![]()

We believe in this

region’s potential

NLB Group Annual Report 2021

![]()

2

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Contents

Forward-looking statements

The expectations, forecasts and statements regarding future

developments that are contained in this report are based on

assumptions and are contingent on a number of factors that

will come into play in the future. Consequently, the actual

situation may turn out to be different.

Statement bythe Management Board of NLB

................

6

Statement by the Chairman of the Supervisory Board of NLB8

Strategic Members Overview

.................................

11

Key Highlights

...............................................

12

KeyEvents

...................................................

17

Market Performance of NLB’s Shares and GDRs

.............

18

Macroeconomic Environment

...............................

21

Regulatory Environment

.....................................

26

BUSINESS REPORT

..........................................

28

Strategy

.....................................................

29

Risk Factors and Outlook

....................................

31

Impact of COVID-19 on Operations

..........................

34

Sustainability

................................................

35

Overview of Financial Performance

........................

40

Segment Analysis

............................................

61

Retail Banking in Slovenia

...................................

62

Corporate and Investment Banking in Slovenia

..............

67

Strategic Foreign Markets

...................................

71

Financial Markets in Slovenia

................................

91

Non-CoreMembers

.........................................

94

Risk Management

...........................................

96

IT and Cyber Security

.......................................

105

Human Resources

..........................................

108

Corporate Governance

......................................

111

Compliance and Integrity

...................................

119

Internal Audit

................................................

121

Corporate Governance Statements

.........................

122

Disclosure on Shares and Shareholders of NLB

............

144

Events After the End of the 2021 Financial Year

.............

146

Reconciliation of Financial Statements in Business and

Financial Part of the Report

................................

147

Alternative Performance Indicators

........................

149

NLB Group Chart

...........................................

167

Organisational Structure of NLB

............................

168

FINANCIAL REPORT

........................................

170

NLB Group Directory

.......................................

342

Definitions and Glossary of Selected Terms

................

345

![]()

NLB Banka, Prishtina

NLB Banka, Sarajevo

NLB Banka, Banja Luka

NLB Banka, Beograd

Komercijalna Banka, Beograd

NLB Banka, Skopje

NLB Banka, Podgorica

NLB, Ljubljana

We are – where you are.

Our home is here.

Here are our families, friends, colleagues, neighbours, our favourite athletes, hosts, who know

what kind of coffee we like … All this is our home and we believe in it with all our hearts.

Since we are where you are, we know your potential and understand your commitment –

even when no one else understands it. Where others merely see a spot on the map, we see

a region full of opportunities.

And we believe you deserve each and every one of them.

![]()

4

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Southeast Europe, a region ofopportunities.Southeast Europe, a region ofopportunities.Southeast Europe, a region ofopportunities.

Who

we

are

Vision

Our

strategic

focus

Sustainable

banking

The Group, headquartered in Ljubljana, is the

largest banking and financial group in Slovenia

with a strategic focus on selected countries in

SEE, which have a population of approximately

17 million people – our home region.

The Group is comprised of the leading and systemically

most important bank in Slovenia,

NLB

,

seven

subsidiary banks in SEE

, several companies providing

ancillary services (asset management, real estate

management, leasing, etc.), and a limited number of

non-core subsidiaries in a controlled wind-down.

1

The Group utilises a

universal banking

model

and supports its clients through retail,

corporate, and investment banking services.

On six out of seven markets where the Group

operates, the market share of member banks

exceeds 10% (measured by total assets).

1On 1 March 2022 NLB acquired the Slovenian Sberbank banka d.d. Further

information is presented in chapter

Events After the End of the 2021 Financial

Year

.

The Group will take

care of the financial

needs of its clients

and improve the

quality of life in its

home SEE region.

In 2021, the Group set the direction of sustainability

activities by publishing the

NLB Group Sustainability

Framework

and aligning its business model with UN’s

Sustainable Development Goals. The focus was on

decisive implementation of activities in the three pillars:

•

Contribution to society

•

Sustainable finance

•

Sustainable operations

As the first bank from Slovenia to commit to

the UN Principles for Responsible Banking,

the Bank performed an impact analysis and

published regional sustainability targets

(

NLB Group Sustainability Report 2021

).

The environmental dimension of the ESG was

addressed by upgrading our climate-related and

environmental risk management, integration of EU

Taxonomy regulation, and measuring the carbon

footprint of the Group’s own operations in 2021.

Focus was put on the social dimension, supported by

continuing CSR activities and the #HelpFrame project.

Become a regional

champion

Putting

clients first

Grow our

market position

Monetize

opportunities

and synergies

Ratings

NLB has an

investment grade rating

from S&P and Moody’s.

Note: Moody's:

unsolicited rating.

2021

S&P: BBB-

Moody's: Baa1

2020

S&P: BBB-

Fitch: BB+

Moody's: ↑Baa1

2019

S&P:

↑

BBB-

Fitch: BB+

Moody's: Baa2

2018

S&P: ↑BB+

Fitch: ↑BB+

Moody's: ↓Baa2

CI: BBB-

2017

S&P: ↑BB

Fitch: ↑BB

Moody's: ↑Ba1

CI: ↑BBB-

2016

S&P:BB-

Fitch:BB-

Moody's: Ba3

CI: BB+

![]()

Hedvika Usenik

Member of the

Management Board

(i)

Blaž Brodnjak

CEO and CMO

AndreasBurkhardt

Member of the

Management Board (CRO)

Antonio Argir

Member of the

Management Board

(i)

Archibald Kremser

Member of the

Management Board (CFO)

AndrejLasič

Member of the

Management Board

(i)

Note:

(i) Appointed by the Supervisory Board of NLB on 20January 2022; Mr. Argir, Ms. Usenik and Mr. Lasič are waiting for the relevant consent by the ECB to assume the office of the Management Board member.

![]()

6

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Encouraged by the economic recovery, driven by healthy

private consumption and strong loan demand, the Group

returned to robust growth, and achieved excellent results

which exceeded set guidance. This growth was based on the

strong underlying performance of all business segments,

meaningful contribution from Komercijalna Banka, Beograd,

while robust risk management supporting Group’s business

operations resulted also in strong asset quality. The Group

generated EUR 236.4 million in profit after tax and increased

market shares in all segments, with all banking members

operating in our home region, SEE, reporting solidly positive

net earnings and contributing 39% to the after tax result.

The results of the banking members prove once again that

they are becoming an increasingly important factor in Group

business operations, as well as in their respective markets – in

five out of six markets where the Group operates, the market

share (by total assets) of member banks exceeds 10 percent.

We firmly believe that further intragroupconsolidation, which

is in full swing following the successful merger of NLB Banka,

Podgorica and Komercijalna Banka, Podgorica in November,

as well as the sale of Komercijalna Banka, Banja Luka in

December, and the expected merger of NLB Banka, Beograd

and Komercijalna Banka, Beograd in April 2022, will bring

additional opportunities toleverage synergies.

The Group’s strong business performance, together with the

expiration of the BoS’s decision on restricting the dividends

payment, enabled the Bank to fulfil stakeholder expectations

with a substantial dividend payout. Keeping its promise, the

Bank paid out a total of EUR 92.2 million as dividends in 2021,

thereby reaffirming the Group's stable and successful business

operations, strong capital position, and solid dividend payment

capacity also for the future. More specifically, the Bank’s

ambition is a total dividend payment to the shareholders of

EUR 210 million in the 2022–2023 period.

In February 2022 the Slovenian parliament adopted law

concerning loan agreements in Swiss francs concluded

by banks operating in Slovenia (including NLB) and

individuals. NLB has used legal remedies against the law.

The implementation of the law is currently suspended by

Constitutional Court while its final decision on the conformity

Dear Stakeholders,

Are you well? How many times have you heard or asked this

question in 2021, a year marked once again by the grip of

COVID-19 and its consequent impact on the global economy

and quality of life? We sincerely hope that you were able to

do as we in the Group did: leave the epidemic behind you and

answer with “we are more than just well – actually, we are

stronger than ever.”

of the CHF Law with the Constitution is pending. If legal

remedies are unsuccessful, the estimated effects on pre-tax

result will be material but manageable.

2

In a remarkable milestone deserving special attention, the

Bank’s share price gained 67.2 percent YoY on the London

Stock Exchange, 66.4 percent on the Ljubljana Stock

Exchange, and received the ‘Prime Market Share of the Year’

award by the Ljubljana Stock Exchange.

Combining dividend payouts, privatisation proceeds, and the

residual value of the RoS equity stake in NLB, the Bank has

fully repaid the amount it received for the 2013 recapitalization.

From here on out, we are creating new value for all our

shareholders.

The Group will continue to prudently grow and increase its

market shares organically, however, we are closely monitoring

developments in our home region and will analyse and

address anyvalue accretive opportunities for newM&A-

based growth. The Bank has the capacity to buy banks and/or

portfolios in any of our existing, as well as other markets in the

region, thus becoming a true regional champion. Accordingly,

based on the SRB’s resolution scheme for Slovenian Sberbank

banka d.d. and decision of BoS regarding the sale of this bank,

NLB on 1 March 2022 bought 100% of shares of Sberbank

banka d.d. With this acquisition NLB contributed to the

financial stability of the Slovenian banking sector and further

improved NLB’s market position in Slovenia. In the following

months Sberbank banka d.d. will be integrated in NLB Group.

In spite ofprevailing global geopolitical challenges,

macroeconomic environment, andother impacts influencing our

business environment in a Slovenian and wider Group’s region

context,our outlookfor thefuture ispositive.

Turning our gaze to the future, our focus will be on providing

our clients with innovative solutionsand the best user

experience, 24 hours a day, every day. Currently in Slovenia,

our clients can fulfil almost all their banking needs without

having to visit a branch, and we strive to apply this digital

2Further information is available in chapters

Events after the end of the 2021

financial year

and

Outlook

2022

.

Statement by the Management Board of NLB

EUR

236.4

million

net profit of NLB Group.

![]()

7

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

leadership position to other markets in which our Group

operates by working on frontend solutions to consolidate

e- and m-banking platforms. Despite many predictions in

the past decades that banks will cease to exist, we are here

stronger than ever, since we have done our homework,

adapted, and started to invest heavily in digitalization, and

fintech technologies. Nowadays, the Group is no longer just

a banking group, but one of the largest IT and data science

companies in the region with an ambition to foster the

evolution of a local flexible digital ecosystem that offers clients

tailormade products and services. The Group is aware of a

cyber security risks and continuously improves the resilience

of its operations.

All of this fills us with confidence and sets good prospects

for the future. Our most important stakeholders, our clients,

understand what we offer them and value our contribution

to society. Ultimately, they are ready to recommend our

solutions, services, knowledge, and advice to their families,

friends, acquaintances, and their community.

This, however, could not be secured without a dedicated

team of colleagues who truly care about our mission and

go the extra mile when needed. That is why we strive to

attract, educate, develop, and retain best talents this region

has to offer. We are not only focused on the field of IT where

considerable effort has been made to attract the brightest

and best IT talent by building a technological hub in Belgrade

that will develop solutions for the whole group, but also in

other vocations of which an institution such as NLB Group has

no shortage.

We believe, that only a satisfied employee, one who feels

the firm’s trust and care for his or her work/life balance and

potential, will help us address the opportunities that await

us. That is why we continue to develop our employees and

search for new approaches that will confirm our care for

their well-being. This is why the Top Employer Institute has

also recognized us, awarding the Bank the prestigious ‘Top

Employer’ certificate for the seventh consecutive year.

We are also happy to report that in February 2022 the

Supervisory Board decided to expand the Bank’s Management

Board by adding three new members. After they receive their

respective licences, the Management Board will consist of six

members which will, in our firm opinion, significantly contribute

to the successful management of the Group and to meeting the

strategic commitments given to you, our stakeholders.

Nevertheless, it is not only the welfare of our clients, our

employees, and the rest of the stakeholders that is on our

minds and in our focus, but also the prosperity and the quality

of life in the entire region. Consequentially, the sustainability

of our business operations and practices is increasingly

becoming our priority. The Group is among the first in the

financial industry in the SEE to set ambitious ESG goals,

to withdraw support for projects using exclusively coal

technologies, to focus on becoming paperless, to actively

reduce its carbon footprint, and to work on introducing

products that promote sustainability and energy efficiency.

In the Group, we do not say in vain that this is our home. Here are

our families, friends, colleagues, neighbours, favourite athletes,

hosts who know what kind of coffee we like . . . here we can

breathe with full lungs, create, experience ups and downs, and

expand our ties together. Here are our thoughts and our hearts.

That’s why we can see what this region is capable of firsthand and

recognise its potential before anyone else. Because where others

see just a spot on the map, we see a region of opportunities.

Yours truly,

Management Board of NLB

Archibald Kremser

CFO

Andreas Burkhardt

CRO

Blaž Brodnjak

CEO & CMO

![]()

8

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

relentlessly pursue the best brain available out there, so we

can keep up with the fast-paced development to which we are

committed.

Group foundations are strong and robust, and we on the

Supervisory Board are of the opinion that the Group will

only grow stronger. If we are to come out of these uncertain

times feeling proud of ourselves and our decisions, strong

foundations are an absolute must. At the time this letter was

created, we have already acquired the Slovenian Sberbank

banka d.d., which, albeit early days, I dare to say, has a

potential to turn into a textbook case of how the Group can act

rapidly, with logical consistency, and flawless delivery of its

business strategy.

Still, while the past is behind us, with the memory fading

quickly in light of the recent developments, we have to

acknowledge the Group's remarkable business performance

in 2021 which led to a record high profits. Such an excellent

result proved that even in times of economic difficulties,

knowledge, experience, and sound business decisions based

on sustainable principles can generate success.

We believe the Group’s business results prove that its

objectives are set prudently and strategically, focusing on

the innovative, higher recurring growth financial products,

addressing digital innovation across our key markets.

Moreover, the past year has once again reaffirmed the

importance of banking members, which are key factor

not only in the Group’s business operations, but also in

their respective markets, where the majority of them hold

systemically important positions. We firmly believe that further

intragroup consolidation will bring additional opportunities to

leverage these synergies and further strengthen our position.

This way we will do everything needed to actually spearhead

the innovation trends in banking, and not merely defend our

market positions in the future at times when some worldwide

trends indicate that digitalization is set to disrupt the classical

banking model in the segment of consumer revenue.

The acquisition of Komercijalna Banka, Beograd at the end of

2020 exemplifies that we are able to execute on the complex

harmonisation process with NLB standards with regard to

the alignment of services, financial products, and support

Dear Shareholders,

The times we find ourselves in make me think of the following

quote which adequately reflects the logic we are trying to

pursue at our NLB Group: “In these uncertain times, we don’t

necessarily need more command and control over what we

already exercise in our regular business operations, but we

do need all possible means to engage everyone’s intelligence

whilst solving and addressing business challenges as they

arise.” Specifically, after the visible ease of the COVID-19

impact on business performance and the strong economic

rebound across our entire region which lifted our Group

performance on a record level, we are now awakening to a

world where worldwide sanctions imposed on Russia have

dramatically increased the markets’ volatility, and all the while

spill-over sector-specific effects are re-calculated over and

over again. Uncertainty looms all over the civilised world.

When it comes to our business, we need a calm and focused

mind, swift execution ability, and the determination to not

stray away from our core business growth strategy, keeping

the promises to all our stakeholders. We also need to

systems. Having said that, we are looking forward to the final

merger of our two banks in Serbia (Komercijalna Banka,

Beograd and NLB Banka, Beograd) in April 2022, enabling us

further push into the organic growth on that market.

We are aware the road ahead is filled with challenges.

However, the Group will continue to pursue its strategic

objectives, focusing mainly on intensive digitalisation and

providing top quality user experience, as well as sustainable

operations and development, whilst justifying the expectations

of its shareholders through dividend payments.

Our focus on EPS and DPS value accretive business decisions

remains intact, and we will never look in any other direction.

Referring to the above, we on the Supervisory Board can

only assure you the Group is transitioning towards the core of

our strategy, to be the talent magnet for tech and consumer

behaviour-savvy jobseekers, who are and will be able to

grasp with the challenges defining the future of banking.

2021 Business Developments

Following a pandemic-induced contraction in 2020, the

global economy recovered strongly in 2021. The rebound

was particularly strong after the re-opening of economies,

but thenthe momentum easedthroughoutthe yeardue to

rising headwinds in the form of supply chain bottlenecks,

inflationary pressures, and new COVID-19 outbreaks.

However, the impact of the pandemic on economic activity

faded over the course of the year.

Similar to global economic trends, the Group’s region

rebounded sturdily fromthe pandemic-induced contraction.

Private consumption was the main growth driver, and it was

propelled by credit growth, remittances, and pent-up demand.

Tourism-dependent countries benefitted in particular from

lifting restrictions at home and abroad, which resulted in the

rebound in the tourism sector over the summer. Nonetheless,

the Group’s region was not immune to the global surge in

commodity prices, rising energy prices and supply-chain

bottlenecks, which coupled with revival in domestic demand

resulted in increasing inflationary pressures.

Nevertheless, the economic rebound in 2021 had a positive

impact on banking systems in the Group’s region with lending

Statement by the Chairman of the Supervisory Board of NLB

Primož Karpe

President of the Supervisory Board of NLB

![]()

9

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

activity recording a notable revival in corporate, as well as

household loans while strong inflow of deposits continued

also in 2021. Positive developments reflected also in the

profitability of the banking systems of the Group’s region,

which recorded a notable improvement.

2021 Business Performance

The remarkable performance of the Group in 2021 led to a

record high profit of EUR 236.4 million – a substantial growth

from the previous year when excluding the effects from the

acquisition of Komercijalna Banka, Beograd, as unaudited

2021 data shows.

Top line growth continued throughout 2021, net interest

income growing by 37% YoY based on strong loan growth

also contributed by Komercijalna Banka group, adding EUR

98.5 million to that revenue line. With realised higher loan

volumes, the Group recorded growth in net interest income in

most of its markets in the region despite the still challenging

margin environment. Impressive growth in net fee and

commission income, up 39% YoY, further added to the Group’s

performance in 2021. Strong demand for investment products,

such as asset management products and bancassurance, and

at the same time strong income generation from increased

business activities (such as payments), led to increase in fee

and commission income. The Group managed to keep costs

within the guidance, also considering an important part

of Komercijalna Banka group integration costs. The Bank

remains a highly desired employer in the region, while the staff

cost is tightly managed by proactive approach to employment

through sourcing employees from all over the region.

The Group recorded 9% loan growth in 2021, thus exceeding

the full year guidance. Loans to individuals recorded double

digit growth throughout the group (12% or 13% excluding

impact of Komercijalna Banka, Banja Luka sale), driven

by strong production of housing loans in Slovenia and the

healthy demand for consumer loans in strategic foreign

markets. Deposits increased by EUR 1,243.6 million in 2021

on the Group level. Deposits from individuals increased by

a mere 5%, indicating that individuals migrated part of their

savings to alternative investments (e.g., mutual funds). The

strengthened liquidity and capital position, with a CET1 ratio

at 15.5% and TCR at 17.8%, ensure a comfortable capacity for

an ambitious shareholder pay-out and continued drive for

growth opportunities. Despite substantial growth, the Group

has managed to maintain RWA close to 2020 levels, helped

by inclusion of BiH and Macedonia on EBA's third party

equivalent list, and by conclusion of MIGA guarantees.

Net interest margin of 2.07% and operational business

margin of 3.28% have stabilised with TLTRO recognition of

interest income in Q4 having a marginal positive impact

in the last quarter. The cost-to-income ratio increased by

four percentage points YoY, to 62.3%, accounting for the

costs of Komercijalna Banka group integration process. The

extraordinary results from workout of the legacy NPL book

and material contributions from Komercijalna Banka group

on top, led to a EUR 35.8 million net release of impairments

and provisions for credit risk – ending the year at -41 bps

cost of risk. The Group established EUR 27.1 million of other

impairments and provisions, of which EUR 14.8 million for

HR restructuring charges in Serbia and the rest mostly from

litigation charges in Serbia – although the recent dynamic in

the latter is more favourable.

NLB Group maintains its corporate governance

principles in line with the highest standards

The Supervisory Board performed its work in accordance

with applicable laws (predominantly, but not exclusively with

recently changed the Companies Act (ZGD-1) and the Banking

Act (ZBan-3), as well as powers and procedures as set by the

Articles of Association of NLB and the Rules of Procedure of

the Supervisory Board of NLB. It carried out its function of

assuring efficient and active supervision over the management

of NLB and the Group in its duty of careful and scrupulous

performance, while adhering to the internal acts of the Bank.

In performing its duties, the Supervisory Board followed the

recommendations of the Corporate Governance Code for

Listed Companies. The Corporate Governance Statement of

NLBtransparently reveals deviationsfrom thementioned

code, as well as explains key aspects of the Bank’s corporate

governance, particularly the composition and work of the

Bank’s Management Board and Supervisory Board and

its committees, internal control mechanisms, and internal

control functions. It is published in the business part of this

Annual report. The Management Board adopted mentioned

statement on its session dated 1 February 2022 and the

Supervisory Board on its session dated 24 February 2022

and had no comments to it (recommendation 5 of the

aforementioned Code). Next year, the Supervisory Board

will report on implementing new recommendations made

with renewed version of the Corporate Governance Code for

Listed Companies, that will be first used for preparation of the

Corporate Governance Statement for the business year 2022.

At the end of 2021, the Supervisory Board was composed of 12

members, of which eight were representatives of shareholders

(in addition to Primož Karpe and Andreas Klingen, members

were also Gregor Rok Kastelic, Mark William Lane Richards,

Shrenik Dhirajlal Davda, David Eric Simon, Verica Trstenjak,

and Islam Osama Zekry) and four were representatives of

employees (Sergeja Kočar, Bojana Šteblaj, Janja Žabjek

Dolinšek, and Tadeja Žbontar Rems).

In 2021, the Supervisory Board held seven regular and 12

correspondence sessions. In its work, the Supervisory Board

of NLB received professional assistance from five operational

committees, namely: The Audit Committee, the Risk Committee,

the Nomination Committee, the Remuneration Committee, and

the Operations and Information Technology Committee. These

committees function as consulting bodies of the Supervisory

Board and in great detail discuss the materials and proposals

of the Management Board related to a particular area. Based

on their findings the Supervisory Board passed appropriate

resolutions. Each of the five committees is composed of at least

three members of the Supervisory Board.

Through the year, the Supervisory Board monitored the

implementation and effectiveness of the NLB Group’s strategy.

The Supervisory Board issued approvals to the Management

Board related to the Bank’s business policy, the Financial Plan,

and the Budget of the NLB Group, adopted the NLB Group

Annual Report, the NLB Group Sustainability Report, the NLB

Group Sustainability Framework, Pillar 3 disclosures for the

NLB Group, periodic business reports, adopted decisions

related to management of risk, reported on cost optimisation

activities, published the annual (and periodic) Internal Audit

Plan and Plan of Compliance & Integrity, adopted yearly

comprehensive opinion of the Internal Audit, adopted

performance assessments and appointments of directors of

Compliance & Integrity, and the Internal Audit.

The Supervisory Board adopted decisions with regards to the

convocation of the two General Meetings of shareholders,

gave consent to termination of office of the Management

Board (Petr Brunclík, COO with the termination of office

with effect on 30 June 2021) and gave consent to nomination

of a candidate for a member of a Supervisory Board. The

Supervisory Board gave consent to renovation of internal

policy on Internal Controls System; Rules and Procedures for

the Sustainability Committee; Review of the Diversity Policy;

New Remuneration Policy for Employees for the NLB and

the NLB Group; The Remuneration Policy of the Members

of Supervisory Board of NLB; and the Members of the

Management Board of NLB. It also gave consent to annual

![]()

10

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

self-assessment of employees performing special work and

approved achievements of the Management Board and

proposed new goals for the Management Board.

The Supervisory Board was active in adopting decisions

on establishment of new companies (in Serbia and North

Macedonia), cross-border financing and international

syndicated financing, transactions with MIGA, large

exposures, sale of receivables, claim write-offs, the divestment

of the Group companies, legal proceedings involving NLB

and the Group members, transactions with persons in special

relations with the Bank, Worker’s Council 2021 report, etc.

On the session of the Supervisory Board dated 20 January

2022, following the best practice selection and evaluation

process, the Supervisory Board appointed three additional

new members of the Management Board, namely: Hedvika

Usenik, Antonio Argir, and Andrej Lasič, thus expanding

it to six members in total. They all come from NLB or NLB

Group, have extensive experience and proven value

creating a positive track record. We believe that the Bank's

Management Board, supplemented with three new members,

is properly equipped for challenge that await us and offers

the best combination of various knowledge, experience, and

competencies. A five-year term of office for the new members

will start after they have obtained consent from regulator.

Until then, they will continue to perform the functions of

executive assistants to the Management Board.

Through the year, we acknowledged regular reports on

documents received from the regulator(s), namely the BoS and

the ECB, and on the implementation of the requirements of

mentioned regulators and adopted other amendments to the

internal policies.

With the aim of ensuring sustainable development, the

Group strives to actively contribute to a more balanced and

inclusive economic and social system through three lines of

actions: sustainable operations, sustainable finance, and

Corporate Social Responsibility. In 2021, the Group moved

from the awareness-raising phase, to the phase of actively

implementing sustainability elements into the business

model. Therefore, in 2021, the Bank adopted the NLB Group

Sustainability Framework and put in place the 4-level NLB

Group Sustainability Governance Structure, which is as follows:

(i) the Supervisory Board; (ii) the Sustainability Committee

(consultative body and a decision-making body of the

Management Board), (iii) the Sustainability Team, and (iv) the

NLB Group Working Groups. The Supervisory Board adopts

decisions related to sustainability issues in almost every session.

While members of the Supervisory Board have the proper and

complementary knowledge, experience, and skills to perform

their duties, they all have different professional, national, and

educational backgrounds. All the members of the Supervisory

Board have the necessary personal integrity and professional

ethics to hold their positions, which was confirmed by the

positive Fit & Proper assessment. This provides the assurance

that we can carry out our supervisory roles in a responsible

manner and make decisions that benefit NLB and add

value to the Group. The delivery of critical and assertive

opinions has been and will always remain at the core of our

decision-making principles through the expected engaged

participation of all the members. I can assure you we also

regularly upgrade the skills and the knowledge required for

the fulfilment of ourduties.

The Supervisory Board continued to act in accordance with

the highest ethical standards of management, considering

the prevention of conflict of interest. The Supervisory Board

members took precautionary measures to avoid any

conflicts of interest that might have influenced their decisions.

Throughout the year, there were 10 potential conflicts of

interest identified at sessions of the Supervisory Board, and

they were all handled with utmost professional due care.

Throughout the year, the Supervisory Board has maintained a

well-balanced professional relationship with the Management

Board and enjoyed timely, comprehensive, and data-

supported inputs from the latter, enabling the Supervisory

Board to adopt all its decisions in line with the professional

interests of the Bank, whilst always adhering to banking

regulations and itsstatutory powers.

Despite extremely demanding times during second year

of COVID-19 pandemic, the Supervisory Board members

assess that the Management Board managed to successfully

implement the NLB Group Strategy. The very solid financial

results of NLB Group in 2021 enabled the Bank to pay out

a total of EUR 92.2 million in dividends to the shareholders,

thereby reaffirming NLB Group’s stable and successful

business operations and strong capital position. The

Supervisory Board assesses that the NLB Group has

successfully utilised the opportunities offered to it by the

supportive economic environment of strong GDP growth

in the region, and that performance and results of the NLB

Management Board proved again we can have full trust in our

executive team.

Pursuant to Article 272 of the Companies Act (ZGD-1) and

the above report the Supervisory Board of NLB established

and ensured that it regularly and thoroughly monitored the

Bank’s and the Group’s operations in 2021 within its powers

and efficiently supervised the Bank’s and NLB Group’s

management and operations.

Review of the NLB Group Annual Report 2021

Pursuant to Article 282 of the Companies Act (ZGD-1), Article

50 of the Banking Act (ZBan-3), it is the obligation of the

Supervisory Board to examine the Annual Report together

with the auditor's report and the proposal for the allocation

of distributable profit presented by the Management Board.

The NLB Group Annual Report 2021 and unaudited financial

statements of NLB Group were examined by the Audit

Committee and the Supervisory Board at its meetings on 23

February and 24 February 2022.

Within the legal deadline, the Management Board of NLB

submitted to the Supervisory Board the NLB Group Annual

Report 2021, including the Business Report and the Financial

Report, with the audited separate financial statements of

NLB and the consolidated financial statements of the NLB

and its subsidiaries, and the auditor's opinion. According to

the auditor's opinion, in all material respects, the separate

and consolidated financial statements enclosed give a true

and fair view of the financial position of NLB and the NLB

Group as of 31 December 2021, the separate and consolidated

income statement, the separate and consolidated statement

of other comprehensive income, the separate and the

consolidated statement of changes in equity and the separate

and the consolidated statement of cash flows for the year

then ended, in accordance with the International Financial

Reporting Standards as adopted by the European Union.

It was also established based on the review of the business

report that the information contained in the business section

of the Annual Report is consistent with the audited financial

statements of the Bank and the NLB Group.

Yours truly,

Supervisory Board ofNLB

Primož Karpe

Chairman

![]()

11

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Strategic Members Overview

SloveniaSerbia

Bosnia and

Herzegovina

KosovoMontenegro

NLB Group

NLB,

Ljubljana

NLB

Lease&Go,

Ljubljana

NLB

Skladi,

Ljubljana

Komercijalna

Banka,

Beograd

NLB

Banka,

Beograd

KomBank

Invest,

Beograd

NLB

Banka,

Skopje

NLB

Banka,

Banja Luka

NLB

Banka,

Sarajevo

NLB

Banka,

Prishtina

NLB

Banka,

Podgorica

(vii)

Market position in 2021

Branches479

(i)

75--19028-4847363322

Active clients1,891,064

(ii)

675,310--975,033142,964-415,368213,112129,954230,01484,342

Total assets (in EUR million)21,57712,7001202,128

(iii)

4,16571521,771927728931751

Net loans to customers

(in EUR million)

10,5875,153100-1,796512-1,084471453635492

Deposits from customers

(in EUR million)

17,6419,660--3,425449-1,400

760

593799610

Result after tax (in EUR million)236.4208.4-0.99.034.84.30.039.018.210.024.410.1

Market share by total assets-26.3%-37.3%

(iv)

9.7%1.6%

(vi)

-16.9%19.1%

(viii)

5.4%

(v)

16.3%14.1%

Macroeconomic indicators for 2021

GDP (real growth in %)7.68.17.44.05.910.412.0

Average inflation (in %)2.92.04.13.22.03.32.4

Unemployment rate (in %)10.74.811.115.715.524.016.6

Current account of the balance

of payments (as a % of GDP)

-1.44.8-4.4-3.5-2.8-6.8-16.4

Budget deficit/surplus

(as a % of GDP)

-4.8-6.5-4.1-5.4-2.7-3.6-4.7

(i)

Including Komercijalna Banka, Beograd.

