Debt securities
51
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
31
Equity instruments
0
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
32
Non-EU country counterparties not subject to CSRD disclosure
obligations
350
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
33
Loans and advances
350
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
34
Debt securities
0
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
35
Equity instruments
0
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
36
Derivatives
89
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
37
On demand interbank loans
42
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
38
Cash and cash-related assets
288
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
39
Other categories of assets (e.g. Goodwill, commodities etc.)
435
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
40
Total assets
26,687
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
Off-balance sheet exposures (stock) to Undertakings subject to CSRD disclosure obligations and local governments
0
0
-
-
-
-
-
-
41
Financial guarantees
455
121
48
45
-
-
2
-
-
-
10
13
-
-
-
-
42
Assets under management
409
180
56
55
-
-
1
-
-
-
8
29
-
-
-
-
43
of which debt securities
116
47
23
23
-
-
-
-
-
-
6
12
-
-
-
-
44
of which equity instruments
293
133
33
32
-
-
1
-
-
-
2
17
-
-
-
-
Annex – Taxonomy templates
378
1.
The following accounting categories of ﬁnancial assets shall be taken into account: ﬁnancial assets at amortised cost, ﬁnancial assets at fair value through other comprehensive income, investments in subsidiaries, joint ventures and associates, ﬁnancial assets designated at fair value through
proﬁt or loss and non-trading ﬁnancial assets mandatorily measured at fair value through proﬁt or loss and real estate acquired by credit institutions by taking ownership in exchange for debt cancellation.
2.
Credit institutions shall duplicate this template for reporting stocks for the calculation of the GAR indicator (stock), and for reporting new assets for the calculation of the GAR ﬂow.
3.
Credit institutions shall duplicate this template for turnover-based and capital expenditure-based (CapEx) statements.
4.
in accordance with Article 7(8)(a) and (b) of this Regulation
5.
in accordance with Article 4(8)(a) and (b) of this Regulation 1a of this Regulation
6.
in accordance with Article 7(3) of this Regulation
Annex – Taxonomy templates
379
Template 1: Assets for the calculation of GAR ﬂow (Turnover)
Flow in Million EUR
Total
[gross]
carrying
amount
Of which
Taxonomy-
eligible
Of which
Taxonomy-
aligned
Substantial contribution to environmental objectives
Of which
Use of
Proceeds
Of which
transitional
Of which
enabling
Non-
assessed
exposures
Of which
financing
nonmaterial
activities of
counterparties
(4)
Of which
exposures
financing
counterparties
reporting in
accordance
with Article 7(9)
Of which
not
assessed
considered
non-
material by
the credit
institution
(5)
Climate
Change
Mitigation
(CCM)
Climate
Change
Adaptation
(CCA)
Water
and
marine
resources
(WTR)
Circular
economy
(CE)
Pollution
(PPC)
Biodiversity
and
Ecosystems
(BIO)
1
GAR - Covered assets in both numerator and denominator
2
Loans and advances, debt securities and equity instruments not HfT eligible for GAR calculation
3,666
2,139
232
208
24
-
-
-
-
82
98
24
109
-
-
109
3
Financial undertakings
115
40
19
19
-
-
-
-
-
-
-
5
-
-
-
-
4
Loans and advances
77
18
1
1
-
-
-
-
-
-
-
-
-
-
-
-
5
Debt securities, including UoP
38
22
18
18
-
-
-
-
-
-
-
5
-
-
-
-
6
Equity instruments
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
7
Non-financial undertakings
813
302
132
107
24
-
-
-
-
-
98
19
-
-
-
-
8
Loans and advances
642
200
121
97
24
-
-
-
-
-
98
8
-
-
-
-
9
Debt securities, including UoP
172
102
11
11
-
-
-
-
-
-
-
11
-
-
-
-
10
Equity instruments
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
11
Households
2,693
1,797
82
82
-
-
-
-
-
82
-
-
65
-
-
65
12
of which loans collateralised by residential immovable property
1,792
1,792
82
82
-
-
-
-
-
82
-
-
-
-
-
-
13
of which building renovation loans
5
5
-
-
-
-
-
-
-
-
-
-
-
-
-
-
14
of which motor vehicle loans
65
-
-
-
-
-
-
-
-
-
-
-
65
-
-
65
15
Local governments financing
45
-
-
-
-
-
-
-
-
-
-
-
45
-
-
45
16
Housing financing
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
17
Other local government financing
45
-
-
-
-
-
-
-
-
-
-
-
45
-
-
45
18
Collateral obtained by taking possession: residential and commercial immovable
properties
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
19
Exposures included on a voluntary basis
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
20
Total GAR assets
3,666
-
-
-
-
-
-
-
-
-
-
-
109
-
-
109
21
Assets not covered for GAR calculation
19,301
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
22
Central governments and Supranational issuers
1,592
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
23
Central banks exposure
15,363
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
24
Trading book
11
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
25
Undertaking and entities not subject to CSRD
2,320
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
26
SMEs and undertakings (other than SMEs) not subject to CSRD disclosure
obligations
2,059
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
27
Loans and advances
2,021
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
28
of which loans collateralised by commercial immovable property
29
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
29
of which building renovation loans
20
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
30
Debt securities
37
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
31
Equity instruments
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
32
Non-EU country counterparties not subject to CSRD disclosure
obligations
13
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
33
Loans and advances
13
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
34
Debt securities
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
35
Equity instruments
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
36
Derivatives
13
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
37
On demand interbank loans
1
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
38
Cash and cash-related assets
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
39
Other categories of assets (e.g. Goodwill, commodities etc.)
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
40
Total assets
22,967
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
Off-balance sheet exposures (stock) to Undertakings subject to CSRD disclosure obligations and local governments
41
Financial guarantees
85
32
10
10
-
-
-
-
-
-
1
7
-
-
-
-
42
Assets under management
127
56
19
13
5
-
-
-
-
57
13
-
-
-
-
-
43
Of which debt securities
38
19
9
7
2
-
-
-
-
15
7
-
-
-
-
-
44
Of which equity instruments
89
37
10
6
4
-
-
-
-
42
6
-
-
-
-
-
Note 1. The following accounting categories of ﬁnancial assets should be considered: Financial assets at amortised cost, ﬁnancial assets at fair value through other comprehensive income, investments in subsidiaries, joint ventures and associates, ﬁnancial assets designated at fair value through
proﬁt or loss and non-trading ﬁnancial assets mandatorily at fair value through proﬁt or loss, and real estate collaterals obtained by credit institutions by taking possession in exchange in of cancellation of debts. Credit institutions shall duplicate this template for reporting on stocks for the
calculation of GAR stock, and reporting on new assets for the calculation of GAR ﬂow. Credit institutions shall duplicate this template for turnover based and CapEx based disclosures.
Annex – Taxonomy templates
380
4. in accordance with Article 7(8)(a) and (b) of this Regulation
5. in accordance with Article 4(1a) of this Regulation
Annex – Taxonomy templates
381
Template 1: Assets for the calculation of GAR Flow (CapEx)
Flow Million EUR
Total
[gross]
carrying
amount
Of which
Taxonomy-
eligible
Of which
Taxonomy-
aligned
Substantial contribution to environmental objectives
Of which
Use of
Proceeds
Of which
transitional
Of which
enabling
Non-
assessed
exposures
Of which
financing
nonmaterial
activities of
counterparties
(4)
Of which
exposures
financing
counterparties
reporting in
accordance
with Article 7(9)
Of which
not
assessed
considered
non-
material by
the credit
institution
(5)
Climate
Change
Mitigation
(CCM)
Climate
Change
Adaptation
(CCA)
Water
and
marine
resources
(WTR)
Circular
economy
(CE)
Pollution
(PPC)
Biodiversity
and
Ecosystems
(BIO)
1
GAR - Covered assets in both numerator and denominator
2
Loans and advances, debt securities and equity instruments not HfT eligible for GAR calculation
3,666
2,261
301
275
26
-
-
-
-
82
137
40
109
-
-
109
3
Financial undertakings
115
49
30
30
-
-
-
-
-
-
-
2
-
-
-
-
4
Loans and advances
77
19
2
2
-
-
-
-
-
-
-
1
-
-
-
-
5
Debt securities, including UoP
38
31
28
28
-
-
-
-
-
-
-
1
-
-
-
-
6
Equity instruments
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
7
Non-financial undertakings
813
416
189
163
26
-
-
-
-
-
137
38
-
-
-
-
8
Loans and advances
642
319
158
132
26
-
-
-
-
-
137
7
-
-
-
-
9
Debt securities, including UoP
172
97
31
31
-
-
-
-
-
-
-
31
-
-
-
-
10
Equity instruments
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
11
Households
2,693
1,797
82
82
-
-
-
-
-
82
-
-
65
-
-
65
12
of which loans collateralised by residential immovable property
1,792
1,792
82
82
-
-
-
-
-
82
-
-
-
-
-
-
13
of which building renovation loans
5
5
-
-
-
-
-
-
-
-
-
-
-
-
-
-
14
of which motor vehicle loans
65
-
-
-
-
-
-
-
-
-
-
-
65
-
-
65
15
Local governments financing
45
-
-
-
-
-
-
-
-
-
-
-
45
-
-
45
16
Housing financing
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
17
Other local government financing
45
-
-
-
-
-
-
-
-
-
-
-
45
-
-
45
18
Collateral obtained by taking possession: residential and commercial immovable properties
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
19
Exposures included on a volutary basis
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
20
Total GAR assets
3,666
-
-
-
-
-
-
-
-
-
-
-
109
-
-
109
21
Assets not covered for GAR calculation
19,301
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
22
Central governments and Supranational issuers
1,592
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
23
Central banks exposure
15,363
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
24
Trading book
11
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
25
Undertaking and entities not subject to CSRD
2,320
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
26
SMEs and undertakings (other than SMEs) not subject to CSRD disclosure obligations
2,059
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
27
Loans and advances
2,021
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
28
of which loans collateralised by commercial immovable property
29
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
29
of which building renovation loans
20
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
30
Debt securities
37
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
31
Equity instruments
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
32
Non-EU country counterparties not subject to CSRD disclosure
obligations
13
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
33
Loans and advances
13
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
34
Debt securities
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
35
Equity instruments
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
36
Derivatives
13
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
37
On demand interbank loans
1
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
38
Cash and cash-related assets
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
39
Other categories of assets (e.g. Goodwill, commodities etc.)
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
40
Total assets
22,967
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
Off-balance sheet exposures (stock) to Undertakings subject to CSRD disclosure obligations and local governments
41
Financial guarantees
85
27
12
12
-
-
-
-
-
-
1
4
-
-
-
-
42
Assets under management
127
61
25
18
7
-
-
-
-
56
18
-
-
-
-
-
43
Of which debt securities
38
21
10
8
2
-
-
-
-
16
8
-
-
-
-
-
44
Of which equity instruments
89
40
15
10
5
-
-
-
-
41
10
-
-
-
-
-
1. The following accounting categories of ﬁnancial assets should be considered: Financial assets at amortised cost, ﬁnancial assets at fair value through other comprehensive income, investments in subsidiaries, joint ventures and associates, ﬁnancial assets designated at fair value through proﬁt
or loss and non-trading ﬁnancial assets mandatorily at fair value through proﬁt or loss, and real estate collaterals obtained by credit institutions by taking possession in exchange in of cancellation of debts.
2. Credit institutions shall duplicate this template for reporting on stocks for the calculation of GAR stock, and reporting on new assets for the calculation of GAR ﬂow.
Annex – Taxonomy templates
382
3. Credit institutions shall duplicate this template for turnover based and CapEx based disclosures.
4. in accordance with Article 7(8)(a) and (b) of this Regulation
5. in accordance with Article 4(1a) of this Regulation
Annex – Taxonomy templates
383
Template 2: GAR sector information (Turnover)
Breakdown by sector - NACE 4 digits level
(code and label)
(Million EUR)
Total
[Gross]
carrying
amount
Of which
Taxonomy
eligible
Of which
Taxonomy
aligned
Climate
Change
Mitigation
(CCM)
Climate
Change
Adaptation
(CCA)
Water
and
marine
resources
(WTR)
Circular
economy
(CE)
Pollution
(PPC)
Biodiversity and
Ecosystems
(BIO)
1
N77.11 - Rental and leasing of cars and light motor vehicles
305
239
18
18
-
-
-
-
-
2
L68.20 - Rental and operating of own or leased real estate
256
416
94
5
89
-
-
-
-
3
D35.11 - Production of electricity
172
62
62
62
-
-
-
-
-
4
D35.13 - Distribution of electricity
144
35
32
32
-
-
-
-
-
5
H49.20 - Freight rail transport
120
106
31
31
-
-
-
-
-
6
C29.10 - Manufacture of motor vehicles
41
24
4
4
-
-
-
-
-
7
H49.10 - Passenger rail transport, interurban
38
33
5
5
-
-
-
-
-
8
F41.20 - Construction of residential and non-residential
buildings
32
24
2
2
-
-
-
-
-
9
C26.11 - Manufacture of electronic components
25
-
-
-
-
-
-
-
-
10
C30.91 - Manufacture of motorcycles
25
2
-
-
-
-
-
-
-
11
Nuclear activities(4)
172
62
62
12
Fossil gas activities(5)
2
1
-
13
Of which non-assessed exposures(6)
Template 2: GAR - sector information (CapEx)
Breakdown by sector - NACE 4 digits level
(code and label)
(Million EUR)
Total
[Gross]
carrying
amount
Of which
Taxonomy
eligible
Of which
Taxonomy
aligned
Climate
Change
Mitigation
(CCM)
Climate
Change
Adaptation
(CCA)
Water
and
marine
resources
(WTR)
Circular
economy
(CE)
Pollution
(PPC)
Biodiversity and
Ecosystems
(BIO)
1
N77.11 - Rental and leasing of cars and light motor vehicles
305
260
67
67
-
-
-
-
-
2
L68.20 - Rental and operating of own or leased real estate
256
491
36
4
32
-
-
-
-
3
D35.11 - Production of electricity
172
76
76
76
-
-
-
-
-
4
D35.13 - Distribution of electricity
144
89
84
84
-
-
-
-
-
5
H49.20 - Freight rail transport
120
116
34
34
-
-
-
-
-
6
C29.10 - Manufacture of motor vehicles
41
16
8
8
-
-
-
-
-
7
H49.10 - Passenger rail transport, interurban
38
37
3
3
-
-
-
-
-
8
F41.20 - Construction of residential and non-residential
buildings
32
3
-
-
-
-
-
-
-
9
C26.11 - Manufacture of electronic components
25
2
-
-
-
-
-
-
-
10
C30.91 - Manufacture of motorcycles
25
22
-
-
-
-
-
-
-
11
Nuclear activities(4)
172
76
76
-
-
-
-
-
-
12
Fossil gas activities(5)
2
1
1
-
-
-
-
-
-
13
Of which non-assessed exposures(6)
0
0
0
0
0
0
0
0
0
Note 1. Credit institutions shall disclose in this template information on top ten exposures in the banking book towards top ten sectors covered by the Taxonomy (NACE sectors 4 levels of detail), using the relevant NACE Codes on the basis of the principal activity of the counterparty. The
counterparty NACE sector allocation shall be based exclusively on the nature of the immediate counterparty. The classification of the exposures incurred jointly by more than one obligor shall be done on the basis of the characteristics of the obligor that was the more relevant, or determinant,
for the institution to grant the exposure. The distribution of jointly incurred exposures by NACE codes shall be driven by the characteristics of the more relevant or determinant obligor. Institutions shall disclose information by NACE codes with the level of disaggregation required in the template.