(ii)

Number of active clients of Komercijalna Banka, Beograd not included in total number of NLB Group active clients due to different definitions.

(iii)

Assets under management.

(iv)

Market share of assets under management in mutual funds.

(v)

Market share in the Federation of BiH as at 30 September 2021.

(vi)

Market share as at 30 September 2021.

(vii)

Merger of NLB Banka, Podgorica and Komercijalna Banka, Podgorica on 12 November 2021.

(viii)

Market share in the Republic of Srpska.

Table 1:

Strategic members overview

North

Macedonia

![]()

12

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Key Highlights

Financial

Performance

Strong business performance

marked by continuous loan growth,

increased fee and commission

income, one-off effects and

negative cost of risk

Business

Overview

Leading player in SEE

Asset

Quality

Good asset quality trends

with welldiversified portfolio,

prudent credit standards

and decisive workout

approach

Capital

& Liquidity

Strengthened capital and

liquidity position ensuring

capital return and continued

growth opportunities

Strategy

Committed to pursue the

strategic objectives

•

Profit a.t.

amounted to EUR 236.4 million.

•Strong

loan growth

of 12% YoY to

individuals, with the high production of

new loans (especially housing loans)

and 8% YoY to corporates, compensated

reduction in interest rates, and

supported net interest income.

•

The economic rebound led to the

optimisation of the investment portfolios

of households, and the growth of

housing loans, mutual funds, and

bancassurance, hence increasing

net

fee and commission income

(39% YoY;

14% YoY without the Komercijalna Banka

group contribution).

•Continuous

cost discipline

.

•

Non-recurring valuation income

in

the amount of EUR 14.8 million from

repayment of exposure, classified as

non-performing, EUR 9.0 million of other

operational income from the settlement

of legal dispute, and EUR 8.1 million loss

from the sale of Komercijalna Banka,

Banja Luka.

•

Positive impact of the release of

impairments and provisions for

credit risk

(EUR 35.8 million), mostly

due to successful repayment of on-

and off-balance exposures and

changed parameters related to

more

favourable macroeconomic forecasts.

EUR 27.1 million net established

other

impairments and provisions

, due to

restructuring provisions and provisions

for legal risk, mostly related to

Komercijalna Banka, Beograd.

•A robust and

sustainable universal

business model

with increased

focus on digitalisation and ESG.

•Striving to become a

regional champion

.

•

Higher

availability and

use of digital channels

–

awider range of 24/7 digital

solutions offered to clients.

•

The integration process of the

Komercijalna Bankabanks

with

the NLB banks in Serbia and

Montenegro is progressing as

planned. In Podgorica, the merger

was successfully completed in

November 2021, while in Serbia

the merger is on schedule to

be completed in the Q2 2022.

Komercijalna Banka in BiH was

successfully sold in December 2021.

•

Positive trends in asset quality

continued, resulting in a further

decline of the NPL ratio, and the

negative cost of risk.

•Well-diversified, stable, and robust

credit portfolio quality

.

•

Proactive approachto

workouts and more favourable

macroeconomic predictions

than expected contributed to the

negative

cost of risk

(-41 bps).

•The stable and low level of

NPE

(EBA def.) of 1.7% with a

comfortable NPL coverage ratio of

57.9%.

•No asset quality deterioration was

observed in

loans with expired

moratoriums.

•

The capital position

was

comfortably above regulatory

requirements (TCR of 17.8%, 1.2

p.p. higher YoY). Inclusion of the

negative goodwill recognised at

the acquisition of Komercijalna

Banka, Beograd as of 30 June 2021,

and partial inclusion of the 2021

result on one side and successful

RWA optimisation measures

undertaken on the other, had a

positive impact on the capital

position.

•In 2021, the Bank paid out

acumulative

dividend

of

EUR 92.2 million.

•

The liquidity position

of the Group

remained very strong, with a high

levelof unencumbered liquid

assets in total assets (38.3%). The

strong deposit

base demonstrated

client confidence in the Group.

•The Bank participated in the

ECB

TLTRO III operation

. The positive

lending performance will partially

compensatethe negative outcome

from holding liquidity reserves.

•The Bank continues to

execute

its strategic initiatives

as

well as

explore new business

opportunities

on both domestic

and other regional markets where

the Group is not yet present.

•

The digital leadership position

in Slovenia is being applied

to other markets in which the

Group operates. The vision is

to become one of the best data

science companies in the region

to productively use customer

data and

to evolve a local flexible

digital ecosystem

offering

products and services for clients.

•Continue to serve the community

aiming to

improve the quality

of life

in the Group’s region.

Driving

business value through

sustainability

and commitment

to enhance the management

of environmental and social

risks of its operations, and

meeting stakeholders’ needs and

expectations.

![]()

13

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Key Performance Indicators

202120202019

NLB GroupNLBNLB GroupNLBNLB GroupNLB

Income statement data

(in EUR million)

Net interest income409139300139318158

Net non-interest income

(i)

258222205173199197

Net non-interest income (BoS)

(i)

294

232360180219204

Total costs

(i)

-415-184-294-180-305-191

Operating costs (BoS)

(i)

-451-193-311-188-321-198

Result before impairments and provisions

(ii)

252

178

211131212164

Impairments and provisions934-71-17-114

Gains less losses from capital investments in subsidiaries, associates, and joint ventures1-1-4-

Result before tax261211

278

114215

178

Result of non-controlling interests11-3-8-

Result after tax236208270114

194

176

Financial position statement data

(in EUR million)

Total assets21,57712,70019,56611,02714,1749,802

Gross loans to customers10,9035,25010,0334,7537,9384,718

Impairments and deviations from FV-316-97-388-158-334-129

Net loans to customers10,5875,1539,6454,5957,6054,589

Financial assets5,2083,0345,1203,0173,8303,169

Deposits from customers17,6419,66016,3978,85111,6127,761

Equity2,0791,5521,9531,4511,6861,333

Non-controlling interests137-170-45-

Total off-balance sheet items4,6553,4894,6713,6844,2223,644

Key financial indicators

a) Capital adequacy

Total capital ratio17.8%24.6%16.6%27.1%16.3%22.6%

Tier 1 ratio15.5%20.3%14.2%22.3%15.8%21.8%

CET 1 ratio15.5%20.3%14.1%22.3%15.8%21.8%

Total RWA (in EUR million)12,6676,70912,4216,0299,1865,225

RWA / Total assets58.7%52.8%63.5%54.7%64.8%53.3%

b) Asset quality

NPL coverage ratio 1 (coverage of gross non-performing loans with impairments for all loans)86.1%75.1%81.8%76.0%89.2%76.2%

NPL coverage ratio 2 (coverage of gross non-performing loans with impairments for non-performing loans)57.9%60.6%57.3%57.9%65.0%56.7%

NPL coverage ratio (EBA definition)

(iii)

58.4%60.8%56.9%55.3%64.5%55.5%

NPL coverage ratio (EBA definition) (BoS)

(iv)

58.4%60.8%56.9%55.3%64.5%55.5%

NPL volume (in EUR million)

367

130475208375

169

NPL ratio (internal def.; NPL / Total loans)2.4%1.5%3.5%3.0%3.8%2.8%

Net NPL ratio (internal def.; net NPL / Total net loans)1.0%0.6%1.5%1.3%1.4%1.3%

NPL ratio (EBA definition)

(iii)

3.4%2.4%4.5%4.0%4.6%3.3%

NPL ratio (EBA definition) (BoS)

(iv)

2.4%1.5%3.4%2.8%3.8%2.7%

NPE ratio (EBA definition)1.7%1.1%2.3%1.9%2.7%2.0%

NPE ratio (EBA definition) (BoS)

(v)

1.7%1.1%2.3%1.9%2.7%2.0%

Received collaterals / NPL61.7%60.0%60.7%65.8%66.6%72.0%

NPL collateral received / NPL (EBA definition)58.8%63.1%42.4%43.5%35.4%33.6%

Credit impairments and provisions / RWA-0.3%-0.4%0.5%0.1%-0.1%-0.3%

Table 2:

Key financial indicators for NLB Group and NLB

Further details on the definition of certain indicators in this table are available in the chapter

Alternative Performance Indicators

.

(i)

Data for 2019 are adjusted to the changed schemes as prescribed by the BoS (relocation of some items from net other income to other general and administrative expenses).

(ii)

Result before impairments and provisions of NLB Group for the year 2020 does not include negative goodwill.

(iii)

Loans and advances without loans and advances classified as held for sale, cash balances at CBs and other demand deposits.

(iv)

Loans and advances including cash balances at CBs and other demand deposits.

(v)

The carrying amount of debt instruments measured at fair value through other comprehensive income (FVOCI) is increased by value adjustments due to impairments.

(vi)

Calculated on the basis of average total assets.

(vii)

Calculated as Net income from operational business (NII - Tier 2 bonds expenses + Net fee and commission income + Recurring net income from financial operations) / Average total assets.

(viii)

As per share register of KDD.The shares are listed on Ljubljana Stock Exchange.The Bank of New York Mellon (the 'GDR Depositary') represented in the share register of KDD as one holder is not the beneficial owner of shares, it holds shares in its

capacity as the depositary for the GDR holders.The GDRs representing shares are issued against the deposit of shares and are listed on London Stock Exchange. Therefore, the number in the share register of KDD does not represent all final beneficial

owners of the Bank shares. The rights under the deposited shares can be exercised by the GDR holders only through the GDR Depositary and individual GDR holders do not have any direct right to either attend the general meeting of bank's shareholders

or to exercise any voting rights under the deposited shares.

(ix)

Including Komercijalna Banka, Beograd.

(x)

Including Komercijalna Banka, Beograd, Komercijalna Banka, Banja Luka and Komercijalna Banka, Podgorica.

(xi)

Unsolicited rating.

![]()

14

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

202120202019

NLB GroupNLBNLB GroupNLBNLB GroupNLB

c) Profitability

Net interest margin (BoS)

(vi)

2.0%1.2%2.0%1.3%2.4%1.7%

Financial intermediation margin (BoS)

(i)

3.4%3.1%4.4%3.1%4.0%3.9%

Operational business margin

(vii)

3.3%2.3%3.2%2.5%3.8%2.9%

ROE b.t.11.8%14.0%15.4%8.2%12.7%13.4%

ROA b.t.1.3%1.8%1.8%1.1%1.6%1.9%

ROE a.t.11.4%13.8%15.4%8.2%11.7%13.3%

ROA a.t.1.1%1.8%1.8%1.1%1.5%1.9%

d) Business costs

Operating costs / Average total assets (BoS)

(i)

2.2%1.6%2.1%1.8%2.4%2.2%

CIR

(i)

62.3%50.8%58.3%57.9%59.0%53.9%

Total costs / RWA

(i)

3.3%2.7%2.4%3.0%3.3%3.7%

Total costs / Total assets

(i)

1.9%1.4%1.5%1.6%2.2%2.0%

e) Liquidity

Liquidity assets / Short-term financial liabilities to non-banking sector48.9%59.4%56.1%65.8%54.7%63.8%

Liquidity assets / Average total assets40.2%47.4%51.8%54.9%44.7%52.1%

Liquidity Coverage Ratio (LCR)252.6%314.5%257.5%336.3%324.9%362.1%

Net stable funding ratio (NSFR)185.2%171.4%165.7%162.1%159.5%158.9%

f) Leverage ratio

Leverage ratio10.2%13.6%7.8%10.3%8.7%9.7%

g) Other

Market share in terms of total assets-26.3%-24.7%-23.8%

LTD

60.0%53.3%58.8%51.9%65.5%59.1%

Total revenues / RWA

(i)

5.3%5.4%4.1%5.2%5.6%6.8%

Key indicators per share

Shareholders

(viii)

-2,571-2,455-2,100

Shares-20,000,000-20,000,000-20,000,000

The corresponding value of one share (in EUR)-10-10-10

Book value (in EUR)103.977.697.672.584.366.7

Branches

Number of branches479

(ix)

75530

(x)

8031893

Employees

Number of employees8,1852,5108,7922,5915,8782,659

International credit ratingsRatingOutlookRatingOutlookRatingOutlook

S&PBBB-StableBBB-NegativeBBB-Stable

Fitch--BB+NegativeBB+Stable

Moody's

(xi)

Baa1StableBaa1StableBaa2Positive

Further details on the definition of certain indicators in this table are available in the chapter

Alternative Performance Indicators

.

(i)

Data for 2019 are adjusted to the changed schemes as prescribed by the BoS (relocation of some items from net other income to other general and administrative expenses).

(ii)

Result before impairments and provisions of NLB Group for the year 2020 does not include negative goodwill.

(iii)

Loans and advances without loans and advances classified as held for sale, cash balances at CBs and other demand deposits.

(iv)

Loans and advances including cash balances at CBs and other demand deposits.

(v)

The carrying amount of debt instruments measured at fair value through other comprehensive income (FVOCI) is increased by value adjustments due to impairments.

(vi)

Calculated on the basis of average total assets.

(vii)

Calculated as Net income from operational business (NII - Tier 2 bonds expenses + Net fee and commission income + Recurring net income from financial operations) / Average total assets.

(viii)

As per share register of KDD.The shares are listed on Ljubljana Stock Exchange.The Bank of New York Mellon (the 'GDR Depositary') represented in the share register of KDD as one holder is not the beneficial owner of shares, it holds shares in its capacity as the

depositary for the GDR holders. The GDRs representing shares are issued against the deposit of shares and are listed on London Stock Exchange.Therefore, the number in the share register of KDD does not represent all final beneficial owners of the Bank shares. The

rights under the deposited shares can be exercised by the GDR holders only through the GDR Depositary and individual GDR holders do not have any direct right to either attend the general meeting of bank's shareholders or to exercise any voting rights under the

deposited shares.

(ix)

Including Komercijalna Banka, Beograd.

(x)

Including Komercijalna Banka, Beograd, Komercijalna Banka, Banja Luka and Komercijalna Banka, Podgorica.

(xi)

Unsolicited rating.

![]()

15

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Outlook

Table 3:

Market performance and outlook for the period 2022-2023

2021 GuidancePerformance in 20212022

(iv)

2023

Regular incomeExceeding EUR 600 millionEUR 640.9 million~ EUR 670 million

> EUR 700 million

Costs

Initial increase in cost base in the year 2021,

costs projected around EUR 430million

including integration costs

EUR 421.4 million

(i)

Costs at 2021 level~ EUR 400 million

Cost of riskAround -20 bps-41 bps20-30 bps30-50 bps

Loan growthMid-single digit loan growth9%High single digit loan growthHigh single-digit loan growth

DividendEUR 92.2 millionEUR 92.2 million

(ii)

EUR 100 millionEUR 110 million

ROE a.t.> 10%11.4%

~ 10%,

(ROE normalized

(iii)

: 12%)

> 10%

(ROE normalized

(iii)

: > 12%)

(i)

Including integration costs: EUR 7.8 million G&A costs and EUR 5.9 million HR provisions.

(ii)

Further information is available in the chapter

Outlook 2022

.

(iii)

ROE normalized = Result a.t. w/o minority shareholder profit divided by consumed capital. Consumed capital computed as 13.06% of average RWA reduced for minority shareholder capital contribution.

(iv)

If legal remedies against the adopted law in February 2022 concerning loan agreements in Swiss francs concluded by banks operating in Slovenia (including NLB) and individuals are unsuccessful, the Bank estimated a negative pre-tax effect on the operations of NLB

and NLB Group should not exceed EUR 70 - 75 million. This would have a limited (up to 55 bps) negative impact on the capital position.

![]()

16

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Table 4:

NLB’s main shareholders as at 31 December 2021

(i)

ShareholderNumber of sharesPercentage of shares

Bank of New York Mellon on behalf of the GDR holders

(ii)

11,357,36856.79

of which Brandes Investment Partners, L.P.

(iii)

/>5 and <10

of which EBRD

(iii)

/>5 and <10

of which Schroders plc

(iii), (iv)

/>5 and <10

Republic of Slovenia (RoS)5,000,00125.00

Other shareholders3,642,63118.21

Total20,000,000100.00

(i)

Information is sourced from NLB’s shareholders book accessible at the web services of CSD (Central Security Depository, Slovenian: KDD - Centralna klirinško depotna družba)

and available to CSD members.The information on major holdings is based on the self-declarations by individual holders pursuant to the applicable provisions of Slovenian

legislation which requires that the holders of shares in a listed company notify the company whenever their direct and/or indirect holdings pass the set thresholds of 5%, 10%,

15%, 20%, 25%, 1/3, 50%, or 75%. The table lists all self-declared major holders whose notifications have been received. In reliance of this obligation vested with the holders of

major holdings, the Bank postulates that no other entities nor any natural person holds directly and/or indirectly 10 or more percent of the Bank’s shares.

(ii)

The Bank of NewYork Mellon holds shares in its capacity as the depositary (the GDR Depositary) for the GDR holders, and is not the beneficial owner of such shares. The

GDR holders have the right to convert their GDRs into shares. The rights under the deposited shares can be exercised by the GDR holders only through the GDR Depositary and

individual GDR holders do not have any direct right to either attend the shareholder’s meeting or to exercise any voting rights under the deposited shares.

(iii)

The information on GDR ownership is based on self-declarations by individual GDR holders as required pursuant to the applicable provisions of Slovenian law.

(iv)

Further information is available in chapter

Events after the end of the 2021 financial year

.

The Bank’s shares are listed on the Prime Market sub-

segment of the Ljubljana Stock Exchange (ISIN SI0021117344,

Ljubljana Stock Exchange trading symbol: NLBR) and the

GDRs, representing shares, are listed on the Main Market

of the London Stock Exchange (ISIN: US66980N2036 and

US66980N1046, London Stock Exchange GDR trading symbol:

NLB and 55VX). Five GDRs represent one share of NLB.

Shareholder structure of NLB

![]()

17

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

KeyEvents

January

New member of the Supervisory Board:

Tadeja Žbontar

Rems was elected as the member of the Supervisory Board of

the Bank – representative of workers.

‘Top Employer’ certificate:

The Top Employers Institute

awarded the Bank the prestigious ‘Top Employer’ certificate

for the 6

th

consecutive year.

February

Quick loans:

Increased accessibility of quick loans for

individuals via video call.

April

Feefor customers balances:

TheBank introduced a monthly

fee for average monthly balances of individuals’ assets over a

certain threshold (currently EUR 100,000).

Increased shareholding in KB, Beograd:

After the Bank

acquired additional shares, its shareholding in Komercijalna

Banka, Beograd increased to 88.28%.

Change in Management Board:

Petr Brunclík, member of the

Management Board and COO, agreed with the Supervisory

Board on the termination of his office taking effect on 30 June.

May

Newpayment methods:

NLB, as the first bank in Slovenia,

introduced the Flik P2M payment method and is offering a

new debit Mastercard for individuals and legal persons.

June

New member of the Supervisory Board:

Islam Osama Zekry

was confirmed as a new member of the Supervisory Board.

Dividend payment:

The Bank paid the first instalment of

dividends in the amount of EUR 12.0 million.

Bankarium:

The first banking museum in Slovenia was

opened for the public.

July

ECB stress tests:

The results of stress tests carried out for

important banks by the ECB to assess the resilience of

financial institutions were disclosed. The result ranks the

Group among banks with solid resilience.

3

Avgust

Advertiser of the Year:

Slovenian Chamber of Advertising has

awarded NLB the title Advertiser of the Year for 2020. NLB was

the only bank in history to receive such award in Slovenia.

September

New products in offering:

The Bank began offering an

extraordinary overdraft with a gradual decrease and

automatic renewal for individuals, as well as a new health

insurance option.

October

Dividend payment:

The Bank paid the second instalment of

dividends in the amount of EUR 12.8 million.

Marketing award:

The Marketing Association of Slovenia

awarded the Bank with the main award in the category

‘Determination of Marketing Strategies’for theproject

‘StrategicInitiative of CustomerFocus.’

3For more information see the chapter

Risk Management

.

November

Consolidation of operations in Montenegro:

The merger of

NLB Banka, Podgorica and Komercijalna Banka, Podgorica

was completed.

4

December

Sale of KB, Banja Luka:

The Bank successfully sold 100% of its

ordinary shares of Komercijalna Banka, Banja Lukato Banka

Poštanska štedionica, Beograd.

Expanding leasing activities:

The Group initiated activities for

expanding leasing operations in Serbia and North Macedonia.

M-bank Klikpro:

M-bank Klikpro was upgraded with a new

digital signing solution.

NLB share awarded:

NLB shares (NLBR) received the

Ljubljana Stock Exchange Award, ‘Prime Market Share of the

Year.’

Supervisory and Management board transactions with

NLBR shares:

Primož Karpe, Chairman of the Supervisory

board, bought 200 ordinary shares of NLB. Blaž Brodnjak,

CEO & CMO and Archibald Kremser, CFO both bought 100

ordinary shares of NLB.

Dividend payment:

The Bank paid an additional incremental

dividend in the amount of EUR 67.4 million, contributing to the

2021 cumulative payout of EUR 92.2 million.

4For more information see the chapter

Strategic Foreign

Markets

.

JanuaryFebruaryMarchAprilMayJuneJulyAugustSeptemberOctoberNovemberDecember

![]()

18

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

higher in comparison to the bottom of 2020. Since peaking in

November 2021, the Bank’s stock moved slightly lower over the

remaining part of the year.

In 2021, the Ljubljana Stock Exchange modified its

methodology for calculation of key indices with which a share

of NLBR increased from 8.71% on 21 December 2020 to 18.05%

on 20 December 2021. The increased weight in local indices

and the strong capital market activity with NLBR in 2021 led to

NLB winning the ‘Prime Market Share of the year’ award for

the first time. In October, the Bank signed an agreement with

InterCapital to provide the service of market making in NLBR

shares with the intention of narrowing the bid-ask spread and

increasing liquidity of shares.

NLB Shares and GDRs

In 2021, European banking sector stocks continued their

recovery that was initiated towards the end of 2020. In

general, European banking sector stocks managed to

gradually recover all of the pandemic-induced drop from

March 2020 over the course of the year, with some of the

banks being among the better performers of the stock market

rally since the end of 2020. European banking sector stocks

recorded an increase in value of around 34% in 2021. However,

European banking sector stocks finished the year below the

2021 peak reached in November and even slightly below the

2020 pre-pandemic peak reached in February 2020.

The Bank’s stocks more than recovered the pandemic-

induced drop in the Bank’s stock price from March 2020.

The Bank’s stock price recorded an increase of around 66%

in 2021, contrasting the approximately 40% growth in the

Slovenian Blue Chip Index SBI Top, and the 34% growth in

European banking sector stocks in the year. In fact, the Bank’s

stock entirely recovered the pandemic-induced drop from

2020 by the beginning of the summer 2021, and then continued

to gradually move higher over the remaining part of the year.

As such, the Bank’s stock price ended the year approximately

17% higher in comparison to the peak of 2020, and 123%

Market Performance of NLB’s Shares and GDRs

Table 5:

NLB share information

Share information31 Dec 2021

Total number of shares issued20,000,000

Highest closing price (in 2021)EUR 80.6

Lowest closing price (in 2021)EUR 42.0

Closing price as at 30 December 2021

(i)

EUR 76.2

NLB Group book value per shareEUR 103.9

NLB Group earnings per share (EPS)EUR 11.8

Price/NLB Group book value (P/B)0.73

Dividend per share (for the previous business year)EUR 4.61

Market capitalisation

(i)

EUR 1,524,000,000

(i)

No market on 31 December 2021.

NLB Shares(NLBR) received

the Ljubljana Stock Exchange Award:

Prime

Market Share

of the Year.

![]()

19

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Investor Relations’ function

The Bank participates in varied forms of engagement, such

as investor meetings, calls, conferences, and roadshows,

reflecting the diverse nature of the Bank’s ownership

structure. Transparent communication with investors and

analysts allowed for dialogue promotion on strategic

developments, as well as on the recent financial performance

of the Group. The Bank promoted greater awareness and

understanding of operating businesses, developments, and

events which have an influence on the performance of the

Bank’s share price. Since the listing, six analysts released

research reports about the Group. Performance of the Bank is

covered by analysts from JP Morgan, Deutsche Bank, Wood &

Company, Citi, InterCapital, and Raiffeisen Bank International.

IR presentations, financial reports, and important information

are available on the Bank’s website in line with IR’s

Financial

Calendar

.

Indices

The Bank’s shares are included in several indices: the

SBITOP index, SBITOP TR index, and ADRIA prime index of

the Ljubljana Stock Exchange; the FTSE Frontier Index, MSCI

Frontier, and MSCI Slovenia; the S&P Eastern Europe BMI,

S&P Emerging Frontier Super Composite BMI, S&P Extended

Frontier 150, S&P Frontier BMI, S&P Frontier Ex-GCC BMI, S&P

Slovenia BMI; as well as the STOXX All Europe Total Market,

STOXX Balkan Total Market, STOXX Balkan Total Market ex-

Greece & Turkey, STOXX EU Enlarged Total Market, STOXX

Eastern Europe 300, STOXX Eastern Europe 300 Banks,

STOXX Eastern Europe Large 100, STOXX Eastern Europe

Total Market, STOXX Eastern Europe Total Market Small,

STOXX Global Total Market, and STOXX Slovenia Total Market.

Figure 1:

NLB shares’ price movement on the Ljubljana Stock Exchange and NLB GDR’s price movement on the London Stock Exchange (in EUR)

Shares (NLBR)GDR (NLB)

GDR

Shares

18.00

17.00

16.00

15.00

14.00

13.00

12.00

11.00

10.00

9.00

8.00

7.00

6.00

5.00

4.00

3.00

2.00

1.00

0.00

85.00

80.00

75.00

70.00

65.00

60.00

55.00

50.00

45.00

40.00

35.00

30.00

25.00

20.00

15.00

10.00

5.00

0.00

Jan 2021

Feb 2021

Mar 2021

Apr 2021

May 2021

Jun 2021

Jul 2021

Aug 2021

Sep 2021

Oct 2021

Nov 2021

Dec 2021

Source: Ljubljana Stock Exchange, Bloomberg.

![]()

We are your loyal partners.

Great-grandfathers built bridges.

Grandfathers built factories.

Fathers built the internet.

Your goal is to build the future.

New builders of the future are driven by the same pioneer spirit that has accompanied this region for decades.

You also are not going to sit and wait for better times to come along, instead you want to create them yourself.

We are right here by your side, following the trends and always developing new solutions which will inspire and

encourage you to create change. The same way we helped others before you.

![]()

21

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Globaland European

economy

Since the strong rebound resulting from the re-opening, the

momentum has eased throughout the year because the global

rebound has faced several headwinds that have influenced

the momentum. The surge in demand for goods has faced

production chain bottlenecks, and has resulted in supply-

demand imbalances. As a consequence, inflation pressures have

emerged in all economies with disruptions in energy, food, and

commodity markets that have been reflected in increased prices.

Inflationary pressures have been passed on to consumers and

lasted longer than initially expected. The labour market is still yet

to recover completely, but labour shortages have been evident in

several economic sectors. The pandemic continued its grasp on

economic activity also in 2021, but to a much lesser extent than in

the previous year. New outbreaks weighed on economic activity

by extending existing and originating new supply constraints. As

such, business survey measures of output and new orders moved

below their peaks recorded in Q2, while consumer confidence

deteriorated in many countries in the last months of the year.

Nevertheless, global industrial production and retail sales

remained above pre-pandemic levels, although they have also

recorded easing momentum over the course of the year.

In the Euro area, economic activity rebounded sharply in H1 in

line with the improvement in the health situation.The main driver

of the rebound has been private consumption that was fuelled

by the pent-up demand and a reduction in the household saving

ratio. These have been driven by diminishing forced savings

when the restrictions started to be gradually lifted in spring. This

propelled the recovery in services which followed the recovery in

manufacturing. Nevertheless, a sharp resumption in economic

activity has resulted in supply-demand imbalances and has

created vast supply disruptions and bottlenecks. The latter has

influenced momentum slowing down the rebound and causing

economic activity to ease after peaking in the summer. Global

supply chain bottlenecks have been a significant constraint on

industrial production and goods trade throughout the year.

Supply bottlenecks, increasing producer prices, coupled with

a surge in energy prices, and stronger demand as a result of

the reopening of the economy have caused a strong increase

in inflationary pressures. The latter has resulted in a surge in

In 2021, following a pandemic-induced

contraction in 2020, the global economy

recorded a strong although imbalanced

recovery. In general, global economic activity

has managed to surpass pre-pandemic levels,

but the recovery has remained incomplete and

uneven across countries as well as sectors.

headline, as well as core inflation rates as inflationary pressures

have become more and more broad-based and have been

mainly passed on to consumers over the course of the year.

The strength of the labour market in 2021 was reflected in the

decreasing unemployment rate throughout the year, while

pockets of labour shortages have emerged and have become a

sector-specific issue.

Monetary policy authorities kept the notion of transitory

inflation for the large majority of the year, but rapid resumption

in economic activity, rising inflation rates, and labour market

conditions improvement forced them to reconsider monetary

policy stances. In the Euro area, the ECB has maintained very

favourable financing conditions in 2021 withTLTRO-III and the

Pandemic emergency purchase programme (PEPP) playing

their parts in supporting the Euro area recovery. Nevertheless,

the pace of purchases under the PEPP have decreased

throughout the year, and at the December meeting, the ECB

outlined the discontinuation plan for the programme. The net

purchases under the programme discontinued in March 2022,

which was in accordance with its design. However, the ECB

has also decided to temporarily increase purchases under the

regular asset purchases programme in order to provide some

sort of a transitional period, but subsequently implemented

a quicker slowdown of the programme. In the US, asset

purchases tapering was announced and outlined in November,

but sustained price pressures prompted the Fed to drop the

notion of transitory inflation and to double the tapering pace,

which also resulted in moving forward the timeline of rate hikes.