Credit institutions shall duplicate this template for turnover based and CapEx based disclosures.
4. referred to in Sections 4.26, 4,27, and 4.28 of Annexes I and II to Delegated Regulation 2021/2139
5. referred to in Sections 4.29, 4,30, and 4.31 of Annexes I and II to Delegated Regulation 2021/2139
6. in accordance with Article 7(8) of this Regulation
Annex – Taxonomy templates
384
Template 3: GAR KPI stock (Turnover)
Taxonomy-
eligible
Taxonomy
aligned
Substantial contribution to environmental objectives
Of which
Use of
Proceeds
Of which
transitional
Of which
enabling
Proportion of
Taxonomy
aligned in
Taxonomy
eligible
Non-
assessed
exposures
(3)
% (compared to corresponding total covered
assets in the denominator)
Climate Change
Mitigation (CCM)
Climate
Change
Adaptation
(CCA)
Water and
marine
resources (WTR)
Circular
economy (CE)
Pollution (PPC)
Biodiversity
and
Ecosystems
(BIO)
1
GAR - Covered assets in both numerator and
denominator
2
Loans and advances, debt securities and equity
instruments not HfT eligible for GAR calculation
75.58%
11.42%
10.85%
0.57%
-
-
-
-
9.28%
0.88%
0.89%
15.12%
2.51%
3
Financial undertakings
3.84%
0.44%
0.44%
-
-
-
-
-
-
0.03%
0.32%
11.55%
-
4
Loans and advances
3.57%
0.36%
0.36%
-
-
-
-
-
-
-
0.29%
9.97%
-
5
Debt securities, including UoP
0.26%
0.09%
0.09%
-
-
-
-
-
-
0.03%
0.03%
33.29%
-
6
Equity instruments
-
-
-
-
-
-
-
-
-
-
-
13.06%
-
7
Non-financial undertakings
6.76%
1.70%
1.13%
0.57%
-
-
-
-
-
0.85%
0.57%
25.19%
-
8
Loans and advances
4.06%
1.34%
0.95%
0.39%
-
-
-
-
-
0.67%
0.45%
33.00%
-
9
Debt securities, including UoP
2.70%
0.36%
0.17%
0.19%
-
-
-
-
-
0.17%
0.12%
13.43%
-
10
Equity instruments
-
-
-
-
-
-
-
-
-
-
-
-
-
11
Households
64.99%
9.28%
9.28%
-
-
-
-
-
9.28%
-
-
14.28%
-
12
of which loans collateralised by residential
immovable property
64.71%
9.28%
9.28%
-
-
-
-
-
9.28%
-
-
14.34%
-
13
of which building renovation loans
0.28%
-
-
-
-
-
-
-
-
-
-
-
-
14
of which motor vehicle loans
-
-
-
-
-
-
-
-
-
-
-
-
1.02%
15
Local governments financing
-
-
-
-
-
-
-
-
-
-
-
-
1.49%
16
Housing financing
-
-
-
-
-
-
-
-
-
-
-
-
-
17
Other local government financing
-
-
-
-
-
-
-
-
-
-
-
-
1.49%
18
Collateral obtained by taking possession:
residential and commercial immovable
properties
-
-
-
-
-
-
-
-
-
-
-
-
-
19
Exposures included on a voluntary basis (4)
-
-
-
-
-
-
-
-
-
-
-
-
-
20
GAR - Total GAR assets
75.58%
11.42%
10.85%
0.57%
-
-
-
-
9.28%
0.88%
0.89%
15.12%
2.51%
Annex – Taxonomy templates
385
Template 3: GAR KPI stock (CapEx)
0
% (compared to corresponding total covered
assets in the denominator)
Taxonomy-
eligible
Taxonomy
aligned
Substantial contribution to environmental objectives
Of which
Use of
Proceeds
Of which
transitional
Of which
enabling
Proportion of
Taxonomy
aligned in
Taxonomy
eligible
Non-
assessed
exposures
(3)
0
Climate Change
Mitigation (CCM)
Climate
Change
Adaptation
(CCA)
Water and
marine
resources (WTR)
Circular
economy (CE)
Pollution (PPC)
Biodiversity
and
Ecosystems
(BIO)
1
GAR - Covered assets in both numerator and
denominator
2
Loans and advances, debt securities and equity
instruments not HfT eligible for GAR calculation
77.59%
12.54%
12.32%
0.22%
-
-
-
-
9.28%
0.55%
2.03%
16.16%
2.51%
3
Financial undertakings
3.94%
0.94%
0.93%
-
-
-
-
-
-
0.02%
0.76%
23.78%
-
4
Loans and advances
3.71%
0.87%
0.87%
-
-
-
-
-
-
-
0.73%
23.58%
-
5
Debt securities, including UoP
0.23%
0.06%
0.06%
-
-
-
-
-
-
0.01%
0.03%
27.14%
-
6
Equity instruments
-
-
-
-
-
-
-
-
-
-
-
15.27%
-
7
Non-financial undertakings
8.67%
2.32%
2.10%
0.22%
-
-
-
-
-
0.54%
1.27%
26.80%
-
8
Loans and advances
5.69%
1.79%
1.64%
0.15%
-
-
-
-
-
0.54%
0.84%
31.41%
-
9
Debt securities, including UoP
2.98%
0.54%
0.47%
0.07%
-
-
-
-
-
-
0.43%
17.97%
-
10
Equity instruments
-
-
-
-
-
-
-
-
-
-
-
-
-
11
Households
64.99%
9.28%
9.28%
-
-
-
-
-
9.28%
-
-
14.28%
1.02%
12
of which loans collateralised by residential
immovable
property
64.71%
9.28%
9.28%
-
-
-
-
-
9.28%
-
-
14.34%
-
13
of which building renovation loans
0.28%
-
-
-
-
-
-
-
-
-
-
-
-
14
of which motor vehicle loans
-
-
-
-
-
-
-
-
-
-
-
-
1.02%
15
Local governments financing
-
-
-
-
-
-
-
-
-
-
-
-
1.49%
16
Housing financing
-
-
-
-
-
-
-
-
-
-
-
-
-
17
Other local government financing
-
-
-
-
-
-
-
-
-
-
-
-
1.49%
18
Collateral obtained by taking possession:
residential and commercial immovable properties
-
-
-
-
-
-
-
-
-
-
-
-
-
19
Exposures included on a voluntary basis (4)
-
-
-
-
-
-
-
-
-
-
-
-
-
20
GAR - Total GAR assets
77.59%
12.54%
12.32%
0.22%
-
-
-
-
9.28%
0.55%
2.03%
16.16%
2.51%
Note 1. Institution shall disclose in this template the GAR KPIs on stock of exposures calculated based on the data disclosed in template 1, on covered assets. Credit institutions shall duplicate this template for turnover based and CapEx based disclosures
3. in accordance with Article 7(8) of this Regulation
4. in accordance with Article 7(3) of this Regulation
Annex – Taxonomy templates
386
Template 4: GAR KPI ﬂow (Turnover)
% (compared to corresponding total covered assets in the
denominator)
Taxonomy-
eligible
Taxonomy
aligned
Substantial contribution to environmental objectives
Of which
Use of
Proceeds
Of which
transitional
Of which
enabling
Proportion of
Taxonomy
aligned in
Taxonomy
eligible
Nonassessed
exposures
(3)
Climate
Change
Mitigation
(CCM)
Climate
Change
Adaptation
(CCA)
Water and
marine
resources (WTR)
Circular
economy
(CE)
Pollution
(PPC)
Biodiversity
and
Ecosystems
(BIO)
1
GAR - Covered assets in both numerator and denominator
2
Loans and advances, debt securities and equity instruments
not HfT eligible for GAR calculation
58.34%
6.34%
5.67%
0.67%
-
-
-
-
2.22%
2.67%
0.65%
10.86%
2.98%
3
Financial undertakings
1.08%
0.52%
0.52%
-
-
-
-
-
-
-
0.14%
47.70%
-
4
Loans and advances
0.49%
0.04%
0.04%
-
-
-
-
-
-
-
-
7.86%
-
5
Debt securities, including UoP
0.60%
0.48%
0.48%
-
-
-
-
-
-
-
0.13%
80.45%
-
6
Equity instruments
-
-
-
-
-
-
-
-
-
-
-
13.06%
-
7
Non-financial undertakings
8.25%
3.60%
2.93%
0.67%
-
-
-
-
-
2.67%
0.52%
43.60%
-
8
Loans and advances
5.46%
3.30%
2.64%
0.67%
-
-
-
-
-
2.67%
0.22%
60.43%
-
9
Debt securities, including UoP
2.79%
0.29%
0.29%
-
-
-
-
-
-
-
0.29%
10.59%
-
10
Equity instruments
-
-
-
-
-
-
-
-
-
-
-
-
-
11
Households
49.00%
2.22%
2.22%
-
-
-
-
-
2.22%
-
-
4.54%
1.76%
12
of which loans collateralised by residential immovable
property
48.87%
2.22%
2.22%
-
-
-
-
-
2.22%
-
-
4.55%
-
13
of which building renovation loans
0.13%
-
-
-
-
-
-
-
-
-
-
-
-
14
of which motor vehicle loans
-
-
-
-
-
-
-
-
-
-
-
-
1.76%
15
Local governments financing
-
-
-
-
-
-
-
-
-
-
-
-
1.22%
16
Housing financing
-
-
-
-
-
-
-
-
-
-
-
-
-
17
Other local government financing
-
-
-
-
-
-
-
-
-
-
-
-
1.22%
18
Collateral obtained by taking possession: residential and
commercial immovable properties
-
-
-
-
-
-
-
-
-
-
-
-
-
19
Exposures included on a voluntary basis (4)
-
-
-
-
-
-
-
-
-
-
-
-
-
20
GAR - Total GAR assets
58.34%
6.34%
5.67%
0.67%
-
-
-
-
2.22%
2.67%
0.65%
10.86%
2.98%
Annex – Taxonomy templates
387
Template 4: GAR KPI ﬂow (CapEx)
% (compared to corresponding total covered assets in the
denominator)
Taxonomy-
eligible
Taxonomy
aligned
Substantial contribution to environmental objectives
Of which
Use of
Proceeds
Of which
transitional
Of which
enabling
Proportion of
Taxonomy
aligned in
Taxonomy
eligible
Non-assessed
exposures
(3)
Climate
Change
Mitigation
(CCM)
Climate
Change
Adaptation
(CCA)
Water and
marine
resources (WTR)
Circular
economy
(CE)
Pollution
(PPC)
Biodiversity
and
Ecosystems
(BIO)
1
GAR - Covered assets in both numerator and denominator
2
Loans and advances, debt securities and equity instruments
not HfT eligible for GAR calculation
61.68%
8.22%
7.50%
0.71%
-
-
-
-
2.22%
3.74%
1.08%
13.32%
2.98%
3
Financial undertakings
1.34%
0.83%
0.83%
-
-
-
-
-
-
-
0.04%
61.84%
-
4
Loans and advances
0.51%
0.06%
0.06%
-
-
-
-
-
-
-
0.02%
11.05%
-
5
Debt securities, including UoP
0.83%
0.77%
0.77%
-
-
-
-
-
-
-
0.02%
92.74%
-
6
Equity instruments
-
-
-
-
-
-
-
-
-
-
-
15.27%
-
7
Non-financial undertakings
11.34%
5.17%
4.45%
0.71%
-
-
-
-
-
3.74%
1.04%
45.55%
-
8
Loans and advances
8.70%
4.32%
3.61%
0.71%
-
-
-
-
-
3.74%
0.19%
49.64%
-
9
Debt securities, including UoP
2.64%
0.85%
0.85%
-
-
-
-
-
-
-
0.85%
32.05%
-
10
Equity instruments
-
-
-
-
-
-
-
-
-
-
-
-
-
11
Households
49.00%
2.22%
2.22%
-
-
-
-
-
2.22%
-
-
4.54%
1.76%
12
of which loans collateralised by residential immovable
property
48.87%
2.22%
2.22%
-
-
-
-
-
2.22%
-
-
4.55%
-
13
of which building renovation loans
0.13%
-
-
-
-
-
-
-
-
-
-
-
-
14
of which motor vehicle loans
-
-
-
-
-
-
-
-
-
-
-
-
1.76%
15
Local governments financing
-
-
-
-
-
-
-
-
-
-
-
-
1.22%
16
Housing financing
-
-
-
-
-
-
-
-
-
-
-
-
-
17
Other local government financing
-
-
-
-
-
-
-
-
-
-
-
-
1.22%
18
Collateral obtained by taking possession: residential and
commercial immovable properties
-
-
-
-
-
-
-
-
-
-
-
-
-
19
Exposures included on a voluntary basis (4)
-
-
-
-
-
-
-
-
-
-
-
-
-
20
GAR - Total GAR assets
61.68%
8.22%
7.50%
0.71%
-
-
-
-
2.22%
3.74%
1.08%
13.32%
2.98%
Note 1. Institution shall disclose in this template the GAR KPIs on stock of exposures calculated based on the data disclosed in template 1, on covered assets. Credit institutions shall duplicate this template for turnover based and CapEx based disclosures
3. in accordance with Article 7(8) of this Regulation
4. in accordance with Article 7(3) of this Regulation
Annex – Taxonomy templates
388
Template 5: KPI off-balance sheet exposures stock (Turnover)
% (compared to corresponding total off-balance
sheet assets)
Taxonomy
eligible
Taxonomy
aligned
Substantial contribution to environmental objectives
Of which
Use of
Proceeds
Of which
transitional
Of which
enabling
Non-assessed
exposures
(4)
Climate Change
Mitigation (CCM)
Climate Change
Adaptation (CCA)
Water and
marine
resources (WTR)
Circular
economy (CE)
Pollution
(PPC)
Biodiversity and
Ecosystems (BIO)
1
Financial guarantees (FinGuar KPI)
25.35%
7.77%
7.72%
0.01%
-
0.04%
0.01%
-
-
1.22%
4.47%
-
2
Assets under management (AuM KPI)
42.29%