At the March meeting, the Fed actually raised the rate by 25 bps,

with additional rate hikes set to follow.

The global economy is expected to continue with the recovery

in 2022. The impact of pandemic on economic activity has

considerably waned over time, and it should further wane over

the coming years, resulting in a restoration of demand patterns

and an easing of supply disruptions and inflationary pressures.

However, the recovery may quite possibly remain unbalanced

across countries and sectors. In the Euro area, the strong output

recovery that is underway is expected to continue in 2022. GDP

growth is expected to moderate to 3.6% in 2022, with forces

of the re-opening set to fade out. Growth in the Euro area will

be primarily driven by strong private consumption in light of

households reducing the saving rate to normal levels on the back

Macroeconomic Environment

economic growth

in the Euro-area

in 2021.

5.3%

economic growth

in Slovenia

in 2021.

8.1%

7.6%

economic growth

in the Group’s

region in 2021.

![]()

22

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

in particular, will push up inflation in the coming months. In fact,

inflation could rise even further and remain elevated for longer

due to commodity price surge and additionally due to second

round effects, in terms of the impact on the underlying inflation,

wage growth and higher inflation expectations. This erodes

household purchasing power and together with a squeeze on

company profits, and deteriorated business and consumer

confidence will weigh on economic growth. Consequently, with

elevated downside risks to growth and upside risks to inflation,

the risks of stagflation have increased.

The economy in the

Group’s region

The Group’s region rebounded strongly from the pandemic-

induced economic crisis, in line with global economic trends.

Private consumption has been the main driver of the growth in

the Group’s region. Private consumption has been spurred by

credit growth, remittances, a strong tourism season, and pent-up

demand despite the fact that labour markets in some countries

have still not escaped the impact of the pandemic-induced crisis.

Private investment has solidified although there have been some

differences in dynamics between countries. Strong export demand

from the EU market and industrial production supported growth

in BiH, North Macedonia, and Serbia, while Montenegro and

Kosovo benefited in particular from the rebound in the tourism

sector over the summer. Nevertheless, the Group’s region was not

able to circumvent the global surge in commodity prices, rising

energy prices and supply-chain bottlenecks. Coupled with firming

domestic demand, this resulted in inflation increasing over the

course of the year. Fiscal policy remained accommodative and

monetary policy rates were kept at historical lows.

of further diminishing forced and precautionary savings. Another

driver is business investment, which is expected to recover

substantially, and which will be additionally supported by the

Next Generation EU funds. The withdrawal of emergency support

measures targeting firms and households should result in a

tighter fiscal policy stance, while the ECB gives the impression

of being headed for the exit from the accommodative monetary

policy. Supply chain bottlenecks and the surge in energy prices

are expected to sustain inflationary pressures in 2022 with

inflation being projected to be higher. Strong labour demand

and likely further improvement in the labour market is expected

to drive the unemployment lower. However, there are still

some risks to the outlook. Despite the weakened impact of the

pandemic on economic activity, it still represents some degree

of risk. Furthermore, supply bottlenecks could be more severe,

prolonged, and widespread than expected, while the emergence

of new sources of supply bottlenecks is also possible. Protracted

staff shortages could drag on economic activity and exacerbate

supply chain issues. Inflation could continue to surprise on

the upside and turn out higher than expected. If inflation

expectations become entrenched at higher levels, more broad-

based price increases could not be excluded. Moreover, with

costs pressures being passed-through to consumers, inflationary

pressures could become even more widespread.The latter could

undermine households‘ purchasing power and impact the main

growth driver. Geopolitical tensions in Eastern Europe adds yet

another layer to the overall pile of risks to the outlook. The war in

Ukraine has several economic implications resulting in a renewed

downside risks to global growth, with Europe being the most

exposed in this regard. Elevated uncertainty, potential energy

supply disruptions, more widespread commodity shortages and

new supply chain disruptions will weigh on the economy. A surge

in commodity prices, with oil and gas prices accelerating higher

A macroeconomic snapshot for the

NLB Group’s region

In

Slovenia

, economic activity surpassed its pre-pandemic level in

2021 on the back of a revival in private consumption, investment,

and strong international demand. The economy expanded rapidly

in H1. Since then, import growth has outpaced export growth and

external trade made a negative contribution to the economic growth.

Nevertheless, this negative contribution was more than offset by

continued growth in private consumption and investment, while the

fiscal policy stance also played its part in supporting the economic

activity. Similarly, to other the Euro area economies, the economy

has not been immune to supply chain bottlenecks and inflationary

pressures. Inflation accelerated in Q3, and continued with acceleration

in Q4, with energy prices being the main driver.

In

Serbia

, after experiencing a mild contraction in 2020, the economy

exceeded the pre-pandemic output level and rebounded strongly

in 2021 on the back of a strong increase in private consumption and

investment, both more than offsetting the negative contribution of net

exports and lower government consumption. Robust wage growth

in the year propelled household spending, while a sharp rebound in

oil prices and increase in food prices resulted in an acceleration of

inflation over the course of the year.

In

North Macedonia

, after contraction in Q1, a marked increase in

private consumption propelled a buoyant Q2. Remittance inflow

also played its part in boosting private consumption resumption by

bolstering households’ disposable incomes. Strengthened foreign

demand turned out beneficial for the external sector of the economy.

Inflation increased over the course of the year with pressures arising

mainly due to rising global energy and goods prices, as well as supply

chain disruptions.

In

BiH

, a recovery in external markets and the expansion of

domestic private consumption propelled the growth in 2021. Private

consumption was supported by credit growth, wages growth, and

remittances. However, in H2 the rebound in private consumption lost

some momentum, but high public and capital spending bolstered

the domestic economy somewhat. Inflation increased throughout the

year due to rekindled domestic demand and global trends in price

pressures.

In

Kosovo

, the economy recovered due to strong growth in domestic

and external demand. Lifted restrictions on travel across Europe

boosted tourism inflows. The rebound in the hospitality sector, while

strong remittances inflow upheld private consumption. Surging

exports of goods and services buoyed the economy when private and

public consumption lost momentum in H2. Higher prices for food and

energy have driven up price pressures over the course of the year.

Table 6:

Movement of key macroeconomic indicators in the Euro area and NLB Group region

GDP

(real grow th in %)

Average inflation

(in %)

Unemployment rate

(in %)

201920202021202220232019202020212022202320192020202120222023

Euro area1.6-6.55.33.62.71.20.32.65.32.27.68.07.77.27.2

Slovenia3.3-4.28.13.53.41.7-0.32.05.72.44.55.04.84.44.4

Serbia4.3-0.97.43.94.11.81.64.17.84.111.29.711.110.09.4

N. Macedonia3.9-6.14.03.43.70.81.23.26.12.517.316.415.715.114.7

BiH2.8-3.25.93.23.20.6-1.12.06.02.515.715.915.515.114.7

Kosovo4.8-5.310.43.94.22.70.23.36.32.625.725.924.023.022.2

Montenegro4.1-15.312.04.83.90.6-0.32.45.02.015.117.916.615.815.2

Source: Statistical offices, Focus Economics.

Note: NLB Forecasts are highlighted in grey.

![]()

23

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

form of the pandemic uncertainties, sturdier and prolonged

elevated inflation, and the long-term impact of supply-side

bottlenecks. Economic implications of the war in Ukraine add

yet another layerof uncertainty.

In

North Macedonia

, the growth in 2022 should be mainly

driven by private consumption, being the key part of the

firming domestic demand. Coupled with strengthening foreign

demand, it should lead to solidexpansion. Nevertheless,

pandemic-related uncertainty, high energy prices, and

prolonged disruption of supply chains represent the main

downside risks to the outlook. Economic implications of the

war in Ukraine represent an additional risk to the outlook.

In

BiH

, economic growth should remain solid, being

supported by higher capital and public spending. That said,

the pandemic-related uncertainty, slower recovery in export

markets, and political stalemate represent the downside risks

to theoutlook. Higher inflation and economic implications of

the war in Ukraine represent an additional risk to the outlook.

In

Kosovo

, the economy should see robust, but cooled-down

economic growth in 2022 due to the lower base effect. Firming

capital expenditure growth and a tighter labour market are

seen as supporting factors for activity with the additional

beneficial effect of a healthier external backdrop. Pandemic-

related uncertainty and lingering political uncertainty are

downside risks to the outlook. Additional downside risk arises

due to the overall economic implications of the war in Ukraine.

In

Montenegro

, further growth in the tourism sector should

propel the economy to recover the pre-pandemic level, but the

In

Montenegro

, the economy rebounded strongly with the

improvement of the epidemiological situation and the opening

of borders which propelled a resumption of tourism. After

a sluggish start, tourism picked-up strongly in the summer

months. The rebound in the tourism sector boosted a surge

of private consumption which was the main driver of the

recovery. Inflation accelerated over the course of the year with

higher commodity prices and firming demand driving price

pressures.

Macroeconomic outlook for

NLBGroup’s region

In

Slovenia

, economic activity is expected to continue

growing, with domestic demand envisioned as being the

main driver. Private consumption and investment, propelled

by EU funds, should be key drivers of GDP growth. The labour

market will drive the unemployment rate lower. After the 2021

pick-up in inflation, the acceleration of inflation is expected

to continue in 2022 with high energy prices continuing to

drive the headline inflation for most of the upcoming year.

Buoyant imports growth should outpace exports, resulting

in a negative contribution to the GDP growth of net exports.

Pandemic-relateduncertainties, althoughwaning, continue

to weigh on the outlook. Economic implications of the war in

Ukraine represent an even greater risk to the outlook.

In

Serbia

, growth is projected to return towards the pre-

pandemic path. Growth should be mainly driven by private

consumption and investment, as well as by more positive

net exports contribution. However, downside risks are in the

labour market is seen as requiring some more time to leave

the memory of the crisis completely behind. Downside risk to

the outlook relatesto thepandemic-related uncertainty and

possible implications on the tourism sector, although its effect

is fading. Downside risk arises due to the overall economic

implications of the war in Ukraine.

The economic growth in the

Group’s region

could be

around 3.7% in 2022. The recovery is expected to lose some

momentum as the external boost gradually fades and the

base effects wanes. Nevertheless, growth should be mainly

driven by firming private consumption and investment. The

tighter labour market could propel household spending and

wage growth. Further improvement in the tourism sector

should be beneficial, especially for tourism-dependent

countriesof the Group’s region. In themid-term, countries

of the Group’s region should also benefit from the Economic

and Investment Plan adopted by the EU, which aims to boost

more sustainable, green, digital, and people-focused growth.

However, supply disruptions, and rising commodity and

energy prices, which are set to be additionally affected by

the war in Ukraine, represent downside risks to the economic

outlookof the Group’s region. Persistently higher inflation

levels could undermine households’ purchasing power and by

that private consumption. This would hinder the main growth

driver thus impacting growth. Moreover, political tensions and

uncertainty in some countries of the Group’s region cannot

be disregarded due to its impact on economic confidence,

while economic activity in tourism-dependent countries is

particularly dependent on the path of the pandemic, in the

Group’s region as well as abroad, despite pandemic’s waning

effect on economic activity in general.

Table 7:

Movement of the balance of payment and fiscal indicators in the Euro area and NLB Group region

Current account balance

(% GDP)

Fiscal balance

(% GDP)

Public debt

(% GDP)

201920202021202220232019202020212022202320192020202120222023

Euro area2.31.92.72.52.6-0.6-7.2-6.8-4.0-2.783.697.399.097.596.5

Slovenia6.07.44.84.94.70.4-7.7-6.5-4.5-3.265.679.878.777.376.0

Serbia-6.9-4.1-4.4-4.3-4.4-0.2-8.0-4.1-2.9-1.751.957.055.655.553.4

N. Macedonia-3.3-3.4-3.5-2.8-2.7-2.0-8.2-5.4-4.6-3.940.751.253.855.456.3

BiH-2.7-3.6-2.8-2.9-2.91.9-5.3-2.7-1.9-1.432.536.737.337.236.9

Kosovo-5.7-7.0-6.8-6.8-6.3-2.6-7.1-3.6-2.2-2.117.622.423.825.526.3

Montenegro-14.3-26.0-16.4-14.4-13.5-2.9-10.2-4.7-3.7-2.976.5105.192.385.781.5

Source: Statistical offices, Focus Economics.

Note: Consensus Forecasts are highlighted in grey.

![]()

24

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

after recording negative growth in 2020. In Serbia, growth in

corporate loans slightly moderated, but remained firm, while

in Kosovo further improvement in corporate loans growth

was recorded. Montenegro and North Macedonia recorded

robust corporate loans growth, representing a remarkable

improvement in comparison to the last year. Considering

household loans, the dynamics were similar to the corporate

loans. BiH and Slovenia recorded a significant rebound in

household loans. Montenegro also recorded an improvement,

while Serbia and North Macedonia retained robust growth

The banking system in

theGroup’s region

The economic rebound in 2021 also had a positive impact on

the banking system in the Group’s region. Lending activity

recorded a notable revival in both, corporate and household

loans. The majority of countries of the Group’s region

recorded a notable improvement in corporate loans growth,

with Slovenia and BiH bouncing into the positive territory

Table 8:

Movement of key banking systems indicators in the NLB Group region, 2021

Corporate loansHousehold loansCorporate depositsHousehold depositsNet interest marginNPLCAR

in EUR

million

∆ % YoY

in EUR

million

∆ % YoY

in EUR

million

∆ % YoY

in EUR

million

∆ % YoY

2020, in %2021, in %in %

∆ pp YoY

in %

∆pp YoY

Slovenia9,3026.311,2635.18,99812.023,9536.81.81.41.6-1.018.2-0.1

Serbia16,1668.810,60611.110,84513.016,91913.63.02.73.5-0.221.7-0.7

N. Macedonia3,0038.73,2567.82,23711.64,9667.13.33.2

(i)

3.6

(i)

0.217.3

(i)

0.4

BiH4,4862.25,3365.52,83017.67,5136.82.42.4

(i)

5.5

(i)

-1.119.2

(i)

0.9

Kosovo2,33513.71,39918.61,12919.73,23713.84.54.52.3-0.415.2-1.2

Montenegro1,2777.31,4563.21,61626.62,19325.33.74.06.20.718.50.0

Source: Statistical offices, CBs, NLB.

Note: Net interest margin calculated on interest-bearing assets;

(i)

Q3 2021 data.

Figure 2:

LTD ratio in the Euro area and NLB Group region

20212020

Montenegro

Kosovo

BiH

N. Macedonia

Serbia

Slovenia

Euro area

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

Source: ECB, National CBs, NLB.

rates from the previous year. Kosovo recorded a marked

improvement in the household loans growth.

However, despite a notable improvement in the credit

activity, a strong inflow of deposits continued in 2021. Despite

remaining robust, corporate and household deposits growth

moderated to some extent in Slovenia and partially in Serbia.

In Montenegro, growth in corporate and household deposits

surged after last year’s outflow of deposits. In Kosovo, already

high growth in household and corporate deposits increased

further, while North Macedonia and BiH recorded a somewhat

less significant increase in the growth rate of corporate and

household deposits.

The net interest margin of the Group’s region banking systems

exhibit some differences. In general, net interest income was

driven by the increase in growth of lending contributing to

positive quantity effects on the movement of net interest, and

by the negative impact of price effects. The net interest margin

of the banking systems in the Group’s region is largely a

reflection of the two factors.

The capital adequacy of the banking systems remains solid,

well-capitalised, and the general improvement of the NPL

ratio suggest some improvement in the quality of banks’

portfolios.

The LTD ratio decreased in some of the Group’s region

banking systems since the inflow of deposits remained strong.

In general, the growth in deposits outpaced the growth in

![]()

25

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Figure 4:

Loans to non-financial corporations and household loans in the Euro area and NLB Group region in 2021

Household loans, % GDPLoans to non-financial corporations, % GDP

Montenegro

Kosovo

BiH

N. Macedonia

Serbia

Slovenia

Euro area

0% 10% 20% 30% 40% 50% 60%

Source: National CBs, National Statistical Offices.

Note: Q3 2021 annualised data for BiH and Kosovo.

loans, hence offsetting the effect of the revival in the credit

activity. The profitability of the banking systems of the Group’s

region improved, with ROE increasing in all countries of

the Group’s region. Profitability improvement was to the

great extent driven by the net release of impairments and

provisions.

Loans potential outlook

for the Group’s region

Loans to non-financial corporations and household loans

as a percentage of GDP levels of the Group’s region suggest

that the whole Group has the potential for further growth

when compared to the levels of the same categories in the

Euro area. The continued solid economic growth in the

Group’s region bodes well for loans’ potential. The growth

in the Group’s region should be predominantly driven by

private consumption and fixed investments, both important

components of loans’ potential, and both expected to exhibit

robust growth in 2022. Private consumption, as the most

important component of GDP, is expected to range from

around 3.0% in BiH to 5.9% in Montenegro. Fixed investment is

expected to be somewhere between 3.4% in Montenegro and

8.6% in North Macedonia, with the growth rate in the Group's

region in the upper half of that range. In general, stabilising

private consumption and fixed investment should have a

positive impact on lending activity in the Group’s region.

Figure 3:

ROE ratio in the Euro area and NLB Group region

20212020

Montenegro

Kosovo

BiH

N. Macedonia

Serbia

Slovenia

Euro area

0% 3% 6% 9% 12% 15% 18%

Source: ECB, National CBs.

Note: Return on average equity (ROAE) used for BiH; Q3 2021 data for BiH, N. Macedonia and Euro area.

![]()

26

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

The regulatory

environment in Slovenia

The Bank is subject to capital adequacy and liquidity rules

imposed by the EU (CRR/CRD), which govern the activities in

which banks may engage in, and are designed to maintain the

safety and soundness of banks, as well as limit their exposure

to risk. The CRD V was further transposed into the new

Banking Act (ZBan-3), which also regulates the participation

of employees in the management of the Bank, something the

Bank already encourages.

As a financial institution offering benchmark-based products,

the Bank meets its obligations under the Regulation 2016/1011

(BMR) and regularly monitors developments in this area by

adapting its operations to the requirements of regulators and

industry.

Due to the constant care for the interests of its customers,

especially the protection of their data, the legislation in the

field of personal data protection is also important for the

Bank. The Bank strictly adheres to its obligations imposed on

it by GDPR in both Slovenia and the Group. As the Slovenian

law, which would further supplement the regulation, was not

adopted either in 2021, further obligations for the Bank may

arise when the law will be adopted.

In the field of financial markets there were no significant

changes in regulatory environment in 2021. Limited

implications of latest upgrades of the Shareholders’ Rights

Directive (SRD II) that was transposed into the amended

Companies Act, have been duly implemented in the Bank’s

processes. The Bank complies with the provisions of MIFIR/

MIFID II and EMIR regarding financial markets transactions,

enhanced investor protection, transparency, and reporting

obligations.

The Group also takes into account and complies with the

regulations in the field of preventing money laundering and

During 2021, more than 100 changes in the

EU and Slovenian regulatory environments

were adopted with material effects on the

Bank and the Group. The Group strives to

be fully compliant with the existing and new

requirements. Disclosure of the most relevant

changes of legislation and regulation which have

an effect on the Group is presented herein.

terrorist financing. At the end of 2021, an amendment to the

Prevention of Money Laundering and Terrorist Financing Act

was proposed that will further remove certain inconsistencies

and ambiguities, relax certain requirements, and introduce

additional tools or options for the implementation of measures

by obliged persons.

Compliance with the Payments Act (PSD2) and regulatory

technical standards, which brought open banking into the

financial environment, required major changes to the Bank’s

information systems. The Bank is constantly monitoring new

regulatory requirements imposed by the regulator, is adapting

to them, and taking into account the best user experience.

Due to the COVID-19 epidemic in 2021, the RoS adopted several

intervention laws and measures which mainly affected the

Bank in the area of credit moratoriums and daily operations.

An ongoing activity from 2019 included the amendment of

policies and contracts due to EBA Guidelines on outsourcing

arrangements, that provide a clear definition of outsourcing

and specify the criteria to assess whether or not an

outsourced activity, service, process, or function (or part of it)

is critical or important.

In the EU’s policy context under the European Green

Deal, ‘sustainable finance’ is understood as finance to

support economic growth while reducing pressures on the

environment, and taking into account social and governance

aspects. The Bank is approaching the development of a

comprehensive policy on sustainable finance, comprising the

action plan on financing transition to low-carbon economy.

Regarding the upcoming legislation in the corporate

governance area, an amendment to the Companies Act

(ZGD-1) is in the process of adoption which will have an impact

on the Bank mainly in the area of relations with shareholders

and the exercise of shareholders’ rights, as well as information

on corporate actions (following SRD2).

Regulatory Environment

![]()

27

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

In the

Republic of Srpska

, a new Decision on the Bank’s

management system was published by the Banking Agency of

the Republic of Srpska, which has replaced five previous by-

laws and therefore required thorough changes of the Bank’s

internal acts. Also, the Law on the Protection from harassment

at work was published in October 2021. Next to these, the

local regulator published several by-laws related to liquidity,

reporting, credit risk management, etc.

In

Kosovo

, the local CB adopted the Instructions for using the

form on the origin of funds and determining the holder of the

property right and the Guideline on loan restructuring due to

COVID-19. The government of the Republic of Kosovo, and the

Ministry of Finance Labour and Transfers adopted the product

‘Diaspora Bonds’; the Deposit Insurance Fund of Kosovo

(DIFK) adopted the Rules on reporting, calculation, and

collection of premiums, testing the depositor compensation

system, and on administrative sanctions for members of the

DIFK. The Assembly of the Republic of Kosovo adopted the

Law onElectronic identification and trust services in electronic

transactions.

In

Montenegro

, the main activities in 2021 were dedicated

to the implementation of Law on Credit Institutions, Bank

Recovery and Resolution Law, together with a number of

by-laws for both legal acts. Also important is that some of the

by-laws have been changed before the start of its application.

No less important were the activities on implementation of

by-laws for Deposit Protection Act, as well as the Central Bank

of Montenegro Decision on the Central Register of Transaction

Accounts.

Regulatory environment

in the Group’s region

The regulatory environment in the rest of the region where the

Group operates was dominated by legislative and regulatory

changes related to the COVID-19 pandemic and minimising its

consequences in the financial sector and economies. There

were also local regulatory (prudential and macroeconomic)

measures adopted to ensure stable functioning of the

financial systems.

Serbia

continued harmonizing the business environment

with theEU framework through the adoption/amendments

of the new Law on Capital Market, the Law on Electronic

Invoicing, and the Law on Companies (all these to be enforced

successively). The National Bank of Serbia put more scrutiny

on the clients’ complaints and the process of refinancing loans

in the banks. Regulatory activities on COVID-19 continued with

the aim of mitigating the consequences of the pandemic both

for the economy and citizens.

In

North Macedonia

, COVID-19 pandemic-related laws

focused mostly on social support for vulnerable social groups,

and financial help for the affected companies. The AML law

was amended to transpose the EU legislation in the relevant

area so that Banks could use electronic identification in its

day-to-day activities. The National Bank of the Republic of

North Macedonia adopted the decisions, mostly in order

to harmonize with EU legislation and standards in the

area of required reserves, the methodology for identifying

systemically significant banks, and submitting and publishing

data on the performed activities in the payment operations.

In the

Federation of BiH

the most important decision of the

regulator in 2021 was the Decision on Internal Governance

System in the Bank, which represents an alignment of local

regulations with EBA Guidelines on Internal Governance.

Anew ‘Law on Accounting and Auditing in the Federation of

BiH’ must also be emphasized as it brings new accounting

frame in Federation of BiH. In the area of legal entity

legislation, there are new regulations related to the possibility

of using digitally signed documents in the registration of

a legal entity, but in this very moment technical and legal

support on the level of the state is not yet provided.

![]()

28

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

BUSINESS REPORT

![]()

29

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Despite the challenging and uncertain

economic environment, the Group has

continued to duly execute its medium-term

strategy. This includes focus on protecting

and strengthening its market position in its

home region, and actively participating in

the growth and consolidation of the market.

Digitalization, client centricity, and cost efficiency

remain some of key strategic orientations

to ensure delivery of the Group’s vision.

Strategy

Finishing integration of

Komercijalna banka, Beograd

Promoting the ESG agenda

Creating new business expansion

opportunities

Digitizing distribution channels

Supporting clients' expansion

Adding new financial products

Building strong customer support

Monitoring and increasing

stakeholder value

Becoming a great place to work

Continuing strategic

transformationinitiatives

Establishing diversified horizontal

businesses

Become a regional champion

The Group aims to further strengthen its role as a systemically

important financial institution in the SEE region, and strives

to become a market leader in all of its core markets and to

have a prominent role in the region’s development. With the

completion of the acquisition of Komercijalna Banka, Beograd

in 2020, the Group made an important step in this direction.

The Group believes there is significant potential from the

deal for the whole region given the complementary product

offerings of Komercijalna Banka, Beograd that enable the

Group to extend a number of products and services in the

Serbian market and increase its cross-border activity. In

addition, cost- and capability-related business synergies will

be derived from its integration within the Group and which will

be finished in 2022. It is estimated that the combined synergy

effects could result in over EUR 20 million annually from 2023

onwards. Further business synergies are expected from the

integration of Sberbank banka d.d. in the Group.

Putting clientsfirst

In retail banking, the Group continues to strive to become

closer to its clients by offering anchor products and the

most accessible and personalised digital services (e.g.,

omnichannel, marketplace) that suit their lifestyles. In

corporate banking, the Bank is looking to provide more

complex, cross-border products and services, and to find

new entry points in order to suit all its clients’ financial needs.

One of the key efforts is improved availability for all clients.

The Group has made itself available anywhere and anytime

by building a strong customer call centre and upgrading its

portfolio of digital sales channels. These now offer a growing

set of banking products and services, both for retail and

corporate clients.

Putting clients

first

Grow our market

position

Become a

regional

champion

Monetize

opportunities

and synergies

![]()

30

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

The Group regularly engages with all of its stakeholders in

defining what is material to both them and the Group. Avariety

of communication channels are used for an open and

transparent dialogue on sustainability related issues. Some

of the most important channels for communications with the

stakeholders (in addition tothe regular publicly available

periodic reports, presentations, and webcasts on the Group

performance) are the NLB Group Sustainability Report, the

CSR and Sustainability e-mail box, the corporate website, and

social media channels.

The Group’s employees represent its key resource: human

capital and are one of its main drivers for creating value.

Through the focus on recruitment, management, and the

continual development of employees, they are given the

opportunity to thrive by making the most of their talent and

experiences and adapt to a fast-changing world. They are

encouraged to act in a responsive, respectful, and result-

driven manner within and outside their work efforts. The

ambition is to truly involve the whole organisation in realising

the Group’ssustainability ambitions.

Monetize opportunities

andsynergies

Significant strategic business efforts are undertaken to

achieve business synergies across the Group, both in costs

and operational efficiency. The Group believes these can help

offset significant negative economic effects of the COVID-19

pandemic on the Group’s future business results. The Group

is fully engaged in re-establishing some of the key financial

services (leasing, factoring, etc.), thus diversifying its services

on a horizontal level.

The Bank is simultaneously monitoring additional M&A

opportunities (within consolidation processes in banking

sectors in the SEE) that could add value to the Bank’s

shareholders. It makes sense to actively participate in the

expected growth and consolidation of the market.

Continuing transformation

To facilitate the aforementioned strategic focus and support

continuoustransformationin an everchanging environment,

the Group is following an elaborated, comprehensive, and

detailed program plan to deliver its mission and financial

targets. The Group has identified a series of projects and

initiatives, and has also dedicated considerable investment

Digitalization

The Group continues to implement comprehensive and

substantial strategic efforts toward digital distribution and

operating models that have been accelerated by the COVID-19

pandemic. The new circumstances related to the pandemic

and the economic uncertainty continue to affect the growth

and acceptance of digital channels by our customers. The

Group was prepared for such a market trend, since it was

already the leading provider and innovator in its core markets

before the outbreak.

At the same time, the Group is striving to simplify and

automate processes in order to minimise their time and

costs. The focus on digitalization is to enable quicker and

better customer service, a higher level of internal processes

efficiency, and consequently additional cost savings.

The Group will continue to invest substantially in IT

infrastructure and its capabilities. The focus will be on

improving the speed IT can deliver results by adopting agile

methodology principles, the provision and implementation

of the best online experience for customers in the SEE, and

enhancing capabilities for processing data, modelling, and

the relevance of services to clients. One such example is

the already established technological hub in Belgrade that

develops solutions for the wholeGroup.

Due to the positive effects of working remotely during the

pandemic, the Group has developed a hybrid working model

(combination of work-from-home and work from the office)

initiative, thus offering more flexibility to its workforce and

achieving cost benefits at the same time.

Grow our market position

The Group is working to protect and strengthen its market

position as a systemic player in its home region. In order to

do this, the Group is monitoring how well it is adding value to

three types of its main stakeholders: shareholders, customers,

and employees. With respect to shareholders, the Group

views its decisions through a lens of maximising its return

on equity. With respect to customers, a net promoter score

(NPS) is monitored and tracked. With respect to employees, an

employee engagement metric is measured and analysed. In

addition to the mentioned key performance indicators, other

supporting indicators and benchmarks are tracked in order

to continually revaluate current projects and utilise those

insights for future decisions.

funds for their implementation. With the projects, all major

running change efforts are channelled into one overall

strategictransformation program.

The backbone of the strategy is strengthening customer-

centricity by establishing customer-based market

management, improving the understanding of clients,

reimagining digital client journeys, and accelerating

innovation to provide lifestyle and value chain services to

strengthen relationships.

The transformation program also focuses efforts into

increased operational efficiency, cost management,

and the improved utilisation of the Group’s capital.

Simultaneously,overall operational capabilities are

being enhanced by improving human capital, optimising

IT infrastructure, digitalizing internal processes, and

leveraging information capital. To drive the transformation,

a new change management platform was set up.

Brexit’s impact on the

Group’s performance

Due to the limited focus of the Group’s operations beyond the

SEE region, Brexit did not have any significant impact on the

Group’s business performance.

![]()

31

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Special attention is paid to continuous provision of services to

clients, their monitoring, health protection measures, and the

prevention of cyber attacks and potential fraud events. The

Group has established internal controls and other measures

to facilitate their adequate management. However, these

measures may not always fully prevent potential adverse

effects.

The Group is subject to a wide variety of regulations and

laws relating to banking, insurance and financial services.