7.88%
7.49%
0.02%
0.01%
0.34%
0.02%
-
-
1.27%
4.49%
-
Template 5: KPI off-balance sheet exposures stock (CapEx)
% (compared to corresponding total off-balance
sheet assets)
Taxonomy
eligible
Taxonomy
aligned
Substantial contribution to environmental objectives
Of which
Use of
Proceeds
Of which
transitional
Of which
enabling
Non-assessed
exposures
(4)
Climate Change
Mitigation (CCM)
Climate Change
Adaptation (CCA)
Water and
marine
resources (WTR)
Circular
economy (CE)
Pollution
(PPC)
Biodiversity and
Ecosystems (BIO)
1
Financial guarantees (FinGuar KPI)
26.62%
10.46%
9.86%
0.06%
-
0.53%
-
-
-
2.18%
2.80%
-
2
Assets under management (AuM KPI)
44.06%
13.72%
13.44%
0.06%
0.01%
0.19%
0.03%
-
-
1.88%
7.17%
-
Template 5: KPI off-balance sheet exposures ﬂow (Turnover)
% (compared to corresponding total off-balance
sheet assets)
Taxonomy
eligible
Taxonomy
aligned
Substantial contribution to environmental objectives
Of which
Use of
Proceeds
Of which
transitional
Of which
enabling
Non-assessed
exposures
(4)
Climate Change
Mitigation (CCM)
Climate Change
Adaptation (CCA)
Water and
marine
resources (WTR)
Circular
economy (CE)
Pollution
(PPC)
Biodiversity and
Ecosystems (BIO)
1
Financial guarantees (FinGuar KPI)
37.06%
11.89%
11.86%
0.01%
-
0.01%
-
-
-
1.18%
7.82%
-
2
Assets under management (AuM KPI)
44.11%
14.68%
10.37%
4.06%
0.01%
-
0.23%
0.01%
44.54%
9.96%
0.35%
-
Template 5: KPI off-balance sheet exposures ﬂow (CapEx)
% (compared to corresponding total off-balance
sheet assets)
Taxonomy
eligible
Taxonomy
aligned
Substantial contribution to environmental objectives
Of which
Use of
Proceeds
Of which
transitional
Of which
enabling
Non-assessed
exposures
(4)
Climate Change
Mitigation (CCM)
Climate Change
Adaptation (CCA)
Water and
marine
resources (WTR)
Circular
economy (CE)
Pollution
(PPC)
Biodiversity and
Ecosystems (BIO)
1
Financial guarantees (FinGuar KPI)
31.80%
14.15%
13.69%
0.02%
-
0.44%
-
-
-
0.82%
4.44%
-
2
Assets under management (AuM KPI)
47.92%
19.57%
14.11%
5.36%
0.02%
-
0.08%
0.01%
44.28%
13.89%
0.18%
-
Note 1. Institution shall disclose in this template the KPIs for off-balance sheet exposures (ﬁnancial guarantees and AuM) calculated based on the data disclosed in template 1, on covered assets. Institutions shall duplicate this template to disclose stock and ﬂow KPIs for off-balance sheet exposures.
Credit institutions shall duplicate this template for turnover-based and CapEx-based disclosures.
4. in accordance with Article 7(8) of this Regulation
Annex – Taxonomy templates
389
Template for the KPI of asset managers
Standard template for the disclosure required under Article 8 of Regulation (EU) 2020/852 (asset managers)
Disclosure reference date
31.12.2025
Exposures
%
Million
EUR
1
Total AUM
100%
3,939
2
Assets covered by the KPI
86.96%
3,425
% of covered assets
%
%
Turnover
CapEx
based
based
3
Taxonomy eligible
5.04%
5.25%
4
Nuclear activities
(1)
0.04%
0.02%
5
Fossil gas activities
(2)
0.19%
0.11%
6
Taxonomy aligned
0.94%
1.64%
7
Undertakings subject to Article 19a and 29a of Directive 2013/34/EU
0.94%
1.64%
8
of which Non-financial undertakings
0.89%
1.56%
9
of which Financial undertakings
0.05%
0.07%
10
Other covered counterparties and real estate assets
-
-
11
Exposures included on a voluntary basis
(3)
-
-
12
Transitional activities
0.15%
0.22%
13
Enabling activities
0.54%
0.86%
14
Nuclear activities
(1)
0.04%
0.02%
15
Fossil gas activities
(2)
-
-
Taxonomy aligned per objective
%
%
Turnover
CapEx
based
based
16
Climate Change Mitigation (CCM)
0.89%
1.60%
17
Climate Change Adaptation (CCA)
-
0.01%
18
Water and marine resources (WTR)
-
-
19
Circular economy (CE)
0.04%
0.02%
20
Pollution (PPC)
-
-
21
Biodiversity and Ecosystems (BIO)
-
-
22
Non-assessed exposures
-
-
23
Exposures financing non-assessed non-material activities of
-
-
counterparties
(4)
24
Non-assessed exposures considered non-material by the reporting entity
(5)
-
-
25
Exposures to counterparties reporting in accordance with Article 7(9) of
-
-
this Regulation
(6)
Breakdown of covered assets
%
Million
EUR
26
Undertakings subject to Article 19a and 29a of Directive 2013/34/EU
11.92%
408
27
of which Non-financial undertakings
9.07%
311
28
of which Financial undertakings
2.85%
97
29
Other covered counterparties and real estate assets
88.08%
3 017
30
Exposures included on a voluntary basis
(3)
-
0
(1) referred to in Sections 4.26, 4.27, and 4.28 of Annexes I and II to Delegated Regulation 2021/2139
(2) referred to in Sections 4.29, 4.30, and 4.31 of Annexes I and II to Delegated Regulation 2021/2139 (3) in accordance with Article 7
(3) of this Regulation
(4) in accordance with Article 7(8)(a) and (b) of this Regulation
(5) in accordance with Article 3(1a) of this Regulation. Figures should be the same in both columns.
(6) Figures should be the same in both columns.
390
Annexes
39
1
Information on Securities issued by the Bank
Debt securities issued by the Bank
ISSUE NAME
ISSUE DATE
MATURITY
DATE
DENOMI-
NATION
NOMINAL
VALUE
PIECES
COUPON
COUPON
PAYMENTS
Mortgage bonds
VUB, a.s., XXX.