Respectively, it faces the risk of significant interventions by a

number of regulatory and enforcement authorities in each of

the jurisdictions in which it operates.

The SEE region is the Group's most significant geographic

area of operations outside of the RoS and the economic

conditions in this region are therefore important to the Group's

results of operations and financial condition. As a result of any

instability or economic deterioration in this region, the Group's

financial condition could be adversely affected.

In this regard, the Group closely follows the macroeconomic

indicators relevantto its operations:

•GDP trends and forecasts

•

Economic sentiment

•

Unemployment rate

•

Consumer confidence

•

Construction sentiment

•Deposit stability and growth of loans in the banking sector

•

Credit spreads and related future forecasts

•Interest rate development and related future forecasts

•FX rates

•Other relevant market indicators

During 2021, the Group reviewed IFRS 9 provisioning by

testing

a set of relevant macroeconomic scenarios

toadequately

reflect the current circumstances and the related impacts in

the future. The Group established and developed multiple

scenarios (i.e. baseline, mild and severe) on the level of ECL

calculation:

•The

baseline scenario

presents a common forecast

macroeconomic view for all countries that are present in

the Group. This scenario is constructed with the purpose

to culminate various outlooks into a unified projection of

macroeconomic and financial variables for the Group. This

is in line with the concept that the Bank has a consolidated

view on the future of economic development in SEE. The

Risk factors

Risk factors affecting the business

outlook are(among others):

•The economies’ sensitivity to a potential

slowdown in the Euro area or globally

•

Widening credit spreads

•

Potential liquidity outflows

•

Worsened interest rateoutlook

•

Potential cyber-attacks

•Regulatory, other legislative and tax

measures impacting the banks

•

Geopolitical uncertainties

The economic momentum in the region where the Group

operates was affected by the COVID-19 pandemic. In 2021,

the Group’s region returned to growth on the back of revival

in private and investment consumption. However, it is not

possible to assume with a high degree of confidence that such

economic momentum will continue.

Lending growth in the corporate segment remained relatively

moderate, especially in the current circumstances. On the

other hand, the Group benefited from increased demand for

mortgage loan financing, especially in Slovenia, as well as in

banking subsidiaries. During 2021 impacts of the COVID-19

pandemic did not have a meaningful impact on the credit

portfolio quality. The Group faced a favourable NPLmovement

resulting in lower percentage of NPLs and positive effects

from on- and off-balance sheet collection. Credit risk is

usually materially increased in times of economic slowdown.

Notwithstanding the established procedures in the Group's

credit risk management, there can be no assurance that they

will be sufficient to ensure that the Group's quality of credit

portfolio or the corresponding impairments will remain at the

adequate level in the future.

The investment strategy of the Group, referring to the

Group’s bond portfolio kept for liquidity purposes, adapts

to the expected market trends in accordance with the set

risk appetite. While the Group monitors its liquidity position

and corresponding trends, impacts of credit spread and

interest rate fluctuations on its positions, any significant and

unanticipated movements on the markets or variety of factors,

such as competitive pressures, customer’s confidence or other

certain factors outside the Group's control, could adversely

affect the Group's operations and financial condition.

IFRS 9 baseline scenario is based on the NLB monthly

Economic Outlook that was created in April 2021.

•The macroeconomic rationale behind the

alternative

scenarios

is related to a range of plausible impacts of the

COVID-19 pandemic on economic development during

the next 3 years. The basis for the alternative scenarios is

related to the ECB's view of economic development after

the coronavirus outbreak since early 2020. Based on the

ECB illustration of a mild and severe scenario resolution of

the pandemic crisis through the lens of possible expected

impact on economic activity in the Euro area, the Group

developed both alternative scenarios. In general, the

mild scenario envisions a resolution of the health crisis

by the end of 2021 and a long-term reviving process of

the economy, while a severe scenario assumes a more

protracted crisis and permanent losses in economic

potential. These scenarios were included in the calculation

of ECL in accordance with IFRS 9 as of 30 June 2021. Apart

from this the Group had kept track of the latest economic

developments and changing official projections.

•The latest set of IFRS 9 scenarios for macroeconomic

variables is applied in the modelling process for the

probability of default (PD) and loss given default (LGD)

estimates. Nevertheless, the focus in macroeconomic

scenarios is on the trajectory of real GDP and the

unemployment rate over the projection horizon from 2021 to

2023. Both variables are included in the modelling process of

PD and LGD,respectively.

The Group established a comprehensive internal

stress-testing

framework

and

early warning systems

in various risk areas

with built-in risk factors relevant to the Group’s business model.

The stress-testing framework is integrated into Risk Appetite,

ICAAP, ILAAP, and Recovery Plan to determine how severe and

unexpected changes in the business and macro environment

might affect the Group’s capital adequacy or liquidity position.

Both the stress-testing framework and recovery plan indicators

support proactive management of the Group’s overall risk

profile in these circumstances, including capital and liquidity

positions from a forward-looking perspective.

Risk Management actions that might be used by the Group

are determined by various internal policies and applied

when necessary. Moreover, the selection and application

Risk Factors and Outlook

![]()

32

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

of mitigation measures follows a three-layer approach,

considering the feasibility analysis of the measure, its impact

on the Group’s business model, and the strength of available

measure.

Outlook

The indicatedoutlook constitutes forward-looking statements

which are subject to a number of risk factors and are not a

guarantee of future financial performance.

The Group is pursuing a range of strategic activities to

enhance its business performance. Interest rate outlook is

uncertain given the adaptive monetary policy of the ECB to

the general economic sentiment. The Bank is committed to

delivering sound financial performance.

The measures and potentials outlined in the above strategy

are reflected in the Group’s outlook for the 2022 to 2023 period

(Table 9). Potential effects of acquisition of Sberbank banka

d.d. are not included in the outlook.

Outlook 2022

Macroeconomic

The global economy is expected to continue with the recovery

in 2022. The impact of pandemic on economic activity has

considerably waned over time, and it should further wane over

the coming years. In the Euro area, output recovery is expected

to continue in 2022. GDPgrowth is expected to moderate to

3.6% in 2022, with the re-opening effects set to fade out. Growth

in the Euro area will be primarily driven by strong private

consumption and business investment, which is expected

to recover substantially, additionally supported by the Next

Generation EU funds. The withdrawal of emergency support

measures targeting firms and households should result in a

tighter fiscal policy stance, while the ECB gives the impression

of being headed for the exit from the accommodative monetary

policy. Supply chain bottlenecks and the surge in energy

prices are expected to sustain inflationary pressures in 2022

with inflation being projected to be higher. However, there are

still some risks to the outlook. Despite the weakened impact

of the pandemic on economic activity, it still represents some

degree of risk. Furthermore, supply bottlenecks could be more

severe, prolonged, and widespread than expected, while

the emergence of new sources of supply bottlenecks is also

possible. Protracted staff shortages could drag on economic

activity and exacerbate supply chain issues. Inflation could

continue to surprise on the upside and even more broad-

based price increases could not be excluded.The latter could

undermine households‘ purchasing power. Geopolitical

tensions in Eastern Europe adds yet another layer to the

overall pile of risks to the outlook. The war in Ukraine has

several economic implications resulting in a renewed downside

risks to global growth, with Europe being the most exposed

in this regard. Elevated uncertainty, potential energy supply

disruptions, more widespread commodity shortages and new

supply chain disruptions will weigh on the economy. A surge in

commodity prices, with oil and gas prices accelerating higher

in particular, will push up inflation in the coming months. In fact,

inflation could rise even further and remain elevated for longer

due to commodity price surge and additionally due to second

round effects, in terms of the impact on the underlying inflation,

wage growth and higher inflation expectations. This erodes

household purchasing power and together with a squeeze on

company profits, and deteriorated business and consumer

confidence will weigh on economic growth. Consequently,

with elevated downside risks to growth and upside risks to

inflation, the risks of stagflation have increased. Regarding the

Group’s region, the economic growth could be at around 3.7%

in 2022. The recovery is expected to lose some momentum.

Nevertheless, growth should be mainly driven by firming

private consumption and investment. Tighter labour market

could propel household spending and wage growth while

further improvement in the tourism sector should be beneficial

especially for tourism-dependent countries.That said, supply

disruptions, and rising commodity and energy prices, which are

set to be be additionally affected by economic implications of

the war in Ukraine, represents downside risks to the economic

outlook of the Group’s region because persistently higher

inflation levels could undermine households’ purchasing power.

Moreover, political tensions and uncertainty in some countries

of the Group’s region cannot be disregarded due to its impact

on economic confidence while economic activity in tourism-

dependent countries is particularly dependent on the path of

the pandemic, despite its waning effect on economic activity.

Revenues and loan growth

On the back of continuing economic rebound with strong

private consumption and business investment, the Group

expects high single digit loan growth in 2022. Retail Banking

in Slovenia is expected so see continuation of strong loan

growth also in 2022, with a healthy demand for mortgage loans.

Corporate and Investment Banking in Slovenia is also expected

to grow on the back of cross-border lending and revival in

investment spending. Strategic Foreign Markets will maintain

robust performance with loan growth expected to reach double

digit growth. Therefore, interest income growth is expected to

be primarily driven by loan book growth, and productive use

of liquid assets. Post COVID-19 opening of the economies and

introduction of high balance fees stimulated demand for fee

generating products and income. All of the above should result

in total regular revenues of around EUR 670 million in2022.

Table 9:

Outlook for the period 2022-2023

2022

(ii)

2023

Regular income~ EUR 670 million> EUR 700 million

CostsCosts at 2021 level~ EUR 400 million

Cost of risk20-30 bps30-50 bps

Loan growthHigh single digit loan growthHigh single-digit loan growth

DividendEUR 100 millionEUR 110 million

ROE a.t.~ 10%, (ROE normalized

(i)

: 12%)> 10% (ROE normalized

(i)

: > 12%)

(i)

ROE normalized = Result a.t. w/o minority shareholder profit divided by consumed capital. Consumed capital computed as 13.06% of average RWA reduced for minority

shareholder capital contribution.

(ii)

If legal remedies against the adopted law in February 2022 concerning loan agreements in Swiss francs concluded by banks operating in Slovenia (including NLB) and

individuals are unsuccessful, the Bank estimated a negative pre-tax effect on the operations of NLB and NLB Group should not exceed EUR 70 - 75 million.This would have

alimited (up to 55 bps) negative impact on the capital position.

![]()

33

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Costs and cost of risk

The Group will continue to pursue a strong cost containment

agenda addressing both labour and non-labour cost

elements. Total costs continue to be impacted by a business

environment witha visiblelabourcost inflationthroughout

the region. Additionally, the Group continues with its

investment activities into information technology upgrades,

amid the growing relevance of digital banking. Importantly,

integration costs associated with the acquired Komercijalna

Banka, Beograd will contribute to total costs in 2022. Based

on this, costs including integration expenses are expected to

remain at 2021 level.

The realised cost of risk in 2021 at -41 bps outperformed

previous outlook guidance for 2021 (around -20 bps) due to

very strong development in NPL resolution. It is expected

that resolutions will continue to positively impact cost of

risk in 2022, but with a diminished importance. Based on

assessed environment the expected cost of risk will be in

the range of 20 bps to 30 bps, and somewhat lower than

expected in the 2023 (30-50 bps).

Loan portfolio quality

The Group anticipates lending growth in all key segments.

Special focus will be given to the retail segment where the

Group experienced strong growth in the previous year. The

Group is very prudent in identifying any increase in credit

risk, as well as proactive in the area of NPL management.

On this basis well diversified and stable quality of credit

portfolio is expected during the year 2022. Potential

moderation of current positive economic trends due to

COVID-19 uncertainties might have a negative impact on the

existing loan portfolio quality, but its impact should not be

excessive.

Liquidity

From liquidity perspective, deposits at the Group level

are still increasing (in the Bank and in banking members),

although growth of retail deposits has moderated in H2

2021. The liquidity position of the Group is expected to

remain solid evenif a highly unfavourable liquidity scenario

materialises, as the Group holds sufficient liquidity reserves

in the form of placements at the ECB, prime debt securities,

and money market placements. Significant attention is given

to the structure and concentration of liquidity reserves, by

incorporating early warning systems, keeping in mind the

potential adverse negative market movements by further

shortening of the portfolio duration and classification of new

investments with longer duration as hold to collect in order

to decrease sensitivity to regulatory capital. High levels of

deposit inflows are putting an additional strain on profitability.

In June 2021 the Bank participated in the ECB TLTRO operation

and has drawn a credit tranche of EUR 750 million. The Bank

is considering early repayment in June 2022. If materialized,

this will not have a material impact on the Group’s liquidity

position.

Capital

The capital position represents a strong base to cover all

regulatory capital requirements, including capital buffers

and other currently known requirements, as well as the Pillar

2 Guidance. If legal remedies against the adopted law in

February 2022 concerning loan agreements in Swiss francs

concluded by banks operating in Slovenia (including NLB) and

individuals are unsuccessful, the Bank estimated a negative

pre-tax effect on the operations of NLB and NLB Group should

not exceed EUR 70 - 75 million. This would have a limited (up

to 55 bps) negative impact on the capital position, leaving

the Bank’scapital position comfortably aboveall current

requirements.

The Bank is exploring opportunities for MREL funding,

issuance of Tier 2, and potential issuance of Additional Tier 1

instrument(s) to further strengthen and optimize its capital on

solo and consolidated level. Based on transitional increase

of MREL requirement, the Bank in 2022 intends to strengthen

MREL eligible liabilities in the amount of around EUR 400

million. Also, in 2022 the Group continues with activities to

optimise RWAs.

M&A opportunities

The Group might explore further value accretive M&A

opportunities in its domestic and other regional markets

where the Group is not yet present with the aim to increase

shareholders’ value.

Dividends

The Bank’s general intention is to distribute dividends on

yearly basis in line with its capacity, while at the same time

fulfilling all regulatory requirements, including the Pillar 2

Guidance and risk appetite. 2021 YE capital calculation does

not include part of the 2021 result in the amount of EUR 100

million. Therefore, there will be no effect on the capital in case

the dividends are paid. The dividend payment in the year

2022 might be split in two instalments. The Bank envisages

cumulative dividend payout of EUR 210 million in the period

2022-2023.

COVID-19

Despite the COVID-19 related circumstances the Group

ensured continuity of service provision to its clients by

adjusting the Group’s offer, increased use of digital channels,

and enhancing customer experience. The Group is aiming to

further support its clients, by constant development including

creating flexible local digital ecosystem of offering products

and services.

Sustainability

The Group has committed to sustainability, and has been

enhancing the management of environmental and social

risks of its operations, among others to meet EBRD and MIGA

standards. It also substantially increased the use of digital

channels, improved customer experience, and aims to create

a flexible local digital ecosystem for offering products and

services.

In 2022, the Group intends to make sustainability more

tangible throughout the Group. The resourcesare shifting

towards a low-carbon economy and engaging with customers

is key in financing the transition. An important step forward

will be done by expanding the product portfolio with loans

dedicated to supporting energy efficiency and renewable

energy production and introducing digital only card. The

Group supports global decarbonization goals and aims to

expand the Group’s measurements of emissions to Scope 3.

Implementation of climate related and environmental risk

management follows ECB and EBA guidelines. Moreover,

participation in ECB climate-risk stress test exercise will

provide additional important insights, which will surely

have an effect on further adaptation of the existing Group’s

business model. Effective integration of sustainability-related

regulatory requirements will be important in 2022 for ESG

disclosures and reporting (e.g. EU Taxonomy, BASEL Pillar III).

The Group plans to make required steps in order to obtain our

first ESG rating. However, all of the above mentioned cannot

be achieved without highly motivated and adequately skilled

teams, hence relevant trainings will be an important part of

the working agenda.

![]()

34

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Impact oncredit

portfolio quality

COVID-19 did not have a meaningful impact on the quality of

the credit portfolio. The support schemes introduced by the

governments in theGroup countries providingmoratoriums

to eligible clients as part of the COVID-19 pandemic measures

phased out during 2021. As at 31 December 2021, the exposures

where COVID-19 moratoria were granted amounted to

EUR 1,681.5 million and represented 10.8% of the Group’s

credit portfolio. The exposure with the remaining COVID-19

moratoria was negligible and amounted to EUR 24.8 million,

while 98.5% of those moratoria already expired by 2021 YE. A

total of 86.4% of exposure with the expired moratoria have no

delays, while 2.1% had delays exceeding 90 days. The Bank is

very prudent in identifying any increase in credit risk.

Measures

The Group continued to take necessary measures to protect its

customers and employees by ensuring safety conditions and

making sure services offered by the Group were provided without

disruption. The vast majority of the products and services offered

by the Group banks are available to clients in digital form without

the need to visit a branch – and 24/7 client support by enhancing

the availability of digital channels was ensured.

The ‘Work from

Home’ initiative

In parallel, the plans to introduce a ‘work from home’ initiative

which pre-dates the COVID-19 pandemic was somehow

accelerated by the overall circumstances in the last two years,

and was well received by the employees. In this respect,

the pandemic provided a further push in the direction of

digitalisation of the Group’s business model.

Resilience of strategic

initiatives

The resilience of the Group’s strategic initiatives was well

demonstrated throughout the outbreak of the COVID-19

pandemic. The new ways of working enabled the avoidance

Following a very demanding year due to the

worldwide impact of the COVID-19 outbreak

having unprecedented effects around the globe,

the year 2021 was in general a return to new

normal and growth. Nevertheless, the disease

is still present and will continue to affect the

economies to various degrees despite increased

medical capabilities and an improved toolbox

against the struggle with the pandemic.

Though the COVID-19 pandemic, coupled with its implications

on all aspects of life and in particular on the business

environment, was still the region’s and world’s buzzword, the

Group managed to stay well capitalised, very liquid, and as

the business results show, also highly profitable.

of any significant delays in the envisaged execution timelines,

which should positively impact the Group’s future financial and

operational performance.

Impact onsustainability

The COVID-19 pandemic has had a substantial influence

on three of the most significant aspects of sustainability: the

society, economy, and environment. Its heavy economic burden

on societies is likely to leave persistent social scars, such as

greater inequality and poverty, as well as challenges regarding

affordability and access to basic needs. By understanding that

the pandemic has had direct effect on the economy, we have

decided to further support vulnerable groups and exempt

humanitarian organisations from paying commissions.

5

Although COVID-19 restrictions of movement and changes

of commuting patterns have altered in the past two years,

with the economy recovery in 2021 global emissions are

rising back to the pre-COVID level, which makes the fight

against climate change even more urgent.

6

This also resulted

in important and decisive steps in development of the

sustainability regulatory framework. In this regard, the Group

strengthened the role of sustainability within the Group and

amplified its activities: enhanced environmental and climate

risk management, performed impact and materiality analysis,

began measuring carbon footprint of own operations, and

strengthened corporate governance by establishing NLB

Group Sustainability Committee. For more information, please

refer to the

NLB Group Sustainability Report 2021

.

The year 2021 has proved that the Group adapted to ‘new

normal’ with distinction. Digitalization, inclusion, and

environmental protection have been some of the most

important drivers for us.We have used them to continue

developing progressive and digitalized services, and products

that support energy efficiency and thus a transition to a low-

carbon society.

7

5For more information, please refer to chapter

Sustainability

and subchapter

Corporate Social Responsibility

.

6IEA, 2021:

https://www

.

iea

.

org/reports/global-energy-review-

2021

/co2-

emissions.

7For more information, please refer to chapter

Corporate and Investment

Banking in Slovenia

.

Impact of COVID-19 on Operations

![]()

35

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Implementation of

sustainability intothe

Group business model

With less than a decade left to the 2030 deadline for achieving

globally set commitments towards ESG, several key pieces

of the EU sustainable finance legislation entered into

force, and the EU Fit for 55 (EUplan to reducegreenhouse

gas emissionsby 55% by 2030) unleashed wide-reaching

industrial changes that need to be implemented. The Group

has shaped a number of important developments, with results

such as:

Sustainability Framework

The NLB Group Sustainability Framework

was published

as a strategic document that highlights the ambitions and

commitments to the integration of sustainability in the Group’s

business model. Besides providing an alignment of the

Group’s sustainability approach with the

UN’s

Sustainable

Development Goals (UN SDG)

, it offers stakeholders a list

of sustainable economic activities promoted by the Group

and therefore sets out the basis for classifying financing as

sustainable. Moreover, the document addresses in detail ESG

risk management, the principles of responsible banking and

business ethics, and the Group’s corporate sustainability

governance structure.

Alignment of the Group’s sustainability

approach with the UN SDG:

SDG 3:

Ensure healthy lives and promote well-being for all at all ages

Sustainability, with a focus on climate issues and

covering other aspects of the environment as well

as broader ESG aspects, is an opportunity for

the Group to meet societal expectations, adapt

to a changing environment, and mitigate certain

risks. This has been demonstrated already in

the widespread actions taken by the Group.

SDG 7:

Ensure access to affordable, reliable,

sustainable, and modern energy for all

SDG 8:

Promote sustained, inclusive, and sustainable

economic growth, full and productive

employment, and decent work for all

SDG 12:

Ensure sustainable consumption and production

SDG 13:

Take urgent action to combat climate change and its impacts

Sustainability

![]()

36

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Principle 5:

Governance & Culture

Principle 6:

Transparency & Accountability

The Bank will fully implement all six principles and therefore

the required steps regarding impact analysis, target-setting &

implementation, and accountability by the end of 2024.

In 2021, the Group conducted an impact analysis

which resulted in target-setting, which represents the

implementation of the second principle for responsible

banking. The impact analysis identifies the most relevant and

significant positive and negative impacts of a bank’s portfolio

on the societies, economies, and environments that the bank

operates in. It is also the essential groundwork needed for

meaningful target-setting.

Materiality analysis

With the aim to keep the ‘double materiality’ concept in the

focus for the year 2021, the Group also decided for a traditional

(GRI) materiality analysis as a complement to the impact

analysis, since GRI materiality and stakeholder identification

can be used to further corroborate impact analysis findings

and so help with the setting of priorities.

Carbon footprint

In H2 2021, ‘The NLB Group Carbon Footprint Measurement

and Reporting Policy’ was adopted as an internal policy

on the calculation of the carbon footprint of the Group’s

own operations, and so provides the key methodological

approach for why and how the carbon footprint reporting

for the Group will be carried out. With reference thereto,

Impact analysis & target-setting

In 2020, the Bank signed the United Nations Environment

Programme Finance Initiative’s Principles for Responsible

Banking (UNEP FI PRB) which aims to align bank’s strategy

and practice with the UN SDG and the Paris Climate

Agreement.

Principles for Responsible Banking are as follows:

Principle 1:

Alignment

Principle 2:

Impact & Target Setting

Principle 3:

Clients & Customers

Principle 4:

Stakeholders

the Group considers the Green House Gas Protocol (GHG

Protocol), which represents the world’s most widely used GHG

accounting standard.

Sustainable financing

In 2021, over EUR 60 million of EU Taxonomy eligible long-term

loans were approved by the Bank (large corporates segment):

the Bank financed investments in energy infrastructure,

a telecommunications network, water supply network,

construction of cultural and school facilities, and energy

efficiency. Within the SME segment, sustainable financing

was at modest levels. At the end of 2021, the Bank and the

Group banking members set ambitious sustainable financing

goals for the years 2022–2025. Based on the analysis, the

focus will be on renewable energy sources, solutions for the

carbon footprint reductions, improving energy efficiency, and

supporting a circulareconomy.

EU Taxonomy

The unfolding of the EU Taxonomy regulation was closely

monitored by the Group representative in the European

Banking Federation’s Sustainable Finance working group,

which covered among other tasks the UNEP FI and EBA

project ‘The Application of the EU Taxonomy to Bank Lending.’

In 2022, the EU Taxonomy regulation will be fully implemented

in the Group financing process.

ESG Risk management

In 2021, substantial effort was made in implementing climate,

environmental, and social risk management requirements

in line with ECB and EBA guidelines. In recent years, the

Bank signed Framework Agreements with the EBRD and the

Contract of Guarantees with MIGA. It was therefore required

to develop a mechanism for environmental and social

screening of current and potential financing applications

against MIGA and EBRD Exclusion List and applicable

environmental and social laws. Consequently, the Group’s

existing risk management framework is constantly upgraded

with environmental and social elements. As a systemically

important institution, the Group is included into 2022 ECB

Climate Stress test exercise. More information is available in

Risk Management

chapter of this report.

Sustainability training

The Group’s ‘Sustainability on-line training program’ was

carefully prepared on the model of similar training programs

of the International Finance Corporation (IFC) and is

implemented throughoutthe Group. In thefuture,the Group

will conduct Sustainability training on a yearly basis.

![]()

37

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Sustainability working groups

Ad hoc

working groups are being set up in the bank to

introduce various elements of sustainability.Their composition

varies according to the area ofsustainability considered.

ESMS Officers have been appointed in our banking

members who regularly report to the local boards. They are

representatives of risk management line who ensure the ESMS

is properly implemented organisation wide.

Other sustainability-related topics

Many of these outcomes reflect ongoing, long-term

challenges, but at the same time they reflect the Group’s ability

to reach tangible results in this area. It should be mentioned

that in 2021 several other sustainability-related topics were

addressed, such as:

•

digitalization and paperless operations

•

remuneration policy

•CSR projects corresponding to UN SDG

•inclusion & diversity at the level of employees and clients

•building partnerships & capacities by being involved with

relevant representatives fromacademia, NGOs, and the real

economy sector

•talent development and care for employees

.

Roadmap for 2022

The Group sustainability roadmap for the year 2022 is full of

new challenges. As a UN PRB signatory, the Bank will consider

joining the UNEP FI’s Net Zero Banking Alliance, since it is an

accelerator that provides a dedicated forum to shape the net

zero journey of the banking industry. The Group is responsive

to the desire of investors, supervisors, and its peers and

other stakeholders to align its business model with net zero

objectives. The progress in achieving targets for 2030 and

2050, at the latest, in line with credible 1.5°C scenarios, is

however, not only dependent on the willingness and capacity

of a bank, but to a large extent on a complex sum of factors,

such as the availability of sustainable investments and

activities, transition projects, transformationcapacities of the

industry, as well as public and industrial policies supporting

transition.

The Group's sustainability ambition is anchored in its mission.

This is seen as an opportunity to help businesses not only

survive, but also to take initiative and position themselves for

future growth. Sustainability is at the centre of our business

model and a pillar for the transformation of the Group.

NLB Group Sustainability Governance Structure

The NLB Group Sustainability Governance Structure is

anchored at different levels within the Bank and the Group

thus guaranteeing that it receives attention from the highest

decision-making bodies while also being broadly integrated in

our operations.

In the Q3 2021, the NLB Group ‘Sustainability Committee’ was

established as part of corporate sustainability governance

developments and the first meeting was held in December

2021. It is chaired by the CEO and oversees the integration

of the ESG factors to the Group business model in a focused

and coordinated way across the Group and issues opinions,

recommendations, initiatives, and takesrelevantdecisions

when needed. The committee has the authority to discuss,

develop, and approve sustainability strategies, policies,

initiatives, methodologies, KPIs, targets, and other relevant

procedures of the NLB Group, and has influence over

sustainability-related strategic objectives.

Apart from anchoring sustainability at different levels within

the Bank in its daily operations (on the Management Board

level, Executive Management level, Group level, and Business

& Country level), NLB has put in place a 4-level NLB Group

Sustainability Governance Structure, namely:

Supervisory Board of the NLB

The Bank has established a comprehensive framework for

sustainable management, starting by sponsoring the matter

at the level of the NLB SB, which, significantly contributes

to the implementation of sustainability. The SB regularly

monitors the implementation of ESG factors and discusses the

topic on regular basis.

Sustainability Committee

It is composed of the highest-level officers and provides

the overall vision and sustainability strategy, it defines key

policies, reviews progress on major initiatives, decides on

specific external partnerships and agreements, and ensures

cohesion of the overall program with the Bank’s mission.

Sustainability Team

The Sustainability Team within Strategy and Business

Development Division of the NLB oversees Group-wide

sustainability agenda and is tasked with driving the culture,

monitoringimplementation of thestrategy, coordinating

initiatives, measuring the impact, and reporting on the

progress to the Sustainability Committee, the MB, and the SB.

For more information, please refer to

:

•

the chapter

Risk Management

, subchapter

Incorporating

ESG Risks

•

Note 6

of the Financial part of the report

•

the chapter

Statement

of Management of Risk

•

the Pillar 3

Disclosures

•the

NLB Group Sustainability Report 2021

Corporate Social

Responsibility

The Group contributes towards wider socio-economic

development through its CSR activities and is responsible to

its clients, employees, and the social environment. The Group

pays special attention to knowledge and lifelong learning.

The key pillars of the socially responsible operations of the

Group are care for its employees and protection of lawfulness

and integrity, as well as the promotion of entrepreneurship,

increasing financial literacy, support to professional and

youth sports, humanitarian activities, the protection of cultural

heritage, and care for the environment.

Every year, the Group strives to increase the share of CSR

activities that pursue UN SDG. The target for 2021 – at least

30% of all CSR activities in every bank member should be

aligned with UN SDG – was achieved, even more, some

member banks even exceeded it. At the same time, the Group

plans, not only to align key CSR topics within Group members,

but also to carry out more joint Group wide CSR projects. In

2021, the main two projects were #HelpFrame and Heartful

opportunities.

Understanding small

entrepreneurs’ challenges-

#HelpFrameproject

continued in 2021

The Group’s socially responsible actions have been

continuously upgraded with projects that follow the UN SDG.

The Group’s first such regional project was launched in spring

2020. The COVID-19 crisis closed the door to many dreams

in previous years. That is why the decision was made to give

a glimmer of hope with the #HelpFrame project for another

![]()

38

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

NLB Banka, Banja Luka

focused on both youth and the

elderly by providing 500 children with disabilities and socially

endangered families with New Year’s presents, and 500

elderly visitors from elderly centres withChristmas lunch and

bedding.

Following its tradition of the past years,

NLB Banka, Sarajevo

supported an orphanage in Tuzla to help children without

parents and families. The public institution, ‘Home for

Children without Parental Care Tuzla’ deals with the care

and upbringing of children without parental care, children

from dysfunctional families, and children found begging

and wandering the streets. They provide all of them with a

home, healthcare, regular education, clothes, and food. They

currently have 56 children of all ages – from babies to high

school students.