5 September 2007
5 September 2032
EUR
33 193.92
1 000
5.00%
annually
Mortgage bonds
VUB, a.s., 31
29 November 2007
29 November 2037
EUR
33 193.92
600
4.90%
annually
Mortgage bonds
VUB, a.s., 67
29 November 2011
29 November 2030
EUR
50 000.00
300
5.35%
annually
Mortgage bonds
VUB, a.s., 72
21 June 2012
21 June 2027
EUR
100 000.00
250
4.70%
annually
Mortgage bonds
VUB, a.s., 85
14 November 2014
14 November 2029
EUR
100 000.00
500
2.25%
annually
Mortgage bonds
VUB, a.s., 90
29 October 2015
29 October 2030
EUR
100 000.00
1 000
1.60%
annually
Mortgage bonds
VUB, a.s., 94
27 April 2017
27 April 2027
EUR
100 000.00
2 500
1.05%
annually
Covered bonds
VUB, a.s., 2
5 October 2018
15 December 2027
EUR
100 000.00
500
1.50%
annually
Covered bonds
VUB, a.s., 4
26 June 2019
26 June 2029
EUR
100 000.00
5 000
0.50%
annually
Covered bonds
VUB, a.s., 6
24 March 2021
24 March 2026
EUR
100 000.00
5 000
0.01%
annually
Covered bonds
VUB, a.s., 7
22 March 2022
22 March 2027
EUR
100 000.00
5 000
0.875%
annually
Covered bonds
VUB, a.s., 8
13 April 2023
13 October 2026
EUR
100 000.00
5 000
3.50%
annually
Covered bonds
VUB, a.s., 9
5 September 2023
5 September 2028
EUR
100 000.00
5 000
3.875%
annually
Covered bonds
VUB, a.s., 10
20 March 2024
20 March 2031
EUR
100 000.00
5 000
3.25%
annually
Covered bonds
VUB, a.s., 11
20 May 2025
20 May 2032
EUR
100 000.00
5 000
3.00%
annually
All debt securities issued by the Bank are bearer bonds in a book-entry form. No person has taken any guarantee
for the repayment of their nominal value and/or payment of the proceeds. The debt securities are transferable to
another holder without restriction and have been issued without the possibility of early redemption.
The rights associated with the debt securities are based on the terms and conditions of issue and the relevant
securities prospectus and in the applicable legal regulations of the Slovak Republic, in particular Act No. 530/1990
Coll. on Bonds as amended, Act No 483/2001 Coll. on Banks as amended, Act No 566/2001 Coll. on Securities and
Investment Services as amended.
As of 31 December 2025, the Bank has not issued or decided to issue bonds with pre-emption rights or convertible
rights associated therewith.
Information on Securities issued by the Bank
39
2
Investment certiﬁcates issued by the Bank
ISSUE NAME
ISSUE DATE
MATURITY
DATE
DENOMI-
NATION
NOMINAL
VALUE
PIECES
COUPON
COUPON
PAYMENTS
Investment certificates
VUB, a.s., 2026
30 June
2021
30 June 2026
EUR
1.00
10 200
0.00%
-
Investment certificates
VUB, a.s., 2027
30 June 2022
30 June 2027
EUR
1.00
25 800
0.00%
-
Investment certificates
VUB, a.s., 2028
28 June 2023
28 June 2028
EUR
1.00
54 480
0.00%
-
Investment certificates
VUB, a.s., 2029
26 June 2024
26 June 2029
EUR
1.00
100 080
0.00%
-
Investment certificates
VUB, a.s., 2030
26 June 2025
26 June 2030
EUR
1.00
264 900
0.00%
-
During the accounting year 2025, the Bank
issued the Investment certiﬁcates
VUB, a.s., 2030. The reason for issuing
investment certiﬁcates was to fulﬁl the obligations arising from the Act on Banks no. 483/2001 Coll. as amended in
conjunction with Regulation EU No 2019/876, amending Regulation 575/2013 on prudential requirements for credit
institutions and investment ﬁrms (CRR) and the internal procedure of
VUB, a.s. – Remuneration Policy. Based on
these documents, part of the variable component of total compensation, severance payments, retirement allowances
and other compensation payable to selected personnel acc. to Section 23a par. 1 of the Act on Banks is provided in
the form of securities or other ﬁnancial instruments.
Investment certiﬁcates issued
by the Bank are registered securities in a book-entry form and they are issued without
the possibility of early redemption. No person has taken any guarantee for the repayment of their nominal value
and/or payment of the proceeds. No pre-
emption or convertible rights are associated with investment certiﬁcates.
Investment certiﬁcates are not transferable to another holder. The rights associated with the investment certiﬁcates
are based on the applicable legislation of the Slovak Republic, in particular Act No 566/2001 Coll. on Securities and
Investment Services as amended, and in the relevant terms and conditions of issue of
the investment certiﬁcates.
39
3
List of VUB Retail Branches
Name
Postcode
Address
Regional Retail Business Network West region
Bratislava – Dolné Hony
821 06
Kazanská 41
Bratislava –
Dúbravka
841 01
Sch. Trnavského 6/A
Bratislava –
Rača
831 06
Detvianska 22
Bratislava – OC Aupark
851 01
Einsteinova 18
Bratislava – OC Avion
821 04
Ivánska cesta 16
Bratislava – OC BORY MALL
841 03
Lamač 6780
Bratislava – OC Vivo
831 04
Vajnorská 100
Bánovce nad Bebravou
957 01
Nám. Ľ. Štúra 5/5
Bytča
014 01
Sidónie Sakalovej 138/1
Čadca
022 24
Fraňa Kráľa 1504
Dubnica nad Váhom
018 41
Nám. Matice slov. 1712/7
Handlová
972 51
SNP 1
Hlohovec
920 01
Podzámska 37
Holíč
908 51
Bratislavská 1518/7
Ilava
019 01
Mierové nám. 77
Kysucké Nové Mesto
024 01
Nám. slobody 184
Malacky
901 01
Záhorácka 15
Myjava
907 01
Nám. M.
R.