NLB Banka, Prishtina

also decided on a double donation. The

first went to the National Autism Association in Kosovo (ANAK)

which deals with the identification and support of children

with autismand theirfamilies. Thistime, the organisation

is promoting thetalents ofchildren with autismthrough

paintings. The second donation was donated to the Ideas

Partnership, an organisation that works mainly with Roma,

Ashkali, and Egyptian communities in the field of education,

health, social work, and the environment.

NLB Banka, Podgorica

’s donation supported the Rights

Centre for Children, a non-governmental organisation

that is, among others, helping children towards stronger

participation in the decision-making process and ensuring

their voices are heard, but also working with sensitive groups,

such as children from foster families and socially vulnerable

groups.

year in 2021. The project is our way of giving a helping hand to

local small entrepreneurs who have been most affected by the

situation in recent years. As part of the campaign, advertising

space was donated to 73 selected entrepreneurs in Slovenia

and 258 across the whole NLB Group. The participants

from 2020 were invited to become ambassadors of last

year's project and to share their positive experiences in the

#HelpFrame.

A world full of heart is a

world full of opportunities

The world is much more beautiful and colourful when

we stand by each other and with full hearts create new

opportunities – opportunities such as those that also arise

with our support. In all markets where the Group operates,

organisations that promote inclusion whether for children, the

elderly, or both with a charitable donation are supported.

In Slovenia,

NLB

donated to two humanitarian organisations,

Botrstvo and Humanitarček. The NLB donation to Botrstvo

will enable 200 disadvantaged children the opportunity to

develop their talent. In contrast, as many as 97,000 elderly

people live below the poverty line in Slovenia. With the help

of a donation, the Humanitarček association will be able to

provide them with 21,000 hot meals.

NLB Banka, Beograd

and

Komercijalna Banka, Beograd

donatedto the centre for youthintegration ‘SOS dečija

sela,’ anon-governmental, humanitarian, and non-profit

organisation that has been working to improve the quality of

life of children and youth without parental care, empowering

families at risk, supporting the economic independence

of young people from vulnerable groups, and providing

emergency assistance to local populations and refugees.

NLB Banka, Skopje

also decided to support both children

and the elderly by donating to a healthcare centre for the

elderly in Skopje and the Foundation for Educational and

Cultural Initiatives ‘Step by Step,’ and the Project ‘Be IN, Be

Inclusive, Be Included,’ that strive to improve the educational

opportunities for children with disabilities and contributes

to the development of an inclusive, non-segregated primary

education subsystem.

![]()

We are your neighbours.

Great-grandmothers saved up for hard times.

For grandmothers, education was the best investment.

Mothers invested in their own companies.

As modern women, you invest in dreams.

We support you through all life periods, help you successfully tackle challenges they bring, offer you useful solutions

and a reliable path towards realising the biggest and the most daring of goals. And even though your priorities

change throughout the years, ours remain the same: we help you with the best advice and provide you with new

opportunities at every step.

![]()

40

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

The Group’s result is based on the following key drivers:

•

Integration of Komercijalna Banka, Beograd, acquired

at the end of 2020, merger of NLB Banka, Podgorica and

Komercijalna Banka, Podgorica in November 2021, and the

sale of Komercijalna Banka, Banja Luka in December 2021;

•Strong 12% loan growth to individuals and solid 8% to

corporate, above 10% growth even without Komercijalna

Banka, Banja Luka;

•Net interest income increased EUR 109.8 million on the

back of the Komercijalna Banka group contribution (EUR

98.5 million). Net interest income without the Komercijalna

Banka group contribution also increased, based on higher

volumes and increased market shares in the loan book

compensating for the reduction in interest rates. In general,

net interest income was impacted by excess liquidity,

which determined a consequently higher volume of cash

and balances with CBs, with low or negative interest rates;

however, additional interest income was recognised based

on lower interest rates for TLTRO in the Bank in December;

•The economic rebound led to the optimisation of investment

portfolio of households, growth of housing loans, mutual

funds, and bancassurance, which increased net fee and

commission income (high balance deposit fees and net fees

from asset management and bancassurance);

•Lower non-recurring income, which in 2021 included

valuation income in the amount of EUR 14.8 million from the

repayment of exposure, classified as non-performing, EUR

9.0 million of other operation income from the settlement

of a legal dispute, and EUR 8.1 million loss from the sale of

Komercijalna Banka, Banja Luka; in 2020, the sale of NLB

Vita and debt securities had a positive effect on the result in

the amount of EUR 28.1 million;

•Continuous cost discipline; costs higher due to integration

costs and employee costs;

•Net impairments and provisions for credit risk were

released in the amount of EUR 35.8 million, mostly due

to the successful repayment of on-and off-balance

exposures and changed parameters related to more

favourable macroeconomic forecasts. Other impairments

and provisions were established in the amount of EUR

27.1 million, mostly due to restructuring provisions and

provisions for legal risk, mostly related to Komercijalna

Banka, Beograd;

The Group achieved a profit after tax in the

amount of EUR 236.4 million, 67.3% or EUR 95.1

million more than the year before (2020: EUR 141.3

million), if the positive impact of the acquisition of

Komercijalna Banka, Beograd in 2020 is excluded.

•NLB Skladi achieved 79.8% YoY growth of gross inflows

in mutual funds (EUR 252.4 million) and the assets under

management from NLB clients is approaching EUR 1.3

billion;

•A strong TCR of 17.8%;

•The negative CoR of -41 bps, given good asset quality trends

and a decisiveworkout approach;

•The multi-year declining trend of the non-performing

credit portfolio stock continued, mostly due to repayments,

collection, the sale of claims, and cured clients. The

combination of successful resolution of NPL and credit

growth of a high-quality portfolio resulted in the decrease

of gross NPL ratio (EBA def.) from 4.5% to 3.4% YoY, and the

NPE ratio (EBA def.) by 0.6 p.p. YoY to 1.7%;

•

Unencumbered liquidity reserves portfolio amounted to

EUR 8,280.6 million (38.3% of total assets).

Overview of Financial Performance

EUR

236.4million

of net profit.

Figure 5:

Profit after tax of NLB Group (in EUR million) / ROE after tax (in %)

(i)

ROE a.t.

225.1

203.6

193.6

269.7

236.4

20172018201920202021

14.4%11.8%11.7%

CAGR\*

1%

8.1%11.4%

\*Compounded Annual Growth Rate.

(i)

Komercijalna Banka group included from 2021 on.

![]()

41

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Income statement

Table 10:

Income statement of NLB Group and NLB

NLB Group

in EUR million

20212020

Change YoY

Q4 2021Q3 2021Q2 2021Q1 2021Q4 2020Change QoQ

o/w KB

contribution

Net interest income409.4299.6109.898.537%107.0103.7101.197.575.13.43%

Net fee and commission income237.2170.366.942.539%64.658.659.954.145.16.010%

Dividend income0.20.10.10.2101%0.00.10.00.00.0-0.1-65%

Net income from financial transactions38.432.06.58.120%5.07.420.85.32.0-2.4-32%

Net other income-18.32.6-20.8-17.9--9.6-3.8-2.0-2.8-1.0-5.8-154%

Net non-interest income257.6204.952.632.826%60.062.378.756.546.1-2.3-4%

Total net operating income666.9504.5162.4131.332%167.0166.0179.9154.0121.21.11%

Employee costs-231.3-165.0-66.4-54.9-40%-63.1-56.5-56.5-55.1-42.0-6.6-12%

Other general and administrative expenses-137.5-97.3-40.3-38.3-41%-43.4-31.7-32.6-29.8-27.6-11.7-37%

Depreciation and amortisation-46.5-31.7-14.8-13.4-47%-11.7-11.6-11.6-11.6-8.0-0.1-1%

Total costs-415.4-293.9-121.4-106.6-41%-118.2-99.9-100.7-96.6-77.7-18.4-18%

Result before impairments and provisions251.5210.541.024.719%48.866.179.157.543.5-17.3-26%

Impairments and provisions for credit risk35.8-62.398.13.4-1.83.314.816.0-13.2-1.6-47%

Other impairments and provisions-27.1-9.1-18.0-24.0-198%-18.32.9-11.3-0.5-7.9-21.2-

Impairments and provisions8.8-71.480.1-20.6--16.56.33.515.5-21.1-22.8-

Gains less losses from capital investments in

subsidiaries, associates, and joint ventures

1.10.90.20.027%0.20.50.30.10.0-0.4-68%

Negative goodwill0.0137.9-137.90.0-0.00.00.00.0137.90.0-

Result before tax261.4277.9-16.54.2-6%32.572.982.973.1160.2-40.4-55%

Income tax-13.5-5.2-8.42.5-162%-0.6-3.3-4.8-4.73.82.781%

Result of non-controlling interests11.53.08.41.5-1.03.92.93.8-1.1-2.9-75%

Result after tax236.4269.7-33.35.2-12%30.965.775.264.6165.1-34.8-53%

![]()

42

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

NLB

in EUR million

20212020

Change YoY

Q4 2021Q3 2021Q2 2021Q1 2021Q4 2020Change QoQ

Net interest income139.1138.90.30%37.434.233.833.734.53.29%

Net fee and commission income119.6104.515.114%31.230.030.827.627.31.24%

Dividend income79.66.373.4-74.70.40.04.55.574.2-

Net income from financial transactions19.028.1-9.2-33%0.81.814.71.63.0-1.0-55%

Net other income4.233.9-29.8-88%0.90.30.82.21.50.5160%

Net non-interest income222.4172.849.629%107.532.646.335.937.474.9-

Total net operating income361.5311.749.816%144.966.880.169.672.078.2117%

Employee costs-107.0-102.6-4.4-4%-28.4-26.8-26.0-25.8-25.4-1.6-6%

Other general and administrative expenses-59.1-60.00.92%-19.2-13.0-13.8-13.1-17.0-6.2-48%

Depreciation and amortisation-17.5-17.80.32%-4.3-4.4-4.4-4.4-4.30.01%

Total costs-183.6-180.5-3.1-2%-52.0-44.1-44.3-43.2-46.8-7.8-18%

Result before impairments and provisions177.9131.246.736%93.022.635.926.425.270.4-

Impairments and provisions for credit risk26.1-9.035.1-4.96.33.311.78.5-1.4-22%

Other impairments and provisions7.5-8.315.8-5.70.1-0.11.8-7.95.5-

Impairments and provisions33.6-17.450.9-10.66.43.213.50.64.266%

Result before tax211.5113.997.686%103.629.039.039.925.874.5-

Income tax-3.00.1-3.1--1.1-0.2-1.2-0.62.6-0.9-

Result after tax208.4114.094.583%102.528.837.939.328.473.7-

![]()

43

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Figure 6:

Profit after tax of NLB Group (in EUR million) – evolution YoY

98.5

42.5

-106.6

-20.6

-137.9

24.4

100.7

2.5

11.3

-4.6

-9.6

-14.9

0.2

-9.9

1.5

5.4

-10.8

2020

269.7

109.8

66.9

-14.2

-121.4

80.1

0.2

-137.9

-8.4

-8.4

236.4

Net interest incomeNet fee and

commission income

Other net non-

interest income

Total costsImpairments and

provisions

Gains and

losses

(i)

Negative

goodwill

Income taxResult of non-

controlling interests

2021

NLB Group w/o KBKB

(i)

Gains less losses from capital investments in subsidiaries, associates, and joint ventures.

EUR

666.9million

of total net operating income.

Result reflects great performance

and importantmilestonesachieved

The Group generated EUR 236.4 million of profit after tax, EUR

33.3 million or 12% less YoY, and was based on the following

key drivers and YoY evolution:

•Net interest income increased EUR 109.8 million, backed

by the Komercijalna Banka group contribution (EUR98.5

million). Increasing net interest income without the

Komercijalna Banka group contribution was impacted by

excess liquidity which determined a consequently higher

volume of cash and balances with CBs, with low or negative

interest rates. Interest income without the Komercijalna

Banka group contribution was higher YoY, based on higher

volumes and increased market shares in the loan book,

compensating for the reduction in interest rates;

•Net fee and commission income increased in all banks, in

the Bank mostly due to repricing of packages, fees for high

balances, higher net fees from asset management and

bancassurance, and arrangement fees for the organisation

of syndicated loans;

•Non-recurring valuation income in the amount of EUR 14.8

million from repayment of exposure, classified as non-

performing, EUR 9.0 million of other operation income from

the settlement of a legal dispute, and EUR 8.1 million loss

from the sale of Komercijalna Banka, Banja Luka; YoY lower,

with the sale of NLB Vita and debt securities impacting the

2020 result in the total amount of EUR 28.1 million;

•Continuous cost discipline; costs higher due to integration

and employee costs;

•Net impairments and provisions for credit risk were released

in the amount of EUR 35.8 million, mostly due to successful

repayment of on-and off-balance exposures and changed

parameters related to more favourable macroeconomic

forecasts;

•Other impairments and provisions were established in

the amount of EUR 27.1 million, mostly due to restructuring

provisions and provisions for legal risk, mostly related to

Komercijalna Banka, Beograd.

![]()

44

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

20202021

+83%

+103%

+80%

+70%

+83%

+625%

+65%

NLB,

Ljubljana

NLB Banka,

Skopje

NLB Banka,

Banja Luka

NLB Banka,

Sarajevo

NLB Banka,

Prishtina

NLB Banka,

Podgorica

NLB Banka,

Beograd

KB,

Beograd

KB,

Banja

Luka

KB,

Podgorica

114.0

208.4

19.2

39.0

10.1

18.2

5.9

10.0

13.3

24.4

1.4

10.1

2.6

4.3

34.8

0.5

-5.8

Figure 7:

Profit after tax of NLB Group banks

(i)

(on a stand-alone basis, in EUR million)

(i)

NLB Banka, Podgorica and Komercijalna Banka, Podgorica merged in November 2021; Komercijalna Banka, Banja Luka was sold on 9 December 2021.

Despite the unstable environment due to COVID-19 pandemic,

all banks (active at the end of the year) reported a profit.

Higher profit YoY was recorded in all the banks, mainly due

to the establishment of credit impairments and provisions

related to COVID-19 outbreak in 2020 and successful

operations in the reporting year.

The result of the Bank increased by 83% YoY to EUR 208.4

million from EUR 114.0 million achieved in 2020, mostly due

to higher dividend pay-out, since banking subsidiaries

were refrained from paying out dividends due to COVID-19

restrictions in 2020, and the net release of impairments

and provisions for credit risk (establishment in 2020 due to

COVID-19 outbreak which materially lowered the final result).

Non-recurring valuation income from repayment of exposure,

classified as non-performing in the amount of EUR 12.9 million

and from the settlement of legal dispute in the amount of EUR

8.6 million influenced 2021 result, while the sale of NLB Vita in

the amount of EUR 35.5 million and the sale of debt securities

in the amount of EUR 17.1 million had a positive impact on the

2020 result.

Recurring profit before impairments and provisions of the

Group totalled EUR 225.5 million, EUR 48.7 million or 28%

higher YoY. In Q2 2021, the result before impairments and

provisions was higher due to non-recurring net non-interest

income (EUR 14.8 million valuation income from the repayment

of exposure classified as non-performing, and EUR 9.0 million

of other operation income from the settlement of a legal

dispute), but partially offset by regulatory costs in the Bank

(EUR 2.0 million for SRF and EUR 7.5 million for DGS).

Figure 8:

Result before impairments and provisions of NLB Group (in EUR million)

Q42020

Q12021

Q22021Q32021

Q4 2021

47.1

61.1

-5.8

70.9

67.2

61.4

-6.5

-6.3

-15.9

-6.4

43.5

-1.1

-2.4

57.5

2.4

79.1

27.8

66.1

1.6

48.8

Result before impairments and provisions w/o non-

recurring income and regulatory costs

Non-recurring net non-interest income

Regulatory costs

![]()

45

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Q42020

Q12021

Q22021

Q32021

Q4 2021

Net interest margin - quarterly

Operational business margin - quarterly

3.25%

2.03%

3.25%

2.09%

3.32%

2.08%

3.18%

2.02%

3.35%

2.07%

Figure 10:

Net interest margin and Operational business margin of NLB

Group

(i)

(quarterly data, in %)

(i)

Calculated on the basis of average interest-bearing assets. Komercijalna Banka

group included from 2021 on.

The quarterly net interest margin of 2.07%, as well as the

operational business margin (OBM) of 3.35% in Q4 for the

Group was 0.1 p.p. and 0.04 p.p. higher YoY. Despite the

declining trend of interest rates on loans, the interest rate

on corporate and state loans in the Bank slightly increased,

due to the syndicated loan with an attractive interest rate,

repayment of some exposures with low interest rates, and

the higher volume of Cross-border corporate loans bearing

higher interest rates. Interest rate on loans to individuals is

in the declining trend mainly due to changed portfolio mix in

favour of housing loans bearing lower interest rate. On the

QoQ basis, the margins were higher due to TLTRO repricing.

KB interest incomeInterest income

Interest expensesKB interest expenses

Figure 9:

Net interest income of NLB Group (in EUR million)

20202021Q4 2020Q3 2021Q4 2021

299.6

409.4

75.1

-14.2

103.7

107.0

355.2

-55.6

89.3

366.7

111.1

-55.8

92.5

28.6

97.0

26.7

-14.3

-3.1

-12.6

-2.6

-14.1

Net interest income of the Group accounted for 61% of the

Group’s total net revenues (2020: 59%), and totalled to EUR

409.4 million. Out of the EUR 109.8 million increase, EUR 98.5

million was contributed by Komercijalna Banka group.

Without Komercijalna Banka group contribution, higher level

of net interest income was achieved YoY, due to higher volume

of securities and loans, despite lower yields, but partially offset

by higher cash volumes and balances with the CB (bearing

negative interest in line with the expansionary monetary policy).

The net interest income was also affected by higher liquidity

position streaming from TLTRO-III secured borrowing and

additional interest income, based on lower interest rates, was

recognised at the end of the year in the Bank.

Interest expenses in most member banks were decreasing

due to lower interest rates for customer deposits. The pressure

on the net interest margins in the Bank and member banks in

SEE continues.

Netinterest income

Net non-interest income

Net non-interest income reached EUR 257.6 million of which

EUR 32.8 million were contributed by Komercijalna Banka

group. A major part of the net non-interest income has been

derived from the net fee and commission income, which grew

YoY, mostly in the Bank due to the repricing of the packages,

fee for high balances in the amount of EUR 8.1 million (from

April on also for individuals

8

), higher net fees from asset

management (79.8% YoY growth of gross inflows in mutual

funds, total of EUR 252.4 million in 2021) and bancassurance

(higher YoY inflows with new distribution terms), and

arrangement fees for organisation of syndicated loans.

The net non-interest income was strongly affected by non-

recurring valuation income in the amount of EUR 14.8 million

from the repayment of exposure classified as non-performing,

EUR 9.0 million of other operation income from the settlement

of a legal dispute, and EUR 8.1 million loss from the sale of

Komercijalna Banka, Banja Luka. The non-recurring items

were higher in 2020 with the sale of NLB Vita and debt

securities in total amount of EUR 28.1 million.

8Further information is available under the chapter

Key Events

.

Figure 11:

Net non-interest income of NLB Group (in EUR million)

Net fee and commission income

Recurring other net non-interest income

KB net fee and commission income

Non-recurring other net non-interest income

Dividend income

20202021Q4 2020Q3 2021Q4 2021

204.9

257.6

46.1

62.3

60.0

-5.8

-1.1

-5.9

12.9

1.2

2.0

2.1

1.6

0.1

0.1

0.8

0.2

0.0

8.8

45.1

170.3

33.7

194.7

42.5

26.0

49.8

51.7

0.0

One-off positive effects in

thetotal amount of

EUR 23.8million

due to positive valuation effect from the

repayment of exposure, classified as

non-performing and other operation

income from the settlement of a

legal dispute.

![]()

46

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Total costs

Figure 12:

Total costs of NLB Group (in EUR million)

165.0

97.3

31.7

42.0

27.6

47.1

16.0

30.8

44.1

12.5

22.7

176.4

54.9

99.3

38.3

33.2

13.4

Employee costs

KB employee costs

Other general and administrative expenses

KB other general and administrative expenses

Depreciation and amortisation

KB depreciation and amortisation

20202021Q4 2020Q3 2021Q4 2021

293.9

415.4

77.7

99.9

118.2

3.3

3.3

9.0

8.0

12.6

8.4

8.3

Total costs amounted to EUR 415.4 million of which EUR 106.6

million fromKomercijalna Bankagroup. Without Komercijalna

Banka group contribution the costs increased YoY for EUR 14.9

million due to integration costs and employee costs.

CIR stood at 62.3%, a 4.0 p.p. increase YoY.

Impairments and provisions

The Group released net impairments and provisions for

credit risk (EUR 35.8 million in 2021) mostly due to successful

repayment of on-and off-balance exposures and changed

parameters related to more favourable macroeconomic

forecasts.

Other impairments and provisions were established in the

amount of EUR 27.1 million, of which there were provisions for

legal risk (EUR 16.6 million, to a large extent attributable to

processing fees in Serbia) and restructuring provisions (EUR

14.8 million).

9

The Group’s cost of risk was negative (-41 bps), as it was in

most Group bank members.

9More details are available in

Note 5.16.

of the Financial part of the report.

EUR

35.8million

released impairments and provisions

for credit risk.

KB other impairments and provisions

Other impairments and provisions

Impairments and provisions for credit risk

KB impairments and provisions for credit risk & expected credit losses

2020

2021

Q42020

Q32021

Q4 2021

Figure 13:

NLB Group impairments and provisions (in EUR million)

-71.4

8.8

-21.1

6.3

-16.5

-13.4

-48.9

-9.1

-13.4

-7.9

3.4

3.6

2.8

-4.2

-14.1

32.4

3.4

-3.1

-24.0

Establishment Release

62 -41

CoR

(bps)

0.2

-1.0

-0.3

-0.4

![]()

47

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Statement of financial position

Table 11:

Statement of financial position of NLB Group and NLB

NLB Group

in EUR million

31 Dec 202131 Dec 2020

Change YoY

31 Dec 202130 Sep 2021

30 Jun 2021

31 Mar 202131 Dec 2020Change QoQ

ASSETS

Cash, cash balances at central banks, and

other demand deposits at banks

5,005.13,961.81,043.226%5,005.14,947.04,739.43,918.23,961.858.11%

Loans to banks140.7197.0-56.3-29%140.7211.7243.4205.0197.0-71.0-34%

Net loans to customers10,587.19,644.9942.210%10,587.110,267.010,071.49,824.59,644.9320.23%

Gross loans to customers10,903.510,033.3870.19%10,903.510,593.710,421.810,208.210,033.3309.83%

- Corporate4,996.04,631.7364.38%4,996.04,783.94,772.74,720.84,631.7212.14%

- Individuals5,621.15,027.6593.512%5,621.15,487.45,304.85,126.65,027.6133.72%

- State286.3374.0-87.7-23%286.3322.3344.4360.8374.0-36.0-11%

Impairments and valuation of loans to customers-316.3-388.472.119%-316.3-326.7-350.4-383.7-388.410.43%

Financial assets5,208.35,119.588.82%5,208.35,264.75,490.95,376.45,119.5-56.4-1%

- Trading book7.784.9-77.2-91%7.710.513.575.184.9-2.8-27%

- Non-trading book5,200.65,034.7166.03%5,200.65,254.25,477.45,301.35,034.7-53.6-1%

Investments in subsidiaries, associates, and joint ventures11.58.03.544%11.58.58.48.18.03.036%

Property and equipment247.0249.1-2.1-1%247.0242.1243.8247.3249.14.92%

Investment property47.654.8-7.2-13%47.654.153.354.454.8-6.5-12%

Intangible assets59.161.7-2.6-4%59.153.055.758.261.76.112%

Other assets271.1268.92.11%271.1249.0281.1266.9268.922.19%

TOTAL ASSETS21,577.519,565.92,011.610%21,577.521,296.921,187.319,959.019,565.9280.61%

LIABILITIES

Deposits from customers17,640.816,397.21,243.68%17,640.817,248.617,143.016,732.116,397.2392.22%

- Corporate4,463.73,949.1514.513%4,463.74,276.64,130.24,011.03,949.1187.14%

- Individuals12,680.812,023.5657.25%12,680.812,495.212,477.812,254.412,023.5185.51%

- State496.4424.571.817%496.4476.8535.0466.7424.519.64%

Deposits form banks and central banks71.872.6-0.8-1%71.882.078.071.972.6-10.1-12%

Borrowings932.6249.8682.8-932.6975.6976.6251.1249.8-43.0-4%

Other liabilities427.6434.9-7.3-2%427.6412.5466.8428.5434.915.14%

Subordinated liabilities288.5288.30.20%288.5290.2287.6286.8288.3-1.7-1%

Equity2,078.71,952.8125.96%2,078.72,140.52,091.42,014.11,952.8-61.8-3%

Non-controlling interests137.4170.3-32.9-19%137.4147.6143.8174.5170.3-10.2-7%

TOTAL LIABILITIES AND EQUITY21,577.519,565.92,011.610%21,577.521,296.921,187.319,959.019,565.9280.61%

![]()

48

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

NLB

in EUR million

31 Dec 202131 Dec 2020

Change YoY

31 Dec 202130 Sep 2021

30 Jun 2021

31 Mar 202131 Dec 2020Change QoQ

ASSETS

Cash, cash balances at central banks, and

other demand deposits at banks

3,250.42,261.5988.944%3,250.43,049.82,961.42,127.32,261.5200.67%

Loans to banks199.3158.341.026%199.3176.5162.8164.3158.322.713%

Net loans to customers5,153.04,595.1557.912%5,153.04,903.54,787.84,677.54,595.1249.55%

Gross loans to customers5,250.44,753.1497.310%5,250.45,001.04,916.34,828.44,753.1249.35%

- Corporate2,411.12,168.5242.611%2,411.12,244.92,245.42,213.42,168.5166.27%

- Individuals2,694.42,411.9282.412%2,694.42,609.82,514.42,452.32,411.984.63%

- State144.9172.6-27.7-16%144.9146.3156.5162.7172.6-1.4-1%

Impairments and valuation of loans to customers-97.4-158.060.638%-97.4-97.5-128.5-150.9-158.00.20%

Financial assets3,034.33,017.217.11%3,034.33,160.23,398.63,365.23,017.2-125.9-4%

- Trading book7.718.8-11.1-59%7.710.413.623.818.8-2.8-26%

- Non-trading book3,026.62,998.428.21%3,026.63,149.83,385.03,341.42,998.4-123.2-4%

Investments in subsidiaries, associates, and joint ventures786.0750.735.35%786.0775.5775.5750.7750.710.61%

Property and equipment86.191.7-5.6-6%86.188.189.389.791.7-2.0-2%

Investment property9.28.30.911%9.29.18.38.38.30.11%

Intangible assets29.528.11.35%29.525.326.126.828.14.116%

Other assets151.7115.636.131%151.7125.4121.2128.6115.626.221%

TOTAL ASSETS12,699.511,026.61,672.915%12,699.512,313.512,330.911,338.411,026.6386.03%

LIABILITIES

Deposits from customers9,659.68,850.8808.99%9,659.69,243.39,272.29,056.68,850.8416.35%

- Corporate2,436.71,916.6520.127%2,436.72,158.42,070.01,996.81,916.6278.313%

- Individuals7,078.96,812.4266.54%7,078.96,994.27,060.36,924.96,812.484.61%

- State144.0121.822.218%144.090.7142.0134.9121.853.459%

Deposits form banks and central banks109.341.667.7163%109.3158.3142.0124.041.6-49.0-31%

Borrowings873.9143.5730.4-873.9863.6866.3143.4143.510.31%

Other liabilities216.3251.4-35.2-14%216.3233.5252.5242.0251.4-17.2-7%

Subordinated liabilities288.5288.30.20%288.5290.2287.6286.8288.3-1.7-1%

Equity1,551.91,451.0100.97%1,551.91,524.61,510.31,485.51,451.027.42%

TOTAL LIABILITIES AND EQUITY12,699.511,026.61,672.915%12,699.512,313.512,330.911,338.411,026.6386.03%

![]()

49

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Balance sheet volume of the Group increased by EUR 2,011.6

million YoY totalling to EUR 21,577.5 million, mainly due to

the continued inflow of deposits from individuals (EUR

657.2 million YoY), corporate (EUR 514.5 million YoY), and

participation in a liquidity-providing operation by the ECB

in the amount of EUR 750 million (TLTRO-III). Excess liquidity

was in large extent placed on the account at the CB (EUR

1,043.2 million YoY increase) and in gross loans to customers

(EUR 364.3 million to corporate and EUR 593.5 million to

individual clients). However, despite the deposit growth, the

trend of redistribution of deposits to alternative investments

(e.g., mutual funds and bancassurance) is visible. The share of

customers’ deposits accounted for 82% of the total funding,

2.0 p.p. less as at the end of 2020.

Assets

54.3% of the total assets were related to Group members

located in Slovenia (2020: 51.8%) and 22.2% in Serbia

(2020:23.4%).

Figure 14:

Total assets of NLB Group (in EUR million) – structure

Figure 15:

NLB Group total assets by location of NLB Group entities (in %)

(i)

Slovenia

Serbia

North Macedonia

BiH

Kosovo

Montenegro

Other

51.8%

54.3%

23.4%

22.2%

8.1%

8.1%

8.5%

7.4%

4.5%

4.3%

3.6%

3.6%

0.1%

0.1%

31 Dec 202031 Dec 2021

31 Dec 201931 Dec 202031 Dec 2021

Cash equivalents, placements with banks and loans to banks

Net loans to customers

Financial Assets

Other Assets

+10%

YoY

5,145.7

4,158.8

2,194.7

10,587.1

9,644.9

7,604.7

5,208.3

5,119.5

3,829.7

14,174.1

544.9

642.6

636.3

19,565.9

21,577.5

(i)

The geographical analysis includes a breakdown of items with respect to the

country in which individual NLB Group members are located. Komercijalna Banka

group is divided between the countries based on each entity location from 30

September 2021 on, with YE data adjusted to the new methodology.

![]()

50

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

The lending activity spiked and recorded a significant growth

in all the banks in 2021. Gross loans to individuals recorded the

highest, 17% YoY increase in Strategic foreign markets (without

Komercijalna Banka group banks, but included Komercijalna

Banka, Podgorica on 31 December 2021 due to the merger

with NLB Banka, Podgorica), while the highest increase

of gross loans to the corporate and state was recorded in

Komercijalna Banka, Beograd, i.e., 16% YoY.

Gross loans to individuals in the Bank grew by EUR 282.4

million YoY, mostly due to an increasing volume of housing

loans (EUR 280.9 million YoY, with enviable high new

production of EUR 557.6 million in 2021, compared to EUR

303.1 million in the previous year) related to more attractive

offers for clients and intensive marketing campaigns. The

volume of consumer loans was slightly lower YoY (EUR 16.1

million); however, the new production in 2021 amounted to

EUR 229.1 million and was higher compared to 2020 (EUR

196.7 million). Gross loans to corporate and state recorded a

EUR 214.9 million growth YoY, where growth derived from the

corporate segment (EUR 242.6 million), while the state segment

exposures shrank by EUR 27.7 million. Corporate loan growth

was distributed across all sub-segments.

The volume of gross loans to customers in Strategic foreign

markets increased, with a remarkable new production in lending

to individuals, with all the Group member banks recording a

double-digit YoY growth in outstanding loan balances.

(i)

On stand alone basis;

(ii)

NLB Banka, Podgorica and Komercijalna Banka, Podgorica merged in November 2021; Komercijalna Banka, Banja Luka sold on 9 December 2021; the growth in Strategic foreign market is impacted by the

merger of NLB Banka, Podgorica and Komercijalna Banka, Podgorica (the latter was not included in this segment as at 31 December 2020).

1,726.1

Despite the declining trend of interest rates on loans,

the average interest rate on corporate and state

loan book portfolio in the Bank slightly increased

due to changed portfolio structure (conclusion of

new syndicated loan with an attractive interest rate,

repayment of some exposures with low interest rates

and higher volume of Cross-border corporate loans),

bearing higher interest rates. The interest rate on

loans to individuals is in a declining trend mainly due

to the changed portfolio mix in favour of housing loans

bearing lower interest rates.

Figure 16:

NLB Group gross loans to customers dynamics (in EUR million)

NLB GroupNLB

(i)

Strategic foreign markets

w/o KB

(i)(ii)

KB Beograd

(i)(ii)

+12%

YoY

+13% w/o

KB BL

+6%

YoY

+8% w/o

KB BL

+12% YoY

+9% YoY

+16% YoY

+9% YoY

+17%

YoY

+14% w/o

KB PG

+10%

YoY

+7% w/o

KB PG

5,027.6

34.6

120.8

50.4

31Dec2020

31Dec2020

31Dec2021

31Dec2021

31Dec2020

31Dec2020

31Dec2021

31Dec2021

31Dec2020

31Dec2020

31Dec2021

31Dec2021

31Dec2020

31Dec2020

31 Dec 2021

31 Dec 2021

4.92%

2.72%

2.98%

1.85%

1.91%

4,884.9

4,993.0

1,992.5

4.90%

5,005.7

5,621.1

5,282.3

2,411.9

4.05%

6.28%

5.83%

2,341.1

2,694.4

3.84%

2,556.0

1,743.5

1,613.9

4.11%

4.01%

2,036.9

44.3

1,776.5

770.2

846.1

840.4

978.4

5.87%

3.52%

Gross loans to individuals

Gross loans to corporate & state

Interest ratesGross loansKB Banja LukaKB Podgorica

![]()

51

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Figure 17:

Loan portfolio

(i)

by segment, geography, currency, and rate type (in EUR million)

Despite significant portfolio growth in all NLB Group banks in

2021, there were no major changes in the corporate and retail

credit portfolio structure. The credit portfolio remains well-

diversified, and there is no large concentration in any specific

industry or client segment. The share of retail portfolio in the

whole credit portfolio is quite substantial, with the segment

of mortgage loans still prevailing. The majority of the loan

portfolio refers to euro currency, while the rest originates

from local currencies of the Group banking members. From

interest rate type, more than 63% of the loan portfolio is

linked to a fixed interest rate, and the rest to a floating rate

(mostly to the Euribor reference rate). Lending growth in

the corporate segment remained relatively moderate, while

the retail segment, namely mortgage lending, experienced

considerable growth in 2021.

Institutions

539

3%

Other

(iii)

730

5%

Slovenia

7,871

51%

BiH

1,262

8%

N. Macedonia

1,309

8%

Montenegro

618

4%

Kosovo

796

5%

Serbia

2,956

19%

SME

2,881

19%

Corporates

2,298

15%

Retail

consumer

2,427

16%

State

(ii)

4,202

27%

Retail mortgages

3,195

21%

EUR

81%

Other

2%

BAM

5%

MKD

5%

RSD

7%

EUR 15.5 billion

EUR 15.5 billion

EUR 15.5 billion

EUR 15.5 billion

(i)

Loan portfolio also includes reserves at CBs and demand deposits at banks.

(ii)

State includes exposures to CBs.

(iii)

The largest part represents EU members.

(iv)

Segmentation in accordance with the company size defined in the Companies

Act of an individual country in the region.

by segment

(iv)

Currency

by geography

Interest rate

Fixed

63%

Floating

37%

![]()

52

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Liabilities

Figure 18:

Total liabilities of NLBGroup – structure (in EUR million)

31 Dec 201931 Dec 202031 Dec 2021

Deposits from individuals

Corporate deposits

State deposits

Borrowings and Deposits from banks and central banks

Subordinated liabilities

Other liabilities

Total equity

+10%

YoY

14,174.1

342.6

434.9

427.6

257.4

322.4

1,004.4

210.6

288.3

288.5

277.7

424.5

496.4

19,565.9

21,577.5

8,582.9

12,023.5

12,680.8

4,463.7

3,949.1

2,772.0

1,730.9

2,123.1

2,216.1

Total liabilities of the Group increased and amounted to EUR

19,361.4 million. The Group’s funding base is dominated by

customer deposits accounting for 82% in which sight deposits

prevail (87%, compared to 85% as at 2020 YE and 81% as at

2019 YE). The majority of customer deposits (72%) were from

individuals. 55% of deposits were collected in Slovenia (54% at

2020 YE), 22% in Serbia (24% at 2020 YE), and the rest in other

Group banking members in SEE.

![]()

53

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Figure 19:

NLB Group deposits from customers dynamics (in EUR million)

(i)

On stand alone basis;

(ii)

NLB Banka, Podgorica and Komercijalna Banka, Podgorica merged in November 2021; Komercijalna Banka, Banja Luka sold on 9 December 2021; the growth in Strategic foreign market is impacted by the merger of NLB Banka,

Podgorica and Komercijalna Banka, Podgorica (the latter was not included in this segment as at 31 December 2020).

NLB GroupNLB

(i)

Strategic foreign markets

w/o KB

(i)(ii)

KB Beograd

(i)(ii)

+5%

YoY

+6% w/o

KB BL

+13%

YoY

+16% w/o

KB BL

+4% YoY

+10% YoY

+2% YoY

+27% YoY

+11%

YoY

+8% w/o

KB PG

+15%

YoY

+11% w/o

KB PG

12,023.5

59.7

78.5

31Dec2020

31Dec2020

31Dec2021

31Dec2021

31Dec2020

31Dec2020

31Dec2021

31Dec2021

31Dec2020

31Dec2020

31Dec2021

31Dec2021

31Dec2020

31Dec2020

31 Dec 2021

31 Dec 2021

4.90%

4,373.7

95.0

12,680.8

4,960.1

2,411.9

6,812.4

2,764.9

3,058.1

2,038.4

2,694.4

7,078.9

2,580.7

1,355.4

1,552.4

44.0

2,307.7

860.8

2,543.7

880.9

Deposits from individuals

Deposits from corporate & state

Interest ratesDepositsKB Banja LukaKB Podgorica

0.31%

0.18%

11,963.8

0.17%

0.17%

0.16%

0.13%

0.05%

0.03%

0.35%

1,508.4

0.22%

0.05%

0.04%

0.47%

0.31%

2,979.6

4,278.7

Deposits from customers increased by 8% YoY. The largest

increase of EUR 542.3 million was recorded in the corporate

and state deposits in the Bank, due to various reasons, i.e., the

increase of balances in investment and pension funds, inflows

from takeovers on the market, and incentives due to COVID-19

pandemic. Deposits from individuals increased the most in the

Komercijalna Banka, Beograd, EUR 236.0 million.

The interest rate for deposits has been decreasing due to

repricing at lower interest rate and shorter maturity (due

term deposits are mostly placed on the accounts). Growth of

deposit base was reflected in higher costs of liquidity surplus,

which was successfully mitigated with a high balance deposit

fee, charged by the Bank to corporate and from April on also

to individualclients. Consequently, thetrend ofredistribution

of deposits to alternative investments (e.g., mutual funds and

bancassurance) was visible.

![]()

54

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Figure 20:

Deposits from customers by type as at 31 December 2021

93.0%

79.4%

7.0%

20.6%

Term depositsSight deposits

InternationalSlovenia

Figure 22:

NLB Group off-balance sheet items (in EUR million)

31 Dec 201931 Dec 202031 Dec 2021

Guarantees

Letters of credit - risk bearing

Commitments to extend credit and other risky commitments

Derivatives

0%

YoY

4,221.7

22.9

21.8

35.6

4,672.7

4,655.3

1,490.8

1,697.7

1,927.5

1,892.2

1,826.7

1,354.8

916.5

1,236.7

1,126.4

Off-balance sheet items of the Group amounted to EUR

4,655.3 million and were comprised of guarantees (27%),

letters of credit (1%), commitments to extend credit and other

risky commitments (41%), and derivatives (32%).

Commitments to extend credit and other risky commitments

were divided between loans (99% corporate), overdrafts (59%

retail and 41% corporate), and cards (89% retail). A majority of

the Group's derivatives were concluded by the Bank either for

the hedging of the banking book or trading with customers.

Figure 21:

LTDratio movement

7,604.7

31 Dec 201931 Dec 202031 Dec 2021

65.5%

11,612.3

58.8%

9,644.9

60.0%

16,397.2

10,587.1

17,640.8

LTDNet loans (in EUR million)Deposits (in EUR million)

The LTD ratio (net) was 60.0% at the Group level; a 1.2 p.p. YoY

increase, due to favourable higher growth of loans compared

to deposits.

![]()

55

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Capital and capital adequacy

Capital

31 Dec 201931 Dec 202031 Dec 2021

Tier 1

Tier2

Figure 23:

NLB Group capital (inEUR million)

1,966

1,768

1,451

287

297

1,496

45

2,065

2,252

In 2021, NLB was required to maintain the OCR at the level of

14.25% on a consolidated basis, consisting of

10

:

•10.75% TSCR (8% P1R and 2.75% P2R); and

•3.5% CBR (2.5% Capital Conservation Buffer, 1% O-SII buffer

11

and 0% Countercyclical buffer).

P2G amounts to 1.0% of CET1.

The Bank and Group’s capital covers all the current and

announced regulatory capital requirements, including capital

buffers and other currently known requirements, as well as

the P2G.

10 Further information on developments in 2022 are available in chapter

Events after the end of the 2021

financial year

.

11The O-SII Buffer will as of 1 January 2023 amount to 1.25%.

16.28%

15.75%

15.25%

15.25%

14.75%

14.25%

14.25%

15.80%

16.63%

14.12%

17.78%

15.47%

31 Dec 201931 Dec 202031 Dec 2021

Total capital ratioCET1 ratioOCR = MDA threshold (Total capital)OCR+P2G (Total capital)

Figure 24:

NLB Group capital ratios and regulatory thresholds (in %)

2.00%

2.69%2.69%

1.50%

0.69%

2.02%

3.50%

1.00%

2.02%

4.50%

0.52%

6.05%

10.55%

1.55%

8.00%

Pillar 1Pillar 2TSCRP2GOCR+P2G (Total capital)Combined Buffer

CET1

AT1

T2

2.75%

10.75%

15.25%

Figure 25:

NLB Group capital requirements as at 31 December 2021

![]()

56

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Table 12:

NLB Group Capital Requirements and buffers

(i)

2021

from 12 March 2020

onwards

as at 1 January till

11 March 2020

2019

Pillar 1 (P1R)

CET14.5%4.5%4.5%4.5%

AT1

1.5%1.5%1.5%1.5%

T22.0%2.0%2.0%2.0%

Pillar 2 (SREP req. - P2R)

CET11.55%1.55%

2.75%

3.25%

Tier 12.06%2.06%2.75%3.25%

Total Capital2.75%2.75%2.75%3.25%

Total SREP Capital Requirement (TSCR)

CET16.05%6.05%7.25%7.75%

Tier 18.06%8.06%8.75%9.25%

Total Capital10.75%10.75%10.75%11.25%

Combined Buffer requirement (CBR)

Conservation bufferCET12.5%2.5%2.5%2.5%

O-SII bufferCET11.0%1.0%1.0%1.0%

Countercyclical bufferCET10.0%0.0%0.0%0.0%

Overall capital requirement (OCR) = MDA threshold

CET19.55%9.55%10.75%11.25%

Tier 111.56%11.56%12.25%12.75%

Total Capital14.25%14.25%14.25%14.75%

Pillar 2 Guidance (P2G)CET11.0%1.0%1.0%1.0%

OCR + P2GCET110.55%10.55%11.75%12.25%

(i)

Further information on developments in 2022 are available in the chapter

Events After the End of the 2021 Financial Year

.

![]()

57

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

As at 31 December 2021 the TCR for the Group stood at 17.8%

(or 1.2 p.p. higher than as at 31 December 2020), and for NLB

at 24.6% (or 2.5 p.p. lower than as at 31 December 2020). As at

31 December 2021, the CET1 ratio stood at 15.5% (1.4 p.p. YoY

increase). The higher Group total capital adequacy compared

to the end of 2020 derives from higher capital (increase of EUR

187.0 million YoY) which compensated RWA increase of EUR

246.4 million YoY for the Group. Higher RWA derives from the

increase of RWA for operational risk. Total capital increased

mainly due to inclusion of negative goodwill in retained

earnings in the amount of EUR 137.9 million and partial

inclusion of 2021 profit (EUR 136.0 million).

Figure 26:

Capital of NLB Group (in EUR million) – evolution YoY

16.6%

17.8%

2,06513813613-63-37n.a.2,252

31 Dec 2020NGWProfit inclusionKB BG buyoutNCIOCI and otherRWA impact31 Dec 2021

1.1%

1.1%

0.1%

-0.5%

-0.3%

-0.3%

![]()

58

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Dividend pay-out

Pursuant to the ECB regulation/BoS decision valid till 30

September 2021, the dividend payout in 2021 was split into two

tranches. The first instalment in the amount of EUR 12.0 million

was paid on 22 June 2021, while the second in the amount of

EUR 12.8 million after expiry of the BoS decision on 18 October

2021. Besides that, the Bank paid on 24 December 2021

additional incremental dividend in the amount of EUR 67.4

million, contributing to the 2021 cumulative pay-out of EUR 92.2

million.

Total risk exposure dynamic

Table 13:

Total risk exposure for NLB Group

in EUR million

31 Dec 202130 Sep 202131 Dec 2020

Change

YoY

Change

QoQ

Total risk exposure amount (RWA)12,667.412,824.412,421.0246.4-157.0

RWA for credit risk10,205.210,648.010,222.9-17.8-442.8

Central governments or central banks1,158.51,842.81,892.2-733.7-684.3

Regional governments or local authorities99.8126.0135.5-35.6-26.2

Public sector entities47.0212.7248.8-201.8-165.8

Institutions310.2355.1311.7-1.4-44.8

Corporates2,748.72,312.42,224.2524.5436.3

Retail4,171.04,190.73,891.8279.2-19.7

Secured by mortages on

immovable property

453.0397.1355.797.456.0

Exposures in default179.4191.8231.5-52.0-12.4

Items associated with particulary high risk442.5444.1344.298.3-1.5

Covered bonds41.140.340.90.20.8

Claims in the form of CU19.417.618.70.81.8

Equity exposures88.579.747.141.48.8

Other items446.0437.7480.9-34.98.2

RWA for market risk + CVA1,218.21,229.01,250.8-32.6-10.8

RWA for operational risk1,244.0947.3947.3296.7296.7

![]()

59

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

The RWA for credit risk decreased by EUR 17.8 million. On

one hand, the factors to increase were loan growth to the

corporates and retail, new investments in subordinated, state

and EU institutions bonds. On the other hand, the increase

was compensated by regulatory changes namely inclusion

of BiH and Macedonia on EBA's third party equivalent list,

legislation criteria changes for the CRR collateral adequacy,

signing of guarantee agreements with MIGA as well as

changed investment policy such as shift of some liquid

assets from the central governments to lower risk-weighted

counterparties (NLB Banka, Prishtina, NLB Banka, Podgorica)

or optimization of deposits with banks (Komercijalna Banka,

Beograd). Furthermore, successful recovery of NPL clients,

where the biggest part represented repayments by a large

client, contributed to the RWA decrease, while on the other

hand RWA for high-risk exposures is higher mainly due to new

project finance loans.

The RWA for market risk decreased by EUR 32.6 million YoY

due to a lower fixed income position in the trading book. In

contrast, RWA for FX risk increased by EUR 35.3 million YoY

and RWA for CVA increased by EUR 10.7 million, of which

EUR 10.6 million as a result of new regulatory requirements

which became effective from June 2021 onward (calculation of

original exposure method (OEM) with residual maturity).

The increase in the RWA for operational risks (EUR 296.7 million

YoY) derives from the higher three-year average of relevant

income, as defined in Article 316 of CRR, which represents the

basis for the calculation.The main effect for increased relevant

income was acquisition of Komercijalna Banka, Beograd in 2020.

Further information on capital and capital adequacy is

available in the

Note

5.22

to the Audited Annual Financial

Statements and in

Pillar 3

Disclosures

.

MREL

The MREL requirement for the Group is based on the Multiple

Point of Entry (MPE) approach. As of 1 January 2024, NLB must

comply with MREL requirement on a consolidated basis at

resolution grouplevel (i.e., NLBResolution Group, consisting

of NLB and other members of the Group excluding banks)

which amounts to 31.38% of Total Risk Exposure Amount

(TREA) (excluding CBR) and 9.97% of the Leverage Ratio

Exposure (LRE). NLB has to ensure a linear build-up of own

funds and eligible liabilities towards MREL requirement and

its compliance with 25.19% of the TREA (excluding CBR) and

8.03% of the LRE on 1 January 2022.

MREL requirement forms part of Group’s risk appetite and

MREL requirement is regularly analysed and monitored by the

Group.

![]()

60

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

As at 31 December 2021 the Group’s unencumbered liquidity

reserves corresponded to EUR 8,280.6 million (2020: EUR

8,327.0million) comprised of cash, balances with CB without

minimum reserve requirement, debt securities portfolio, and

credit claims eligible for CB-secured funding operations.

Among other these liquidity reserves provide the basis for

future strategic growth. Encumbered liquidity reserves

(EUR 877.6 million; excluding obligatory reserves), used for

operational and regulatory purposes, are excluded from the

liquidity reserves portfolio.

10,000

9,000

8,000

7,000

6,000

5,000

4,000

3,000

2,000

1,000

0

EUR million

31 Dec 202031 Mar 2021

30 Jun2021

30 Sep 202131 Dec 2021

ECB eligible credit claimsCash & CB reserves

Trading book debt securitiesBanking book debt securities

8,327.0

8,203.1

8,366.1

8,191.1

8,280.6

43.1%

42.0%

39.1%

29.6%

32.2%

55.9%

57.7%

59.7%

63.4%

59.9%

7.0%

0.8%

6.3%

0.7%

1.2%

0.0%

0.4%

0.0%

1.0%

0.0%

Figure 28:

Evolution of NLB Group unencumbered liquidity reserves (in EUR million)

Liquidityposition

The Group’s liquidity remains strong, with a high level of

unencumbered liquidity reserves in total assets (38.3%) that

is reflected in the LCR ratio standing at 252.6% (31 December

2020: 257.5%). The Group holds a comfortable liquidity position,

with liquidity ratios standing well above the risk appetite limit at

the Group and individual banking member level.

Figure 27:

LCR quarterly dynamic of NLB Group

5,367

5,286

5,453

4,915

5,003

2,125

1,941

2,000

1,876

1,943

7,000

6,000

5,000

4,000

3,000

2,000

1,000

-

EUR million

300.0%

250.0%

200.0%

150.0%

100.0%

50.0%

0.0%

31 Dec 202031 Mar 2021

30 Jun2021

30 Sep 202131 Dec 2021

Stock of HQLANet liquidity outflowLCR

257.5%

262.0%

272.6%

272.4%

252.6%

![]()

61

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Segment Analysis

Table 14:

Core and Non-Core Segments of NLB Group

Core SegmentsNon-Core Segment

Retail Banking in Slovenia

Corporate and Investment

Banking in Slovenia

Strategic Foreign Markets

Financial Markets

in Slovenia

OtherNon-Core Members

includes banking with

individuals and micro

companies, asset

management (NLB

Skladi), and one part

of the subsidiary NLB

Lease&Go that deals with

retail clients, as well as

the contribution to the

result from the associated

company Bankart.

includes banking with Key

corporate clients and SMEs,

Cross-border corporate

financing, Investment

Banking and Custody,

Restructuring and Workout,

and one part of the

subsidiary NLB Lease&Go

that renders services

to corporate clients.

includes the operations

of strategic Group

banks in the strategic

markets (Serbia, North

Macedonia, BiH, Kosovo

and Montenegro).

covers treasury activities

and trading in financial

instruments, while it

also presents the results

of asset and liabilities

management (ALM).

accounts for the Bank’s

categories of which

the operating results

cannot be allocated to

specific segments as

well as the subsidiary

NLB Cultural Heritage

Management Institute.

includes the operations of

non-core Group members,

namely REAM and leasing

entities (except NLB

Lease&Go), NLB Srbija,

and NLB Crna Gora.

(in EUR million)

NLB Group

Profit b.t.

261.449.086.8113.215.8-4.71.3

Contribution to Group’s

profit b.t.

100%19%33%43%6%-2%0%

Total assets

21,5772,8232,3349,7986,190337

96

% of total assets

100%13%11%45%29%2%0%

CIR

62.3%68.1%44.4%63.0%35.8%177.5%157.4%

Cost of risk (bps)

-4126-141-11///

NLB Group’s main indicator of a segment’s efficiency is net profit before tax. No revenues were generated from transactions with a single external customer that would amount to 10% or more of Group's

revenues.

![]()

62

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Financial performance

Table 15:

Performance of the Retail Banking in Slovenia segment

in EUR million consolidated

20212020

Change YoY

Net interest income79.581.4-1.9-2%

Net interest income from Assets

(i)

82.778.44.35%

Net interest income from Liabilities

(i)

-3.13.0-6.1-

Net non-interest income91.589.02.53%

o/w Net fee and commmission income96.682.713.817%

Total net operating income171.0170.40.70%

Total costs-116.5-114.1-2.4-2%

Result before impairments and provisions54.556.2-1.7-3%

Impairments and provisions-6.7-15.18.456%

Net gains from investments in subsidiaries, associates, and JVs'1.10.90.227%

Result before tax49.042.06.917%

31 Dec 202131 Dec 2020

Change YoY

Net loans to customers2,731.62,415.4316.213%

Gross loans to customers2,769.72,450.7319.013%

Housing loans1,815.51,534.7280.918%

Interest rate on housing Loans2.34%2.51%-0.17 p.p.

Consumer loans635.6651.7-16.1-2%

Interest rate on consumer Loans6.70%6.43%0.27 p.p.

Other318.6264.354.321%

Deposits from customers7,703.67,356.8346.85%

Interest rate on deposits0.03%0.04%-0.01 p.p.

Non-performing loans (gross)58.152.45.711%

20212020

Change YoY

Cost of risk (in bps)2663-38

CIR68.1%67.0%1.1 p.p.

Interest margin1.55%1.75%-0.20 p.p.

(i)

Net interest income from assets and liabilities with the use of FTP.

The Bank continues to be the market leader in

retail banking by knowing customers’ needs.

Through anchor loan products and best-suited

offers to different segments, the Bank again

proved its efficiency and gained new clients. The

banking environment is changing considerably

and new approaches and sales channels are

emerging. The Bank continues to be available

through its traditional branch offices, but also

through its mobile branch. Technology enables

the availability of the Bank’s services to clients

24/7 via the Contact Centre and digital banking.

Retail Banking in Slovenia

Contribution to NLB Group

Figure 29:

Contributionto NLB Group

Result b.t.

19%

Net interest income

19%

36%

Net non-interest

income

![]()

63

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Net interest income

The net interest income from loans to individuals was EUR 4.3

million higher YoY; the higher volume of housing loans and

higher interest margins on consumer loans was due to higher

volumes of new production and a higher share of loans with a

risk premium and quick loans in the portfolio; lower volumes

on overdrafts had a negative impact on the interest income.

There was also a reduction of the retail deposits margin after

transfer price (FTP) in the amount of EUR 6.1 million YoY.

Net non-interest income

Higher net non-interest income in the amount of

EUR2.5million YoY was due to EUR 13.8 million or 17% higher

net fee and commission income related mostly to package

repricing and higher net fees from asset management (high

net inflows in mutual funds of NLB Skladi, EUR 192.8 million)

and bancassurance. In April, the Bank started charging a fee

for high balances for individuals to restrain the deposit inflow

which diverted extra liquidity to other financial products

(mutual funds, investments) and compensated for the negative

interest rates charged for the balances at the CB.

Net impairments and provisions

Net impairments and provisions were established in the

amount of EUR 6.7 million, due to changes in risk parameters.

Loans to customers

The production of new housing loans was record high, EUR

557.6 million in 2021 (2020: EUR 303.1 million).

Deposits from customers

The deposits base increased by EUR 346.8 million (5%) YoY,

with sight deposits prevailing (95% in 2021, compared to 93%

in 2020).

Business performance

The market leader in retail banking

inSlovenia

Leader in Slovenia

Bank remains the leader in the Slovenian market in retail

lending and deposit-taking. An encouraging increase of the

market share is noticed in the category of housing loans,

namely to 24.4% (31 December 2020: 22.5%), which is the result

of a very impressive production of new housing loans in 2021

(market share of 32.2%; 2020: 28.3%).

The Bank remains the leader because of their very well-

established branch and ATM network, the 24/7 Contact centre,

and continuous digitalization improvements.

The Bank retains its role as a market leader in payments

by being a reliable and trustworthy provider of payments

services with a focus on providing a positive user experience.

The private banking arm of the Bank has been positioned as a

leader in this segment in Slovenia for over 20 years.

NLB Skladi is a market-leading asset management company,

whose market share and annual net inflows are increasing

everyyear.

Market share in loans to customers

Market share in deposits from customers

Market share in housing loans

Market share in consumer loans

33.0%

31.0%

29.0%

27.0%

25.0%

23.0%

21.0%

19.0%

17.0%

15.0%

31 Dec 201931 Dec 202031 Dec 2021

Distribution channels

Branch office and ATMs network

The Bank’s main sales channel remains its branch network

in Slovenia with 75 branches, and is supported with the ATM

network (538 or a 37.6% market share in Slovenia) of which

89% are contactless.

A higher daily limit of cash withdrawals on ATMs was

enabled to encourage clients to increase use of ATMs, and

consequently to strengthen the advisory role of branch

offices.

Mobile bank: NLB Bank&Go

The mobile branch NLB Bank&Go, engaged in promoting

the Bank in various cities in Slovenia, is being increasingly

recognised.

Unique 24/7 banking service in Slovenia

Extending the use of video calling for sales and contract

conclusions for almost all of the Bank’s products (consumer

and housing loans with straightforward collateral, Vita and

Generali insurance products, deposits, savings and cards,

onboarding of e- and m-bank) was an important step towards

strengthening the role of the Contact Centre as a 24/7 sales

channel.

The Contact Centre experienced a YoY increases of 11% in total

contacts, mainly due to the 57% increase in video calls.

Despite the broader scope of work, the client experience

remained at a very high level, with an average 2021 NPS for

video call and chat of 71.

Figure 30:

NLB’s market share in Retail Banking in Slovenia

The Bank strengthened

its position in

Lending

and Asset

Management.

30.5%

26.2%

23.1%

21.8%

31.3%

26.4%

23.4%

22.5%

30.7%

26.9%

24.7%

24.4%

![]()

64

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Sustainability

Following the ESG orientation of the Group, special financing

for the purchase of solar panels, power storage and heat

pumps was agreed to be offered to clients by one of the

Slovenian retailers, selling technical products.

Digital banking

The number of digital users continued to increase (13%

YoY), with the number of active users surpassing 300,000.

The number of m-bank Klikin and e-bank NLB Klik users

increased by 23% (72,076 new users) and 6% (22,771 new users)

YoY respectively, which is well demonstrated by the digital

penetration (see the figure below).

The total volume and number of payments processed in

the e-bank and m-bank increased by 32% and 14% YoY,

respectively.

Figure 33:

Online and mobile banking penetration

31 Dec 201831 Dec 201931 Dec 202031 Dec 2021

E-bankM-bank

35%

35%

27%

38%

40%

36%

42%

52%

Digitalisation and improved client

experience

High level of client satisfaction

The Bank maintained a high level of client satisfaction, as

measured through the Customer Satisfaction Index (CSI). The

CSI remains stable and well above competition. Furthermore,

clients also express a high level of trust and loyalty.

The Bank also managed to change price perception in

segment of young people, where satisfaction improved (from

74 to 77; 2021 Valicon Client Satisfaction Survey).

Figure 31:

NLB Contact Centre no. of contacts

43,289

100,397

158,099

863,717

999,460

1,112,933

201920202021201920202021

Video call

Totalcontacts

Competitor banks' average 2021

NLB 2021

NLB 2020

NLB 2019

NLB 2018

75

81

83

77

77

Figure 32:

Satisfaction withthe attitude towardscustomers

Source: 2021 Valicon Client Satisfaction Survey.

Mobile wallet - NLB Pay

M-wallet NLB Pay usage is increasing at a significant pace

and the application is constantly being upgraded. The most

recent updates have been made in line with regulatory

requirements forStrong Customer Authenticationand include

Flik Instant Payments for person to person (P2P), person to

merchant (P2M), and person to e-merchant (P2eM) payments.

The application has become a must-have, especially as it is an

easy way to confirm e-commerce purchases.

24.4%

market share in housing loans.

Digital banks

NLB Klik’s and Klikin’s penetration and

share of active users substantially

increased.