Štefánika 525/21
Nové Mesto nad Váhom
915 01
Hviezdoslavova 19
Partizánske
958 01
L. Svobodu 4
Pezinok
902 01
Štefánikova
24
Piešťany
921 01
Nám. slobody 11
Považská Bystrica
017 01
Nám. A. Hlinku 23/28
Prievidza
971 01
Nám. slobody 10
Prievidza –
Bojnická cesta
971 01
Bojnická cesta 15
Púchov
020 01
Nám. slobody 1657
Senica
905 33
Nám. oslobodenia 8
Skalica
909 01
Potočná 20
Stará Turá
916 01
SNP 275/67
Topoľčany
– Moyzesova
955 19
Moyzesova 585/2
Trenčín
–
Legionárska
911 01
Legionárska 7158/5
Trenčín
– OC Laugarício
911 01
Belá 7271
Trnava – Dolné bašty
917 01
Dolné bašty 2
Trnava – OC Arkadia
917 01
Veterná 40/A
Žilina
010 01
Na bráne 1
Žilina
–
OC Dubeň
010 08
Vysokoškolákov 52
Magnifica Centres
Trenčín
– Magnifica
911 01
Legionárska 7158/5
Trnava – Magnifica
917 01
Dolné bašty 2
Žilina
– Magnifica
010 43
Na bráne 1
Bratislava – MC BORY MALL
841 03
Lamač 6780
List of Retail Branches
39
4
Mortgage Centres
Bratislava – OC Aupark
851 01
Einsteinova 18
Trnava
917 01
Dolné bašty 2
Trenčín
911 01
Legionárska 7158/5
Žilina
010 43
Na bráne 1
Regional Retail Business Network Central region
Bratislava – Centrum
811 06
Nám. SNP 15
Bratislava – Herlianska
821 03
Komárnická 11
Bratislava –
OC Centrál
821 08
Metodova 6
Bratislava – OC Eurovea
811 09
Pribinova 8
Bratislava –
Páričkova
821 08
Páričkova 2
Bratislava –
Petržalka C
ity
851 01
Rusovská cesta 50
Bratislava –
Ružinov
827 61
Kaštieľska 2
Banská Bystrica
975 55
Nám. slobody 1
Banská Bystrica
–
OC Európa
974 01
Na troskách 26
Banská Štiavnica
969 01
Radničné nám. 15
Detva
962 11
M. R. Štefánika 65
Dunajská Streda
929 35
Alžbetínske nám. 328
Fiľakovo
986 01
Biskupická 2
Galanta
924 41
Mierové nám. 2
Komárno
945 23
Tržničné nám. 1
Krupina
963 01
Svätotrojičné nám. 8
Levice
934 01
Štúrova 21
Lučenec
984 35
T. G. Masaryka 24
Nitra –
Tabáň
949 01
Štúrova ulica 10
Nitra – OC Centro
949 01
Akademická 1/A
Nová Baňa
968 01
Nám. slobody 11
Nové Zámky
940 33
Hlavné nám. 5
Senec
903 01
Nám. 1. mája 25
Sereď
926 00
Cukrovarská 3013/1
Šaľa
927 00
Hlavná 5
Šamorín
931 01
Hlavná 64
Štúrovo
943 01
Hlavná 59
Šurany
942 01
SNP 25
Veľký Krtíš
990 20
Novohradská 7
Vráble
952 01
Levická 1288/16
Zlaté Moravce
953 00
Župná 10
Zvolen
960 94
Nám. SNP 2093/13
Želiezovce
937 01
Komenského 8
Žiar nad Hronom
965 01
Nám. Matice slov. 21
Magnifica Centres
Bratislava – MC Eurovea
811 09
Pribinova 8
Banská Bystrica
– Magnifica
975 55
Nám. slobody 1
Nitra – Magnifica
949 01
Štúrova ulica 10
Mortgage Centres
Bratislava – Centrum
811 06
Nám. SNP 15
Bratislava –
Páričkova
821 08
Páričkova 2
Nitra
949 01
Štúrova ulica 10
Banská Bystrica
975 55
Nám. slobody 1
List of Retail Branches
39
5
Regional Retail Business Network East Region
Bardejov
085 01
Kellerova 1
Brezno
977 01
Boženy Němcovej 1/A
Dolný Kubín
026 01
Radlinského 1712/34
Humenné
066 01
Nám. slobody 26/10
Kežmarok
060 01
Hviezdoslavova 5
Košice
–
Štúrova
040 01
Štúrova 27/A
Košice
–
Hlavná 1
042 31
Hlavná 1
Košice
–
Letná
040 01
Letná 40
Košice
– OC Aupark
040 01
Nám. osloboditeľov 1
Košice
– OC Galéria
040 11
Toryská 5
Košice
– OC Optima
040 11
Moldavská cesta 32
Krompachy
053 42
Lorencova 20
Levoča
054 01
Nám. Majstra Pavla 38
Lipany
082 71
Nám. sv. Martina 2
Liptovský Mikuláš
031 31
Štúrova 19
Martin
036 01
M. R. Štefánika 2
Martin – OC Tulip
036 01
Pltníky 2
Medzilaborce
068 10
Mierová 289/1
Michalovce
071 80
Obchodná ulica 6/A
Moldava nad Bodvou
045 01
Hviezdoslavova 13
Námestovo
029 01
Hviezdoslavovo nám. 200/5
Poprad
058 17
Mnoheľova 2832/9
Poprad – OC Forum
058 01
Nám. sv. Egídia 3290/124
Prešov
080 01
Masarykova 13
Prešov –
Hlavná
080 01
Hlavná 61
Prešov – OC Eperia
080 01
Armádneho Generála L. Svobodu 25
Revúca
050 01
Nám. slobody 3
Rimavská Sobota
979 13
Francisciho 1
Rožňava
048 73
Šafárikova 21
Ružomberok
034 01
Podhora 48
Sabinov
083 01
Nám. slobody 90
Snina
069 01
Strojárska 2524
Spišská Nová Ves
052 14
Letná 33
Stará Ľubovňa
064 01
Nám. sv. Mikuláša 27
Stropkov
091 01
Mlynská 692/1
Svidník
089 27
Centrálna 584/5
Trebišov
075 17
M.
R. Štefánika 3197/32
Trstená
028 01
Nám. M. R. Štefánika 15
Turčianske Teplice
039 01
Hájska 3
Tvrdošín
027 44
Trojičné nám. 191
Veľké Kapušany
079 01
Sídl. P. O. Hviezdoslava 79
Vranov nad Topľou
093 01
Nám. slobody 6
Magnifica Centres
Košice
– Magnifica
042 31
Štúrova 27/A
Prešov – Magnifica
081 86
Masarykova 13
Mortgage Centres
Košice
042 31
Štúrova 27/A
Poprad
058 17
Mnoheľova 2832/9
Prešov
081 86
Masarykova 13
39
6
List of VUB Corporate Branches
Corporate Business Centre Bratislava
BRATISLAVA
Iv
á
nska cesta 16
0904 751 310
Corporate Business Centre Trnava
TRNAVA
Dolné bašty 2
0904 750 026
SENICA
Nám. oslobodenia 8
0904 756 420
Corporate Business Centre Nitra
NITRA
Štúrova 10
0904 751 379
TOPOĽČANY
Moyzesova 585/2
0904 750 543
LEVICE
Štúrova 21
0904 757 796
Corporate Business Centre Nové Zámky
NOVÉ ZÁMKY
Hlavné námestie 5
0904 750 611
KOMÁRNO
Tržničné nám. 1
0904 751 514
GALANTA
Mierové námestie 2
0904 755 804
DUNAJSKÁ STREDA
Alžbetínske nám. 328
0904 751 514
Corporate Business Centre Trenčín
TRENČÍN
Legionárska 7158/5
0904 750 356
POVAŽSKÁ BYSTRICA
Nám. A. Hlinku 23/28
0904 750 009
PRIEVIDZA
Námestie slobody 10
0904 750 140
Corporate Business Centre Žilina
ŽILINA
Na bráne 1
0904 750 828
MARTIN
M.R.Štefánika 2
0904 751 242
ČADCA
Fraňa Kráľa 1504
0904 755 443
DOLNÝ KUBÍN
Radlinského 1712/34
0904 755 762
Corporate Business Centre Banská Bystrica
ŽIAR NAD HRONOM
Nám. Matice slovenskej 21
0904 751 097
ZVOLEN
Námestie SNP 2093/13
0904 755 400
BANSKÁ BYSTRICA
Námestie slobody 1
0904 755 400
LUČENEC
T.G. Masaryka 24
0904 751 152
RIMAVSKÁ SOBOTA
Francisciho 1
0904 751 152
Corporate Business Centre Poprad
POPRAD
Mnoheľova 2832/9
0904 755 925
LIPTOVSKÝ MIKULÁŠ
Štúrova 19
0904 755 533
SPIŠSKÁ NOVÁ VES
Letná 33
0904 750 900
Corporate Business Centre Prešov
PREŠOV
Masarykova 13
0904 750 680
BARDEJOV
Kellerova 1
0904 750 680
HUMENNÉ
Námestie slobody 26/10
0904 751 428
Corporate Business Centre Košice
KOŠICE
Štúrova 27/A
0904 750 258
MICHALOVCE
Obchodná ulica 6/A
0904 751 307
39
7
Organization Chart of VUB as at 31 December 2025
39
8
Scope of business
Pursuant to Article 2 of Act No. 483/2001 Coll. on Banks, the Bank carries out, apart from taking deposits and
providing loans, the following activities:
1.