+57%

+11%

Figure 34:

NLB Pay in numbers

12,827

18,402

44,097

7,722

12,577

36,218

201920202021201920202021

# of usersVolume of transactions (in EUR thousand)

+140%

+188%

![]()

65

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Ancillary businesses complementing

bankingproducts

NLB Skladi – Slovenia’s largest

asset management company

The market share of NLB Skladi increased to 37.3% (31

December 2020: 34.9%). With EUR232.8 million of net inflows in

2021, which is the company’s highest annual amount of inflows

ever recorded, the company ranked first among its peers in

Slovenia, accounting for 50.4% of all net inflows in the market.

Fees for high balances of clients’ assets introduced in April

2021 also triggered a partial reallocation of client assets from

deposits and contributed to an additional increase of interest

occurred on asset management products.

The total assets under management amounted to EUR 2,128.0

million (31December2020: EUR 1,625.6 million) of which

EUR1,610.4 million consisted of mutual funds (31December

2020: EUR 1,125.5 million) and EUR 517.6 million of the

discretionary portfolio (31 December 2020: EUR 500.1 million).

Vita - insurance company

The insurance company Vita remains the Bank’s strategic

partner. Its products aresold through the Bank’s distribution

network, such as savings and investment insurance products,

risk, and health insurance products.

Vita introduced a new health insurances product – NLB Vita

Specialist, which among others covers the costs of medical

specialists and more complex diagnostic examinations.

Stable card market share

The Bank’s card market share remained stable with 26.1%

(2020: 26.5%) in the Slovenian market.

New debit Mastercards (NLB Debit Mastercard, NLB Debit

Mastercard World, and NLB Mastercard World Elite) were

introduced to replace the Maestro card, and are part of

the client’s wallet and mobile wallet NLB Pay. The debit

Mastercard offers added value to clients at a time when most

purchases are made online.

SMS Instalments for personal pay-later payment cards

were introduced. The only condition to activate this option

is the activation of SMS Alarm service. This new service

complements instalment purchases for all possible card

transactions (POS and e-commerce purchases, ATM

withdrawals).

Flik Instant payments

The introduction of a new payment method within the local

Slovenian instant payment scheme Flik P2M promotes further

migration from cash to digital payments. Flik P2M is integrated

in the m-wallet NLB Pay and also provides support for iOS

users.

Private banking

Leading private banking provider in Slovenia

Private banking has positioned itself among the leading

private banking providers in Slovenia for over 20 years. In

2021, its leading position was further strengthened with assets

under management reaching EUR 1.2 billion (16% YoY), and the

number of clients increased by 14% YoY.

Throughout the year, private bankers managed to maintain

sales activities on a high level. Results were solid in all areas,

but the best were in mutual fund sales. This can be attributed

to our dedicated team, the positive economic and capital

market environment, and introduction of the fee for high

balances for individual clients.

By offering carefully selected and tailored products and

services, the Bank demonstrates that it is able to take good

care of their clients’ wealth.

GENERALI Zavarovalnica -

Non-life insurance products

Non-life insurance products, including car and home

insurance, are provided to clients in cooperation with the

GENERALI Zavarovalnica.

Despite challenging circumstances, excellent results were

achieved, namely gross written premiums increased YoY by

19%, and the number of car insurance and home insurance

policies by 19% and 23%.

Figure 35:

Assets under management and the number of private banking clients

A new Debit

Mastercard

was introduced to replace

the Maestro card.

Figure 36:

Customers’ penetration of ancillary business

31 Dec 201631 Dec 201731 Dec 201831 Dec 2019 31 Dec 202031 Dec 2021

NLB SkladiVitaGenerali

1.2%

3.7%

12.9%

13.4%

14.0%

14.9%

15.2%

15.6%

4.9%

6.5%

7.5%

8.3%

9.1%

1.5%1.5%

1.7%

1.9%

2.2%

31 Dec 201631 Dec 201731 Dec 201831 Dec 201931 Dec 2020 31 Dec 2021

AuM (million EUR)# of Clients

554.0

746.9

752.5

911.1

1,075.1

1,242.9

1,077

1,168

1,231

1,309

1,580

1,800

![]()

We are your right hand.

The great-grandfather had the first store on the street.

The grandfather expanded his business onto the entire town.

The father built a national store chain.

For them, there are no limits.

Even small companies have big plans. Yet, business growth demands creativity, passion and hard work.We want to cooperate

with companies that boast such qualities and support them on their path. That is why we offer much more than just banking

services – we share our knowledge with you to build a stronger, more profitable future in the region where determination and

entrepreneurial courage know no limits.

![]()

67

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

The Bank is strengthening its market position

as a systemic player in its home region,

and actively participates in the growth of

markets by supporting sustainable projects.

As a leading player, the Bank also supports

the more complex, cross-border needs of

its clients and diversifies services for them.

Clients’ trust and satisfaction are solid

foundations for future sustainable growth.

Corporate andInvestment Banking in Slovenia

31.5%

market share in guarantees and

letters of credit.

Contribution to NLB Group

Figure 37:

Contributionto NLB Group

Result b.t.

33%

Net interest income

9%

26%

Net non-interest

income

Financial performance

Table 16:

Performance of the Corporate and Investment Banking in Slovenia segment

in EUR million consolidated

20212020

ChangeYoY

Net interest income35.734.01.75%

Net interest income from Assets

(i)

41.136.84.312%

Net interest income from Liabilities

(i)

-5.4-2.8-2.6-93%

Net non-interest income65.841.224.660%

o/w Net fee and commmission income38.933.25.717%

Total net operating income101.575.226.335%

Total costs-45.1-41.8-3.3-8%

Result before impairments and provisions56.433.423.0

69%

lmpairments and provisions30.59.021.5-

Result before tax86.842.444.5105%

31 Dec 202131 Dec 2020

Change YoY

Net loans to customers2,332.42,047.1285.214%

Gross loans to customers2,390.72,167.5223.110%

Corporate2,258.52,006.4252.113%

Key/SME/Cross Border Corporates2,110.61,827.6283.115%

Interest rate on Key/SME/Cross

Border Corporates loans

1.79%1.79%0.00 p.p.

Investment banking0.10.2-0.1-38%

Restructuring and Workout

88.2160.8-72.6-45%

NLB Lease&Go59.617.841.7-

State

131.9160.7-28.8-18%

Interest rate on State loans2.07%2.20%-0.13 p.p.

Deposits from customers1,938.21,487.4450.730%

Interest rate on deposits0.03%0.06%-0.03 p.p.

Non-performing loans (gross)72.5156.0-83.5-53%

20212020

Change YoY

Cost of risk (in bps)-141-44-97

CIR44.4%55.6%-11.1 p.p.

Interest margin1.76%1.90%-0.15 p.p.

(i)

Net interest income from assets and liabilities with the use of FTP,

![]()

68

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Net interest income

The interest income from loans to corporate and state was

EUR 4.3 million higher YoY, due to higher volumes, mostly in

Key and Cross-Border Corporates. There was also a reduction

of the deposits margin after transfer price (FTP) in the amount

of EUR 2.6 million YoY.

Non-recurring net non-interest income

Non-recurring net non-interest valuation income in the

amount of EUR 13.0 million from repayment of exposure,

classified as non-performing, and EUR 8.6 million other

operation income from the settlement of a legal dispute.

Net fee and commission income

Higher net fee and commission income YoY, mostly due to a

higher fee for high balances on customers assets (EUR 6.6

million in 2021, EUR 3.3 million higher YoY) and arrangement

fees for organisation of syndicated loans.

Net impairments and provisions

Net impairments and provisions were released in the amount

of EUR 30.5 million due to the repayment of several exposures,

changes in credit ratings, and changed parameters for

collective impairments and provisions related to more

favourable macroeconomic forecasts.

Loans to customers

The volume of loans to corporate increased by EUR 252.1

million YoY, mostly due to newly approved syndicated loans

and increased volumes in the Cross-border Corporates and

NLB Lease&Go.

The Investment Banking and Custody

The Investment Banking and Custody recorded non-interest

income in the amount of EUR 10.8 million and increased

by EUR 1.4million YoY, mostly due to arrangement fees for

organisation of syndicated loans. The total value of assets

under custody decreased YoY and amounted to EUR 15.9

billion (31December 2020: EUR 16.2 billion).

Business performance

Market leader focusingon

customers’ needs

Leading bank servicing corporate

clients in Slovenia

NLB is the leading bank in servicing corporate clients in

Slovenia with a growing client base, and it has an 18.3%

market share in corporate loans (31 December 2020: 17.3%).

The Bank also remains a reliable partner to Slovenian

companies when they want to expand their activities abroad.

Despite substantial loan repayments, the entire portfolio grew

as several new high-quality transactions were concluded

in financing exports and manufacturing, the state, project

finance, acquisitions, factoring, and international finance. In

2021, EUR 1,281.5 million of loans were approved to corporate

and state clients presenting a 23% YoY increase. Market

presence and a proactive approach are also reflected in the

YoY growth of the loan portfolio in all corporate segments,

namely in Key by 7%, SME by 9%, and Cross-border even by

79%. Growth is recorded across all products and services.

As the leading bank in the Slovenian market for the

organisation of syndicated loans, the Bank continues to

successfully support and finance the expansion of Slovenian

companies in the region.

The Bank is also a leading Slovenian bank in the field of trade

finance with products that support the export economy.

Group clients are supported with letters of guarantees,

letters of credit, and purchases of receivables through digital

channels in a safe and fast way, with a market share of 31.5%

(31 December 2020: 31.4%) in guarantees and letters of credit

(including guarantee lines).

Diversified product mix

Bank’s offer

The Bank’s offer of financial services, including lending, cash

management, payment services, as well as capital markets’

advisory services supports various clients’ needs.

Clients can get short-term or long-term financing facilities and

advisory services to find a best-suited financing structure. In this

way, the Bank supports key projects that are important for the

development of the country, as well as the Group’s home region.

Market share in loans to customers

Market share in deposits from customers

Market share in guarantees and letters of credit

35.0%

30.0%

25.0%

20.0%

15.0%

10.0%

31 Dec 201931 Dec 202031 Dec 2021

Figure 38:

NLB’s market share in Corporate Banking in Slovenia

30.0%

17.5%

16.5%

31.4%

17.3%

17.0%

31.5%

18.9%

18.3%

Client base

expanded

with additional stable and well

performing groups of companies.

![]()

69

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Basic products & Cards business

New debit Mastercard products (NLB Debit Mastercard

Business and NLB Debit Mastercard World Business) are now

also available to business account holders, replacing the

Maestro business card.

New debit cards are included in the renewed package offer

for legal entities, namely NLB Business Package Basic,

Advanced, and Comprehensive, with a special offer for the

target group of newly established and non-profit clients.

SMS Instalments for business pay-later payment cards were

introduced, the only condition being the activation of an SMS

Alarm service. This new service complements the instalment

purchase for all possible card transactions (POS and

e-commerce purchases, ATM withdrawals).

Trade finance solutions

The Bank is a leading Slovenian bank in the field of trade

finance with products that also support the export economy,

and represent an important part of the Slovenian economy.

The trade finance product range and tailor-made solutions

are comprehensive and range from traditional trade finance

products, to other modern structures which provide safe

financingthroughout thesupply chains.

As a member of the Factor Chain International, the Bank aims

to offer exporters and importers international purchase of

receivables, thus providing them with a modern, fast, and

easy way of financing, which is an additional incentive for

international business. Special attention is given to letter of

guarantees by which the Bank supports major infrastructure

projects in Slovenia and the wider home region. The stronger

market position reflects the Group’s active advisory approach

towards its customers.

Sustainability

In the process of actively integrating the ESG factors, the Bank

is devoting increasing efforts to identifying new business

opportunities arising from its transition to support circular and

carbon neutral economy.

#HelpFrame, a social environment project with a clearly

defined sustainability component, continued in 2021. In

addition to know-how, advice, and services, advertising

space was also made available to the selected entrepreneurs,

farmers and small and micro companies, thus helping them

present their products and services to potential buyers and

customers.

Project financing

Recent developments in the real estate market have

opened up new opportunities for project financing. With

comprehensive financial solutions, supported by a strong

team of experts, the Bank is able to meet even the most

demanding challenges in this area.

Each project is reviewed from different perspectives –

feasibility, costs, and sale, thus trying to minimise risk for both,

the Bank and the client. Clients are also supported in the trade

finance area, as successful completion of the transaction also

requires guarantees to eliminate hidden defects to end users.

Favourable financing conditions are offered to the buyer of

the property, and a team of mobile bankers is involved to

ensure a successful implementation.

The platform provides security and simplicity, a competitive

edge to providers, and good user experience.

Instant payments

Since 2020, the Bank gradually introduced instant payments,

including instant internal transfers and Flik payments in the

NLB Pay. Instant outgoing payments are now also available to

clients (free of charge) in the m-banking solutions Klikin and

Klikpro.

Flik payments

With the main goal of decreasing the use of cash, the Flik P2M

payment method is being gradually implemented in all shops

with NLB POS terminals. NLB was the first bank in Slovenia to

enable clients such a service.

Global Payments Innovation (GPI) full on-boarding

The Group, as a first banking group in the region, fully

onboarded the GPI (Global Payment Initiative), i.e., service

from SWIFT, which enables more efficient processing and

easier tracking of international payment orders, thus enabling

considerable improvement and smoother international

payments experience for customers involved in international

business.

Figure 39:

Transaction volume in acquiring (in EUR million)

14

47

55

2,247

2,348

2,535

201920202021201920202021

e-commerce (in EUR million)POS (in EUR million)

+17%

+8%

A leader in merchant-acquiring

The Bank is a leader in merchant-acquiring by accepting all

major payment cards, the local Flik instant payment scheme

and a modern contactless POS network, with a 36.7% market

share in merchant acquiring.

Users of e-commerce expect secure and simple online

purchases, which is why the Bank offers NLB E-commerce, a

modern payment platform, to its providers and their clients.

Cross border

financing

is becoming increasingly important.

![]()

70

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

loans, which includes also some of world-renowned brands

and leaders in their industries. The EEA lending portfolio

exceeds EUR 150 million at YE, and is also expected to grow

further due to very well-established relationships with some of

the European partnership banks.

Digitalisation ofproduct offering

M-bank Klikpro

The number of m-bank Klikpro users is constantly increasing

(YoY by 17%), which proves that clients are adopting the

process of digital banking.

The latest upgrade also included digital signing of documents

for a defined list of products, which will be further extended in

the following periods.

Mobile wallet NLB Pay

The Bank’s mobile wallet NLB Pay application enables clients

to make contactless, simple, fast, and secure payments on

the contactless POS (in Slovenia and abroad) with the NLB

Business Mastercard and NLB Business Maestro cards, and

also enables instalment payments.

Investment banking and

securitiesservices

Arranger of several transactions

In 2021, the Bank organised six syndicated facilities in the

total amount of EUR 652.1 million, where it also acted as the

mandated lead arranger, as an agent, and also as the leading

bank with EUR 275.7 million participation.

International corporate business

Collaboration within the Group

Excess liquidity, a rather limited Slovenian market, and the

wish to expand operations with existing and new clients are

the main reasons why cross-border financing is becoming

increasingly important. In the Western Balkans, the Bank is

among others currently supporting selected projects mainly

in the telecommunications and food industry, as well as

renewable energy sources.

At YE, the portfolio, including participating shares of Group

subsidiaries lending in such a transaction, already well

exceeds EUR 150 million. The notable potential in the region

can be observed especially in corporate financing focusing

on renewable energy, infrastructure, and residential project

finance.

Corporate lending in EEA

The Bank also entered into different EU markets and

diversified its cross-border portfolio across the EEA. Most

notable transactions were concluded in Germany, France,

Austria, and the Netherlands.

Deals are primary made through participation in syndicated

international facilities orthrough participation inSchuldschein

The Bank helped many companies broaden funding base

and arranged the issuance of both long-term and short-term

instruments in the total of EUR 44.3 million on debt capital

markets.

The Bank was active in M&A and other financial advisory

engagements. As the sole financial advisor, it successfully

organised the sales process of a leading Slovenian company

in the production of paints. The Bank successfully organised

two takeover bids as well.

Brokerage services and Financial Instruments

In the brokerage services in 2021, the Bank executed clients’

buy and sell orders in the total amount of EUR 902.9 million

(2020: EUR 941.3 million), while in the area of dealing in

financial instruments, the Bank executed foreign exchange

spot deals in the total of EUR 946.6 million (2020: EUR 724.0

million) and for EUR 382.5 million (2020: EUR 242.6 million)

worth of transactions involving derivatives.

Good economic conditions in 2021 resulted in more activities

in foreign, non-Euro markets, by the clients. At the same time,

due to higher inflation expectations, more demand for interest

rate hedging was noticed.

Custodian services

The Bank remains one of the top Slovenian players in

custodian services for Slovenian and international customers.

The total value of assets under custody on 31 December 2021

was, together with the fund administration services, EUR 15.9

billion (31 December 2020: EUR 16.2 billion).

Arranging

EUR

652.1 million

of syndicated loans.

![]()

71

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Financial performance

Table 17:

Results of the Strategic Foreign Markets segment

in EUR million consolidated

20212020

Change YoY

o/w KB

contribution

Net interest income266.8159.3107.598.868%

Interest income299.6182.6117.0111.564%

Interest expense-32.8-23.3-9.5-12.8-41%

Net non-interest income95.149.845.333.291%

o/w Net fee and commmission income101.654.147.542.388%

Total net operating income361.9209.1152.9132.073%

Total costs-227.9-109.0-118.9-107.3-109%

Result before impairments and provisions134.0100.134.024.734%

Impairments and provisions-20.8-59.138.3-20.665%

Negative goodwill (KB)137.9-137.9-

Result before tax113.2178.8-65.64.2-37%

o/w Result of minority shareholders11.53.08.41.5-

31 Dec 202131 Dec 2020

(i)

Change YoY

Net loans to customers5,441.95,052.4389.58%

Gross loans to customers5,632.25,234.8397.48%

Individuals2,877.32,592.9284.411%

Interest rate on retail loans5.83%--0.45 p.p.

Corporate2,613.52,443.7169.87%

Interest rate on corporate loans3.96%--0.20 p.p.

State

141.4198.1-56.7-29%

Interest rate on state loans3.35%--0.18 p.p.

Deposits from customers7,998.87,552.2446.66%

Interest rate on deposits0.29%--0.14 p.p.

Non-performing loans (gross)191.7195.0-3.3-2%

20212020

Change YoY

Cost of risk (in bps)

(ii)

-11140-151

CIR63.0%52.1%10.8 p.p.

Interest margin

(ii)

2.86%3.33%-0.47 p.p.

(i)

Interest rates for 2020 are calculated without Komercijalna Banka group.

(ii)

Komercijalna Banka, Beograd is excluded from the calculation.

With the merger of two banks in Montenegro

and the finalised sale of one bank in the

Republic of Srpska in 2021, the core part of the

Group in foreign markets now consists of seven

banks and one investment fund company.

They are locally even stronger embedded as

important financial institutions and market

leaders in various business segments. All

Group subsidiary banks have a stable market

position and strong reputation. The market

shares by total assets of subsidiary banks

exceed 10% in five out of six markets.

The banks in the Group strategic foreign markets

offer a full range of financial services to retail

and corporate clients. In 2021, the Group banks

marked remarkable double-digit growth of gross

loans to customers, especially in housing loans

segments with raised demand for housing loans,

reaching up to 41% YoY (NLB Banka, Sarajevo)

to 55% YoY growth rates (NLB Banka, Beograd).

In 2021 the Group banks accelerated their digital

transformation by offering e-identification

(NLB Banka, Skopje), pay mobile card solution,

end-to-end automated loan processing

(Komercijalna Banka, Beograd) to robotics

solutions in several internal processes (NLB

Banka, Sarajevo), and implemented SWIFT GPI

services to enable faster, more transparent, and

reliable international transactions to its clients.

Strategic Foreign Markets

Contribution to NLB Group

Figure 40:

Contributionto NLB Group

Result b.t.

43%

Net interest income

65%

37%

Net non-interest

income

![]()

72

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Net interest income

Net interest income increased by EUR 8.8 million (6%) YoY

without theKomercijalnaBanka group contribution, due to

higher volumes despite a lower interest margin.

Net non-interest income

Net non-interest income increased EUR 12.1 million YoY

without theKomercijalnaBanka group contribution, ofwhich

EUR 5.1 million in net fee and commission income due to

normalisation of business after COVID-19 outbreak in 2020.

Net non-interest income in 2021 was negatively affected with

the sale of Komercijalna Banka, Banja Luka (EUR 8.1 million),

while in 2020 with modification losses caused by changes

of contractual cash flows for loans subject to COVID-19

moratoria in 2020.

Totalcosts

Total costs increased YoY (EUR 11.6 million or 11%) due to a

higher volume of business in all banks and additionally due to

integration costs on the Serbian and Montenegrin markets.

Net impairments and provisions

Net impairments and provisions were established in the

amount of EUR 20.8 million, mostly related to legal and

restructuring provisions, while impairments and provisions for

credit risk of the segment were net released.

Figure 41:

Gross loans volume and interest rates in Strategic Foreign Markets

Seven

subsidiary banks and

one

investment fund

company.

Gross loans to customers

Gross loans to customers increased by EUR397.4 million (8%)

YoY, despite EUR 155.4 million decrease attributable to the

sale of Komercijalna Banka, Banja Luka. The most material

increase was in housing loans. The increase of the loan

portfolio was visible in all of the member banks; the largest

increases were recorded in Komercijalna Banka, Beograd

(EUR 202.5 million) and NLB Banka, Skopje (EUR 123.1 million).

1,604.0

3,162.0

6.71%

4.46%

1,558.0

31 Dec 201931 Dec 202031 Dec 202120192020

w/o KB

2021

IndividualsCorporate & state

+8% YoY

2,592.9

5,234.8

6.28%

4.11%

2,641.9

2,877.3

5,632.2

5.83%

3.92%

2,754.9

Profit before tax

EUR

113.2million

only 37% lower compared to last year,

when the result was higher due to

acquisition of Komercijalna Banka,

Beograd.

![]()

73

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Figure 42:

Deposit volume and interest rates in Strategic Foreign Markets

Deposits from customers

Deposits from customers increased by EUR 446.6 million

YoY, despite EUR 154.7 million decrease due to the sale of

Komercijalna Banka, Banja Luka. The growth was recorded in

all member banks, except NLB Banka, Beograd.

2,598.0

3,856.7

0.58%

0.41%

1,258.7

31 Dec 201931 Dec 202031 Dec 202120192020

w/o KB

2021

IndividualsCorporate & state

+6% YoY

5,211.1

7,552.2

0.47%

0.35%

2,341.1

5,601.9

7,998.8

0.32%

0.22%

2,397.0

The market shares

(by total assets) of subsidiary

banks exceed

10%

in five out of six markets.

![]()

74

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Komercijalna Banka,

Beograd

The acquisition of Komercijalna Banka, Beograd further

strengthened the Group’s strategic position in Serbia and

has placed NLB as one of the leading (and systemic) banks

on the market. The bank is strongly positioned as a leader

on retail market with more than 1.1 million clients, and a high

market share both in lending (consumer and housing) and

deposits. In corporate segment, the bank was mainly building

relationships with public and large domestic companies.

Nevertheless, the Group recognises that Komercijalna

Banka, Beograd has still important growth potential in all the

segments, which is expected to be realised in the following

period.

NLB finalised harmonisation of Komercijalna Banka, Beograd

with NLB Group standards within six months from acquisition,

while the merger of Komercijalna Banka, Beograd with

NLB Banka, Beograd is planned for the end of April 2022.

It is expected that the merger of the two banks could bring

important synergy effects on cost and on revenue side. After

finalisation of the merger, the Bank will focus on digitalization

and modernisation of services to establish the bank as one of

the leaders in service quality. Despite ongoing harmonisation

activities and merger process with the NLB Banka, Beograd,

the bank achieved in 2021 record sales growth in both retail

and corporate banking segment and already introduced

some modern digital solutions (Kombank pay mobile card

solution, end-to-end automated loan processing, etc.).

Macroeconomic Snapshot

In Serbia, the economy lost some steam in Q4 due to

rising price pressures while softer merchandise import

growth suggesting a slight cooldown in domestic demand.

Nevertheless, the economy rebounded from a mild

contraction in 2020 with investment and private consumption

propelling economic activity in 2021.

Figure 43:

GDP growth, Inflation, Unemployment

8.0

6.0

4.0

2.0

0.0

-2.0

8.0

6.0

4.0

2.0

0.0

12.0

10.0

8.0

6.0

202020212022202020212022202020212022

GDP (real growth in %)Average inflation (in %)Unemployment rate (in %)

Outlook

Economic growth is expected to return towards the pre-

pandemic path, and so, growth is expected at a slower pace

in 2022. The economy should grow on the back of private

consumption and investment,while governmentinvestment

and EU funds should further aid the growth. Downside risks

are in the form of pandemic-related uncertainty, sturdier and

prolonged elevated inflation, the long-term impact of supply-

side bottlenecks and economic implications of the war in

Ukraine.

Contribution to NLB Group

Figure 44:

Contributionto NLB Group

18%

Net non-interest

income

Result b.t.

10%

Net interest income

22%

Banking services provided through:

190 branches

281 ATMs

4

th

largest bank in the country.

![]()

75

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Business performance

Retail banking

The retail segment, with the largest client base on the local

market, represents the predominant strength of Komercijalna

Banka, Beograd. Since the acquisition, the bank focuses

strongly on boosting activity in retail area through series of

structural initiatives. These initiatives resulted in significant

growth in gross loans (9% YoY). The Bank recorded the

historically highest loan production growth (cash loans

62% YoY growth, retail housing loans 34% YoY growth) and

growth in total income (9% higher YoY) and growth in net

fees (18% higher YoY). The bank finally managed to defend

the retail loan market share despite the ongoing integration

process. Conversely, deposits growth was 10% YoY of which

foreign currency savings grew EUR 169 million. The bank also

developed ‘KomBank Pay,’ a mobile wallet for contactless

payments.

Corporatebanking

Corporate banking in the bank was historically concentrated

on servicing public and domestic companies and was holding

a less dominant market position compared to the retail

segment. In the corporate segment, the bank improved its

management structure and processes. This generated 18%

YoY growth in gross loans. In addition, 2021 was a record year

in the bank in terms of new loan production which amounted

to EUR 524.7 million, representing 39% growth YoY, and mainly

comingfrom large segment clients, noticeably outperforming

the market growth. Additionally, corporate deposits noted a

growth of 8%. The key drivers of income growth were large

corporate and SME loans. Net non-interest income increased

by 3% YoY and net fees recorded growth by 11% YoY.

Additionally, the bank redesigned offer of existing loans

for liquidity and working capital (18 and 36 months), and

introduced reverse factoring (production of EUR 7.4 million). 

Financial performance

Table 18:

Key performance indicators of Komercijalna Banka, Beograd

(i)

in EUR thousand

2021

Key performance indicators

Net interest income88,570

Net non-interest income40,110

Total costs-87,979

Impairments and provisions-7,637

Result before tax33,064

Result after tax34,818

Financial position statement indicators

Total assets4,165,249

Net loans to customers1,795,882

Gross loans to customers1,818,793

Deposits from customers3,424,633

Equity634,643

Key financial indicators

Total capital ratio28.6%

Net interest margin2.4%

ROE a.t.5.5%

ROA a.t.0.9%

CIR68.4%

NPL volume36,329

NPL ratio (internal def.: NPL/Total loans)1.4%

Market share by total assets9.7%

LTD

52.4%

(i)

Data on a stand-alone basis as included in the consolidated financial statements

of the Group. For year 2020, comparable data are not available.

The bank realised a profit after tax in the amount of

EUR 34.8million, ROE a.t. 5.5% and CIR 68.4%. TCR was

stable at 28.6%. The result was driven by the high loan

production growth in retail and corporate. Net interest

income reached EUR 88.6 million, while net non-interest

income was EUR40.1million. The total assets amounted to

EUR4,165.2million. The NPL ratio was 1.4%.

9.7%

market share in total assets.

EUR

33.1 million

result b.t.

Market share by total assets

Market share in loans to corporate

Market share in loans to individuals

Market share in deposits from customers

14.0%

12.0%

10.0%

8.0%

6.0%

4.0%

2.0%

0.0%

31 Dec 202031 Dec 2021

11.8%

10.0%

6.3%

8.5%

11.2%

9.7%

6.3%

8.4%

Figure 45:

2-year market share evolution

![]()

76

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

NLB Banka, Beograd

In 2021, one of the crucial activities for NLB Banka, Beograd

was participation and full support for the ongoing integration

project with Komercijalna Banka, Beograd where the

merger is planned in Q2 2022. After the merger, NLB Banka,

Beograd will cease to exist. The bank was fully engaged in all

initiatives of the integration process. In spite of demanding

integration process, the Bank managed to maintain dynamic

sales activity, where the retail and agro segments produced

outstanding results. The bank increased market shares in

housing and consumer loans, and in the agro segment the

bank managed to strengthen its market position to 14.1%

(2020: 13.6%).

Macroeconomic Snapshot and Outlook for Serbia see under

Komercijalna Banka, Beograd.

Financial performance

Table 19:

Key performance indicators of NLB Banka, Beograd

(i)

in EUR thousand

20212020

Change YoY

Key performance indicators

Net interest income23,35921,8227.0%

Net non-interest income6,9544,81244.5%

Total costs-22,170-20,351-8.9%

Impairments and provisions-3,202-3,59110.8%

Result before tax4,9412,69283.5%

Result after tax4,2932,59865.2%

Financial position statement indicators

Total assets715,375686,6934.2%

Net loans to customers511,693472,1708.4%

Gross loans to customers520,518482,5527.9%

Deposits from customers449,476496,288-9.4%

Equity77,91874,2055.0%

Key financial indicators

Total capital ratio19.2%19.1%0.2 p.p.

Net interest margin3.4%3.4%0.1 p.p.

ROE a.t.5.5%3.5%2.0 p.p.

ROA a.t.0.6%0.4%0.2 p.p.

CIR73.1%76.4%-3.3 p.p.

NPL volume9,4898,7188.8%

NPL ratio (internal def.:

NPL/Total loans)

1.5%1.4%0.1 p.p.

Market share by total assets

(ii)

1.6%1.9%-0.2 p.p.

LTD

113.8%95.1%18.7 p.p.