The provision of payment services and clearing;
2.
The provision of investment services, investment activities and auxiliary services under the Act on Securities, and
investing in securities for account;
3.
Trading activities for the Bank’s account:
a)
Financial instruments of the money market in EUR or foreign currency, including currency exchange services;
b)
Financial instruments of the capital market in EUR or foreign currency;
c)
Precious metal coins, commemorative coins and banknotes, sheets of banknotes and sets of circulation
coinage;
4.
The management of claims on behalf of clients, including advisory services;
5.
Financial leasing;
6.
The provision of guarantees, opening and endorsing of letters of credit;
7.
The provision of business advisory services;
8.
The issuance of securities, participation therein, and the provision of related services;
9.
Financial intermediation;
10.
The safe custody of assets;
11.
The renting of safe deposit boxes;
12.
The provision of banking information;
13.
Mortgage transactions pursuant to Article 67(1) of the Act on Banks;
14.
Performance of the functions of a depository under a separate regulation;
15.
The processing of banknotes and coins;
16.
The issuance and administration of electronic money;
17.
Financial intermediation under a
special regulation as an independent ﬁnancial agent in the insurance and
reinsurance sector, provision of loans, housing loans and consumer loans, and as a
tied ﬁnancial agent in the
supplementary pension savings sector.
Pursuant to Article 79a and Article 6 of Act No. 566/2001 Coll. on Securities and Investment Services and on changes
and amendments to some acts (Act on Securities).
Pursuant to Article 79a(1) and Article 6(1) and (2) of Act No. 566/2001 Coll. on Securities and Investment Services,
the investment of securities on own account, the provision of investment services, investment activities and ancillary
services in accordance with Article 79a(1) and in conjunction with Article 6(1) and (2) of the Act on Securities, within
the following scope:
(i) Reception and transmission of client orders in relation to one or more ﬁnancial instruments with respect to the
following ﬁnancial instruments:
a)
Transferable securities;
b)
Money market instruments;
c)
Fund shares or securities issued by foreign collective investment entities;
d)
Options, futures, swaps, forwards and other derivatives related to securities, currencies, interest rates or yields
or other derivative instruments, ﬁnancial indexes or ﬁnancial rates which can be settled by delivery or in cash;
e)
Options, swaps and forwards related to commodities which must be settled in cash or can be settled at the
option of one of the parties; this does not apply if the settlement is carried out due to insolvency or another
Scope of business
399
event resulting in contract termination;
f)
Options and swaps related to commodities which can be settled in cash, if traded on a regulated market or
within a multilateral trading system;
g)
O
ptions, swaps and forwards related to emission licences, inﬂation rate which must be settled in cash or can be
settled at the option of one of the parties, for a reason other than due to insolvency or another event resulting
in contract termination.
(ii) E
xecution of orders on behalf of clients with respect to ﬁnancial instruments:
a)
Transferable securities,
b)
Money market instruments,
c)
Fund shares or securities issued by foreign collective investment entities;
d)
Options, futures, swaps, forwards and other derivatives related to securities, currencies, interest rates or yields
or other derivative instruments, ﬁnancial indexes or ﬁnancial rates which can be settled by delivery or in cash;
e)
Options, swaps and forwards related to commodities which must be settled in cash or can be settled at the
option of one of the parties; this does not apply if the settlement is carried out due to insolvency or another
event resulting in contract termination;
f)
Options and swaps related to commodities which can be settled in cash, if traded on a regulated market or
within a multilateral trading system;
g)
O
ptions, swaps and forwards related to emission licences, inﬂation rate, which must be settled in cash or can
be settled at the option of one of the parties, for a reason other than due to insolvency or another event resulting
in contract termination.
(iii) D
ealing on own account with respect to ﬁnancial instruments:
a)
Transferable securities,
b)
Money market instruments,
c)
Fund shares or securities issued by foreign collective investment entities;
d)
Options, futures, swaps, forwards and other derivatives related to securities, currencies, interest rates or yields
or other derivative instruments, ﬁnancial indexes or ﬁnancial rates which can be settled by delivery or in cash;
e)
Options, swaps and forwards related to commodities which must be settled in cash or can be settled at the
option of one of the parties; this does not apply if the settlement is carried out due to insolvency or another
event resulting in contract termination;
f)
Options and swaps related to commodities which can be settled in cash, if traded on a regulated market or
within a multilateral trading system;
g)
O
ptions, swaps and forwards related to emission licences, inﬂation rate, which must be settled in cash or can
be settled at the option of one of the parties, for a reason other than due to insolvency or another event resulting
in contract termination.
(iv) P
ortfolio management with respect to ﬁnancial instruments:
a)
Transferable securities,
b)
Money market instruments,
c)
Fund shares or securities issued by foreign collective investment entities;
d)
Options, futures, swaps, forwards and other derivatives related to securities, currencies, interest rates or yields
or other derivative instruments, ﬁnancial indexes or ﬁnancial rates which can be settled by delivery or in cash
.
Scope of business
40
0
(v) I
nvestment advice with respect to ﬁnancial instruments:
a)
Transferable securities,
b)
Money market instruments,
c)
Fund shares or securities issued by foreign collective investment entities.
(vi) U
nderwriting or placing of ﬁnancial instruments on a ﬁrm commitment basis with respect to ﬁnancial
instruments:
a)
Transferable securities,
b)
Fund shares or securities issued by foreign collective investment entities.
(vii) P
lacing of ﬁnancial instruments without a ﬁrm commitment basis with respect to ﬁnancial instruments:
a)
Transferable securities,
b)
Money market instruments,
c)
Fund shares or securities issued by foreign collective investment entities.
(viii) S
afe custody and administration of ﬁnancial instruments for the account of clients, including custodianship and
related services, such as cash/collateral management with respect to ﬁnancial instruments:
a)
Transferable securities,
b)
Money market instruments,
c)
Fund shares or securities issued by foreign collective investment entities.
(ix) G
ranting credits or loans to an investor to allow him to carry out a transaction in one or more ﬁnancial
instruments, where the provider of the credit or loans is involved in the transaction.
(x)
Advice on capital structure and business strategy, and advice and services relating to the merger, consolidation,
transformation or splitting of undertakings or the purchase of undertakings.
(xi) Foreign exchange transactions where these are connected to the provision of investment services.
(xii) I
nvestment survey and ﬁnancial analysis or the other forms of general recommendation relating to transactions
in ﬁnancial instruments
.
(xiii) S
ervices related to the underwriting of ﬁnancial instruments
.
(xiv) R
eceipt and transmission of clients’ orders concerning one or more ﬁnancial instruments, execution of clients’
order on their own account, trading on own account related to underlying derivative instruments – forwards related
to emission licenses which must be settled in cash or can be settled at the option of one of the parties for a reason
other than due to insolvency or other event resulting in contract termination, provided that they are connected with
the provision of investment services or ancillary investment services for these derivatives.