(i)

Data on a stand-alone basis as included in the consolidated financial statements

of the Group.

(ii)

Data for 2021 as at 30 September 2021.

The bank realised a profit after tax in the amount of

EUR 4.3million (2020: EUR 2.6 million) and profit before

impairments and provisions in the amount of EUR 8.1 million

(2020: EUR 6.3 million). ROE a.t. was 5.5% (2020: 3.5%), while

CIR decreased to 73.1% (2020: 76.4%). The result was mainly

driven by the increase in business volume. The total assets

of the bank rose by 4%, the main factor being new loan

production. NPL ratio increased to 1.5% (2020: 1.4%).

Contribution to NLB Group

Figure 46:

Contributionto NLB Group

Result b.t.

2%

Net interest income

6%

3%

Net non-interest

income

16

th

largest bank in the country.

Banking services provided through:

28 branches

63 ATMs

![]()

77

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Corporatebanking

As a part of the integration strategy for Serbia, large company

production has been moved from NLB Banka, Beograd to

Komercijalna Banka, Beograd, to benefit from the larger

capital base and lower cost of funding, which finally resulted

in the decline in overall gross loans (-1.4%) in NLB Banka,

Beograd. Thus, the corporate portfolio was driven mainly by

production in SME segment, which was on a satisfactory level.

In addition, in the integration process it has been decided

to move corporate sales force and production completely

to Komercijalna Banka, Beograd at the beginning of 2022

(including the micro and agro segments in retail), which was

one of the major organisational initiatives impacting the

corporate team at the end of 2021.

Deposit volumes also declined during the year (-3.1%),

driven on one side by the transfer of large corporates to

Komercijalna Banka, Beograd, while on the other side there

was one additional major impact coming from a synergy

initiative between both banks enabling NLB Banka, Beograd

to offer loans at higher pricing compared to the cost of

deposits NLB Banka, Beograd paid on the market. Due to this,

NLB Banka, Beograd was in the position to gradually release

expensive deposits, which resulted in a decline of deposit

volumes.

Business performance

Retail banking

Retail banking recorded double-digit growth in gross loans

(22.3%), while deposits declined by 13.8% compared to 2020.

Retail deposits were mainly in EUR.

In 2021, the retail loan portfolio was dominated by consumer

loans (62.4% of gross retail loans), while housing loans

occupied 36.1% of gross retail loans. The retail loan portfolio

is driven by cash loans (RSD) with still attractive interest rates

(below 7.6%). The interest margin on cash loans was high,

but under significant pressure coming from competition and

falling interest rates in RSD and increasing dinarisation

12

in

general. In 2021, the bank put more efforts on housing loans

and achieved a significant 55% YoY growth in this segment,

where the market is very active and competitive with banks

were offering interesting products at attractive prices.

Figure 47:

3-year market share evolution

(i)

Market share by total assets

Market share in loans to corporate

Market share in loans to individuals

Market share in deposits from customers

2.5%

2.0%

1.5%

1.0%

0.5%

0.0%

31 Dec 201931 Dec 202031 Dec 2021

2.0%

2.0%

2.0%

2.2%

1.9%

1.8%

1.8%

1.8%

1.6%

1.4%

1.9%

1.9%

(i)

Market share data for 2021 as at 30 September 2021.

12Dinarisation – Strategy of Dinarisation of the Serbian Financial System as

per Memorandum, signed between National Bank of Serbia (NBS) and the

Government of the Republic of Serbia, expected to be implemented in 2022.

1.6%

market share in total assets.

EUR

4.9 million

result b.t.

![]()

78

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Macroeconomic Snapshot

In North Macedonia, economic growth slowed considerably

in Q3 as the base effect faded. Growth in private consumption

and investment decelerated, while the external sector

supported economic activity. In Q4 2021, growth in retail

sales eased as inflation further increased, at the same time

as industrial production figures imply stronger private sector

dynamics.

Figure 48:

GDP growth, Inflation, Unemployment

7.0

3.5

0.0

-3.5

-7.0

8.0

6.0

4.0

2.0

0.0

17.0

15.0

13.0

11.0

202020212022202020212022202020212022

GDP (real growth in %)Average inflation (in %)Unemployment rate (in %)

Outlook

GDP should record a solid expansion in 2022 on the back of

private consumption. This should be the main growth driver

of the firming domestic demand, while foreign demand

should also be supportive of the activity. Pandemic-related

uncertainty, high energy prices, and prolonged disruption

of supply chains represent the main downside risks to

the outlook. Economic implications of the war in Ukraine

represent an additional downside risk to the outlook.

NLB Banka, Skopje

On its local market, the bank is in the group of systemically

important banks. The predominant strength of the bank is

the retail segment. However, the bank provides a full range

of financial services to retail and corporate clients. Having

a continuous progress in digitalization, the bank achieved

in 2021 great success in this field, being the first bank in

the country by introducing e-identification, upgrading,

and adjusting the mKlik application for visually impaired

clients and by opening a new, completely digital branch,

offering cashless services. The position of a market leader

in bancassurance was once again confirmed by expanding

the offer, introducing voluntary private healthinsurance

and a new unique life insurance product in cooperation with

partner insurance company. Besides this, the bank introduced

assets management products for clients, the sale and

trading of shares and funds for individuals and legal entities

in cooperation with an asset management and investment

services company.

Contribution to NLB Group

Figure 49:

Contributionto NLB Group

Result b.t.

17%

Net interest income

13%

7%

Net non-interest

income

3

rd

largest bank in the country.

Banking services provided through:

48 branches

170 ATMs

![]()

79

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

provisions and higher collected written-off receivables. The total

assets of the bank rose by 12%, with a 12% growth in gross loans

to customers, and a 9% growth in deposits from customers. The

NPL ratio amounted to 4.3% (2020: 5.1%).

Business performance

Retail banking

Retail banking recorded a significant growth in gross loans

(12%) substantially over the market average growth, driven by

the growth in housing loans (17.5%) and in the deposit base

(9%). The retail loan portfolio was dominated by consumer

loans (54.4% of gross retail loans), while housing loans

occupied 37.5% of gross retail loans. The interest margin

in the retail segment is still high, but under strong pressure

from competition and expansive monetary policy. The key

drivers of income growth were domestic and foreign payment

operations, account management, and card operations.

Figure 50:

3-year market share evolution

Market share by total assets

Market share in loans to corporate

Market share in loans to individuals

Market share in deposits from customers

25.0%

20.0%

15.0%

10.0%

5.0%

0.0%

31 Dec 201931 Dec 202031 Dec 2021

20.5%

20.8%

21.6%

17.3%

16.0%

18.1%

14.4%

16.9%

14.9%

18.0%

14.2%

16.5%

Corporatebanking

The upward trend in the corporate segment which started in

May, resulted in a 12% growth in gross loans at the 2021 YE.

Corporate deposits noted a growth of 8%. The key drivers

of income growth were long-term loans, investment, loans

for working capital and the liquidity needs of the companies,

as well as domestic and foreign payment operations and

account management.

As at 31 December 2021, the bank had a market share of 14.9%

in corporate gross loans. The bank increased the portfolio,

especially in the segment of long-term financing to high-

rated clients, who secured the long-term stability of the

portfolio and stable revenue generation. The bank approved

total of EUR 55 million in project financing, out of which

almost EUR 20 million was approved solely for green energy

investments, while also providing syndicated financing for

several large clients. The bank has successfully concluded the

internationally financed syndicated facility for the shopping

mall in Skopje, opened and operational since October 2021,

as one of the most important projects for the bank and the

Group. The project totalling EUR 72 million, was supported

with participation of five banks – three local banks and two

international banks.

Financial performance

Table 20:

Key performance indicators of NLB Banka. Skopje

(i)

in EUR thousand

20212020

Change YoY

Key performance indicators

Net interest income50,38648,1404.7%

Net non-interest income18,04314,51824.3%

Total costs-28,619-26,497-8.0%

Impairments and provisions3,244-15,373-

Result before tax43,05420,788107.1%

Result after tax39,00019,222102.9%

Financial position statement indicators

Total assets1,770,5871,585,65211.7%

Net loans to customers1,084,075956,93113.3%

Gross loans to customers1,144,4201,021,27612.1%

Deposits from customers1,399,5011,288,8248.6%

Equity243,267229,7775.9%

Key financial indicators

Total capital ratio18.0%15.7%2.3 p.p.

Net interest margin3.1%3.3%-0.2 p.p.

ROE a.t.15.9%8.8%7.1 p.p.

ROA a.t.2.4%1.3%1.1 p.p.

CIR41.8%42.3%-0.5 p.p.

NPL volume59,72863,177-5.5%

NPL ratio (internal def.:

NPL/Total loans)

4.3%5.1%-0.8 p.p.

Market share by total assets16.9%16.5%0.4 p.p.

LTD

77.5%74.2%3.2 p.p.

(i)

Data on a stand-alone basis as included in the consolidated financial statements

of the Group.

The bank realised a profit after tax in the amount of EUR 39.0

million (2020: EUR 19.2 million), and profit before impairments

and provisions in the amount of EUR 39.8 million (2020: EUR

36.2 million). This very good result in the first post COVID-19 year

reflected in ROE a.t., which increased to 15.9% (2020: 8.8%), and

CIR, which decreased to 41.8% (2020: 42.3%). TCR increased to

18.0% (2020: 15.7%). The result was driven mostly by retail lending,

payment services, and additionally by lower impairments and

16.9%

market share in total assets.

EUR

43.1 million

result b.t.

![]()

80

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Macroeconomic Snapshot

In BiH, the economy expanded at a softer pace in Q3, partly

due to a less favourable base effect. Private consumption

recorded the largest slowdown in growth rate amid rising

inflation. Higher growth in public and capital spending

propelled the domestic economy. In Q4, a further rise in

consumer prices and pandemic-related restrictions further

weighed on private consumption.

Figure 51:

GDP growth, Inflation, Unemployment

6.0

3.0

0.0

-3.0

-6.0

6.0

4.0

2.0

0.0

-2.0

16.0

14.0

12.0

10.0

202020212022202020212022202020212022

GDP (real growth in %)Average inflation (in %)Unemployment rate (in %)

Outlook

The economy is expected to record a solid growth in 2022,

supported by higher capital and public spending while the

relaxationof restrictive pandemic-related measures at

home and abroad should further bolster economic activity.

Pandemic-related uncertainty,slowerrecovery in export

markets, and political tensions represent the downside risks to

the outlook. Additional downside risk to the outlook has arisen

due to the war in Ukraine.

NLB Banka, Banja Luka

The bank in 2021 celebrated its 25

th

anniversary. The

predominant strength of the bank is its market position in

the corporate and retail segments, and a very strong deposit

base. The bank introduced new banking solutions and

products for clients largely contributing to a high share of net

non-interest income (37.7% of fee and commissions income in

net income).

Contribution to NLB Group

Figure 52:

Contributionto NLB Group

Result b.t.

7%

Net interest income

5%

5%

Net non-interest

income

2

nd

largest bank in the Republic of Srpska.

Banking services provided through:

47 branches

71 ATMs

![]()

81

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

released impairments and provisions as a result of successful

NPL management. Net non-interest income represents 39.5%

of total income, the highest among NLB Group banking

subsidiaries. The total assets of the bank rose by 16%, with

a 9% growth in net loans to customers, predominantly to

individuals, and a 20% growth in deposits from customers,

respectively. The NPL ratio decreased to 1.3% (2020: 2.3%).

Business performance

Retail banking

Retail banking recorded double digit growth in gross loans

(14%) and deposits (10%). The retail loan portfolio was

dominated by housing loans (51.9% of gross retail loans), while

consumer loans participated with 43.5% of gross retail loans.

Growth in gross retail loans was recorded, mainly due to

growth in consumer loans (8%) and housing loans (13%). The

key drivers of income growth were new loan production and

card operations.

The focus remains in further growth of retail portfolio, with

special emphasis on introducing additional services for

customers, especially in the field of digitalisation.

Figure 53:

3-year market share evolution

Market share by total assets

Market share in loans to corporate

Market share in loans to individuals

Market share in deposits from customers

25.0%

20.0%

15.0%

10.0%

5.0%

0.0%

31 Dec 201931 Dec 202031 Dec 2021

20.1%

20.1%

20.4%

18.8%

16.4%

19.1%

14.8%

18.4%%

14.3%

13.8%

17.5%

18.6%

Corporatebanking

Corporate banking recorded a growth in deposits (22%),

as well as in gross loans to corporate (3%). The pandemic

situation had a huge influence in reducing the demand for

investments and new projects for the second year in the

row, which also effected the loan portfolio in this segment.

The Banking Agency of Republic of Srpska (BARS) maintains

reliefs, moratoriums, and grace periods for clients directly and

indirectly affected by the negative effects from the pandemic.

Financial performance

Table 21:

Key performance indicators of NLB Banka, Banja Luka

(i)

in EUR thousand

20212020

Change YoY

Key performance indicators

Net interest income20,08718,5898.1%

Net non-interest income13,12811,47714.4%

Total costs-15,182-13,874-9.4%

Impairments and provisions1,379-5,009-

Result before tax19,41211,18373.6%

Result after tax18,18010,12279.6%

Financial position statement indicators

Total assets927,152796,48616.4%

Net loans to customers471,144430,7139.4%

Gross loans to customers488,672450,7088.4%

Deposits from customers759,915633,50720.0%

Equity97,14999,872-2.7%

Key financial indicators

Total capital ratio16.9%17.3%-0.5 p.p.

Net interest margin2.4%2.5%-0.1 p.p.

ROE a.t.17.0%10.8%6.2 p.p.

ROA a.t.2.1%1.3%0.8 p.p.

CIR45.7%46.1%-0.4 p.p.

NPL volume9,37113,703-31.6%

NPL ratio (internal def.:

NPL/Total loans)

1.3%2.3%-1.0 p.p.

Market share by total assets19.1%18.6%0.4 p.p.

LTD

62.0%68.0%-6.0 p.p.

(i)

Data on a stand-alone basis as included in the consolidated financial statements

of the Group.

The bank realised a profit after tax in the amount of EUR 18.2

million (2020: EUR 10.1 million), and profit before impairments

and provisions in the amount of EUR 18.0 million (2020: EUR

16.2 million). ROE a.t. was 17.0% (2020: 10.8%) and CIR dropped

to 45.7% (2020: 46.1%). TCR also dropped to 16.9% (2020:

17.3%). The main drivers of the result were higher income and

19.1%

market share in total assets.

EUR

19.4 million

result b.t.

![]()

82

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Komercijalna Banka,

Banja Luka

The sale process of Komercijalna Banka, Banja Luka was

concluded on 9December2021, therefore after that date the

bank was no longer part of NLB Group. Until 9 December

2021 Komercijalna Banka, Banja Luka was part of the core

segment, one of the stand-alone member banks of the Group,

therefore the key performance indicators of the bank for 2021

are represented in the table below.

Table 22:

Key performance indicators of Komercijalna Banka, Banja Luka

(i)

in EUR thousand

2021

Key performance indicators

Net interest income4,885

Net non-interest income1,655

Total costs-5,393

Impairments and provisions-607

Result before tax540

Result after tax495

(i)

Data on a stand-alone basis as included in the consolidated financial statements

of the Group. For year 2020 comparable data are not available.

![]()

83

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

NLB Banka, Sarajevo

The predominant strength of the bank is in consumer lending

and the development of innovative retail products largely

contributing to a high share of net non-interest income (33%

of fee and commission income in net income). Improving

customer experience was achieved with the introduction of

new digital products and robotic process automation (RPA)

solutions.

Macroeconomic Snapshot

In BiH, the economy expanded at a softer pace in Q3, partly

due to a less favourable base effect. Private consumption

recorded the largest slowdown in growth rate amid rising

inflation. Higher growth in public and capital spending

propelled the domestic economy. In Q4, a further rise in

consumer prices and pandemic-related restrictions further

weighed on private consumption.

Figure 54:

GDP growth, Inflation, Unemployment

6.0

3.0

0.0

-3.0

-6.0

6.0

4.0

2.0

0.0

-2.0

16.0

14.0

12.0

10.0

202020212022202020212022202020212022

GDP (real growth in %)Average inflation (in %)Unemployment rate (in %)

Outlook

The economy is expected to record a solid growth in 2022,

supported by higher capital and public spending while

relaxationof restrictive pandemic-related measures at

home and abroad should further bolster economic activity.

Pandemic-related uncertainty,slowerrecovery in export

markets, and political tensions represent the downside risks to

the outlook. Additional downside risk to the outlook has arisen

due to the war in Ukraine.

Contribution to NLB Group

Figure 55:

Contributionto NLB Group

Result b.t.

4%

Net interest income

4%

4%

Net non-interest

income

Banking services provided through:

36 branches

84 ATMs

7

th

largest bank in the Federation of BiH.

![]()

84

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Financial performance

Table 23:

Key performance indicators of NLB Banka. Sarajevo

(i)

in EUR thousand

20212020

Change YoY

Key performance indicators

Net interest income17,79517,826-0.2%

Net non-interest income10,2568,90215.2%

Total costs-16,183-15,113-7.1%

Impairments and provisions-920-5,06381.8%

Result before tax10,9486,55267.1%

Result after tax10,0125,89569.8%

Financial position statement indicators

Total assets727,860647,15012.5%

Net loans to customers452,977399,14613.5%

Gross loans to customers473,118420,27412.6%

Deposits from customers593,026521,63913.7%

Equity87,83889,808-2.2%

Key financial indicators

Total capital ratio16.9%17.9%-1.1 p.p.

Net interest margin2.8%2.9%-0.2 p.p.

ROE a.t.10.7%7.0%3.7 p.p.

ROA a.t.1.5%0.9%0.6 p.p.

CIR57.7%56.5%1.1 p.p.

NPL volume19,04624,691-22.9%

NPL ratio (internal def.:

NPL/Total loans)

3.1%4.5%-1.4 p.p.

Market share by total assets

(ii)

5.4%5.2%0.2 p.p.

LTD

76.4%76.5%-0.1 p.p.

(i)

Data on a stand-alone basis as included in the consolidated financial statements

of the Group.

(ii)

Data for 2021 as at 30 September 2021.

The bank realised a profit after tax in the amount of EUR 10.0

million (2020: EUR 5.9 million), and profit before impairments

and provisions in the amount of EUR 11.9 million (2020: EUR 11.6

million). The higher profit was the result of higher net non-

interest income and release of impairments and provisions.

ROE a.t. increased to 10.7% (2020: 7.0%), and CIR increased to

57.7% (2020: 56.5%). Net interest income was at the same level

as in 2020, while net interest margin dropped to 2.8% (2020:

2.9%). Net non-interest income was higher than previous year,

mainly due to higher net income from financial operations.

The bank intensified activities on less risky products such as

trade finance and with good results compensated missing

interest income. TCR stood at 16.9% and was above the

regulatory required minimum. Total assets of the bank rose by

12%, with 13% growth in net loans and 14% growth in deposits.

The NPL ratio decreased to 3.1% (2020: 4.5%).

Business performance

Retail banking

Retail banking recorded growth in gross loans (12%) and

deposits (8%). Growth in gross retail loans was driven by

growth of housing and consumer loans. Significant growth

of housing loans of 41% was the result of increased demand,

many campaigns and increased engagement of employees.

The share of housing loans in total retail loans increased by

4p.p., to 20.5%. The average interest rate in the retail segment

is decreasing (2021: 5.73%; 2020: 6.26%).

The bank continued with activities aimed to increase the

active number of e- and m-banking users; the number of

active users for e- and m-Bank in 2021 increased by 60%, and

the number of transactions by 72%.

Figure 56:

3-year market share evolution

(i)

Market share by total assets

Market share in loans to corporate

Market share in loans to individuals

Market share in deposits from customers

7.0%

6.0%

5.0%

4.0%

3.0%

2.0%

1.0%

0.0%

31 Dec 201931 Dec 202031 Dec 2021

6.1%

6.3%

6.6%

5.3%

5.3%

5.1%

5.5%

5.4%

5.4%

5.0%

5.2%

5.2%

(i)

Market share data for 2021 as at 30 September 2021.

Corporatebanking

The corporate banking segment recorded a growth in gross

loans (14%) and deposits (9%). Focus was on increasing the

client loan portfolio with acquisition of new creditworthy

clients. Also, a positive trend was in the volume of guarantees

portfolio, mainly due to the introduction of a new product

‘Guarantee Line.’

Deposits from corporates increased. In December, the bank

introduced a fee for vista deposits above EUR 0.3 million for

legal entities, with the exception of the government and public

enterprises. The aim was to reduce the concentration of a

vista corporate deposits.

5.4%

13

market share in total assets.

13 Data for 2021 as at

30September 2021.

EUR

10.9 million

result b.t.

![]()

85

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

NLB Banka, Prishtina

On its market, the bank is the market leader and had above

average growth in 2021. The predominant strength of the bank

is in providing a full spectrum of financial services to retail and

corporate clients, and being a market leader in innovations

on the local banking sector. A noticeable boost has been

observed in e-banking usage resulting in an increased

number of e-banking users by 17.8%.

Macroeconomic Snapshot

In Kosovo, the pace of economic expansion softened in Q3,

although it remained strong. The deceleration reflected

softer domestic demand with private and public consumption

increasing at a slower pace. Exports of goods and services

propelled the economy in Q3. In Q4, domestic demand

seems to have cooled amid rising inflation and falling

remittances inflows. Nevertheless, in 2021 remittances inflows

largely surpassed pre-pandemic levels, thus representing a

considerable domestic demand aid. Diaspora inflows were in

general a significant driver of the economic growth, especially

when pandemic-related restrictive measures wereeased.

Figure 57:

GDP growth, Inflation, Unemployment

12.0

6.0

0.0

-6.0

8.0

6.0

4.0

2.0

0.0

26.0

24.0

22.0

20.0

202020212022202020212022202020212022

GDP (real growth in %)Average inflation (in %)Unemployment rate (in %)

Outlook

The economy should record a robust although cooled-down

economic growth in 2022 due to the lower base effect. Firming

capital expenditure growth and a tighter labour market are

seen supporting activity, assisted by the beneficial effect of

healthier external backdrop.Pandemic-related uncertainty

and lingering political uncertainty are downside risks to

the outlook. The war in Ukraine and its overall economic

implication represents additional downside risks to the

outlook.

Contribution to NLB Group

Figure 58:

Contributionto NLB Group

Result b.t.

10%

Net interest income

9%

3%

Net non-interest

income

Banking services provided through:

33 branches

99 ATMs

2

nd

largest bank in the country.

![]()

86

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Financial performance

Table 24:

Key performance indicators of NLB Banka, Prishtina

(i)

in EUR thousand

20212020

Change YoY

Key performance indicators

Net interest income34,45932,2866.7%

Net non-interest income7,3746,39215.4%

Total costs-13,546-12,289-10.2%

Impairments and provisions-1,064-11,34590.6%

Result before tax27,22315,04481.0%

Result after tax24,43613,33483.3%

Financial position statement indicators

Total assets930,545879,0645.9%

Net loans to customers634,529559,22313.5%

Gross loans to customers672,376596,07612.8%

Deposits from customers798,790748,3156.7%

Equity98,85698,3350.5%

Key financial indicators

Total capital ratio17.3%17.8%-0.5 p.p.

Net interest margin3.8%3.9%-0.1 p.p.

ROE a.t.22.4%14.5%8.0 p.p.

ROA a.t.2.7%1.6%1.1 p.p.

CIR32.4%31.8%0.6 p.p.

NPL volume15,61417,519-10.9%

NPL ratio (internal def.:

NPL/Total loans)

1.9%2.3%-0.3 p.p.

Market share by total assets16.3%17.2%-0.9 p.p.

LTD

79.4%74.7%4.7 p.p.

(i)

Data on a stand-alone basis as included in the consolidated financial statements

of the Group.

The financial result of the bank remained solid, although

influenced by COVID-19. The net profit amounted to EUR

24.4 million (2020: EUR 13.3 million), while the profit before

impairments and provisions increased to EUR 28.3 million

(2020: EUR 26.4 million). ROE a.t. was 22.4% (2020: 14.5%), while

CIR minimally increased to 32.4% (2020: 31.8%). TCR decreased

to 17.3% (2020: 17.8%) due to dividend payout. The result was

mainly driven by the increase of the business volumes. The

total assets of the bank rose by 6%, the main factors were

the amount of net loans to customers and deposits from

customers. The NPL ratio decreased to 1.9% (2020: 2.3%).

Business performance

Retail banking

In 2021, the bank recorded growth in gross loans (17%) and

deposits (12%). The retail loan portfolio was dominated by

housing loans (70.7% of gross retail loans), while consumer

loans occupied 26.3% of gross retail loans. Growth in gross

retail loans was recorded, mainly due to the increased volume

of housing loans (21% growth). The key drivers of income

growth were housing loans.

The growth in retail was mainly driven by several partnership

agreements with construction and trade companies to finance

its products. New m-Klik features were also introduced.

Figure 59:

3-year market share evolution

Market share by total assets

Market share in loans to corporate

Market share in loans to individuals

Market share in deposits from customers

19.5%

19.0%

18.5%

18.0%

17.5%

17.0%

16.5%

16.0%

15.5%

15.0%

31 Dec 201931 Dec 202031 Dec 2021

18.8%

18.9%

18.7%

18.3%

17.9%

17.6%

16.9%

16.7%

16.3%

17.2%

17.5%

17.4%

Corporatebanking

Corporate banking recorded growth in gross loans (10%),

which was mainly due to the cross-selling of products through

existing corporate clients targeting new retail and SME clients

as well. A discouraging approach on deposits was reflected

in a 7% decrease compared to 2020 YE. The key drivers of

income growth were loans for fixed assets and overdrafts.

The bank offered fast, safe, and reliable execution of

payments, and competitive pricing led to an increased

number of payments contributing to the non-interest income

growth. Cooperation on the Group level resulted in the

financing of the construction of a major locally recognised

project contributing largely to clean energy production from

renewable sources.

16.3%

market share in total assets.

EUR

27.2 million

result b.t.

![]()

87

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

NLB Banka,Podgorica

On 12 November 2021, the merger of NLB Banka, Podgorica

and Komercijalna Banka, Podgorica was completed and the

bank continues to operate under the franchise of NLB Banka,

Podgorica. On its local market, the bank is categorised as one

of the systemically important banks. The merged bank (NLB

Banka, Podgorica) is the second largest financial institution

in Montenegro. As the first positive effect of the merger, NLB

Klik, web and e-banking app are offering new and upgraded

functionalities to the clients.

The predominant strength of the bank is seen in the segment

of retail housing and consumer loans, where the bank is an

important player on the local market. It achieved the highest

housing loans growth in 2021 amongst all banking members.

The year was marked by several campaigns promoting digital

channels, with a focus on cards, packages, and NLB Pay.

Also, expanding the number of partners, the ‘NLB Loan on

the spot’ campaign continued. After implementing the new

payment service SWIFT GPI, the bank became the only bank

in Montenegro connected to the SWIFT GPI platform with the

aim of improving SWIFT payments for both banks and clients,

providing faster implementation, transparency of transaction

costs, and real-time transaction

status information.

Macroeconomic Snapshot

In Montenegro, the economy accelerated in Q3 due to robust

public consumption and surging export growth as the tourism

sector fared well. In Q4, industrial output growth gained some

steam, while the tourism sector continued to record strong

increases in arrivals. Rising inflation resulted in eased retail

sales.

Figure 60:

GDP growth, Inflation, Unemployment

16.0

8.0

0.0

-8.0

-16.0

6.0

4.0

2.0

0.0

-2.0

18.0

16.0

14.0

12.0

202020212022202020212022202020212022

GDP (real growth in %)Average inflation (in %)Unemployment rate (in %)

Outlook

The economic growth is expected to ease in 2022 due to a

fading base effect. Further growth in the tourism sector should

propel the economy to recover towards the pre-pandemic

level with the easing of pandemic-related restrictions also

supporting domestic and foreign demand. The key downside

risk to the outlook is related to the pandemic-uncertainty and

its effect on the tourism sector due to Montenegrin economy’s

considerable dependence on this sector of the economy. The

war in Ukraine has emerged as an additional negative risk to

the outlook.

Contribution to NLB Group

Figure 61:

Contributionto NLB Group

Result b.t.

4%

Net interest income

5%

2%

Net non-interest

income

2

nd

largest bank in the country.

Banking services provided through:

22 branches

65 ATMs

![]()

88

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Financial performance

Table 25:

Key performance indicators of NLB Banka, Podgorica

(i)

in EUR thousand

20212020

Change YoY

Key performance indicators

Net interest income21,95320,5986.6%

Net non-interest income6,1613,74164.7%

Total costs-17,351-13,622-27.4%

Impairments and provisions613-8,887-

Result before tax11,3761,830-

Result after tax10,0501,387-

Financial position statement indicators

Total assets751,351537,62939.8%

Net loans to customers491,579367,16833.9%

Gross loans to customers514,308386,52533.1%

Deposits from customers609,792431,65741.3%

Equity92,64368,55635.1%

Key financial indicators

Total capital ratio16.3%16.2%0.1 p.p.

Net interest margin4.0%4.1%-0.1 p.p.

ROE a.t.13.1%2.0%11.1 p.p.

ROA a.t.1.7%0.3%1.4 p.p.

CIR61.7%56.0%5.7 p.p.

NPL volume42,16627,28054.6%

NPL ratio (internal def.:

NPL/Total loans)

7.0%5.8%1.2 p.p.

Market share by total assets14.1%11.7%2.4 p.p.

LTD

80.6%85.1%-4.4 p.p.

(i)

Data on a stand-alone basis as included in the consolidated financial statements

of the Group.

The bank realised profit after tax in the amount of EUR 10.1

million (2020: EUR 1.4 million) and profit before impairments

and provisions in the amount of EUR 10.8 million (2020: EUR

10.7 million). Compared to previous year, positive development

is visible in the segment of net impairments and provisions

cost. ROE a.t. increased to 13.1% (2020: 2.0%), while CIR

increased to 61.7% (2020: 56.0%). TCR was slightly higher

compared to last year and reached 16.3% (2020: 16.2%).

Theresult was driven by the double-digit growth of the loan

portfolio to individuals being the main net interest income

driver. The total assets increased by 40%, mainly due to

merger. In 2021, mainly due to the merger, the bank increased

the volume of new NPL. The NPL ratio increased to 7.0%

(2020:5.8%).

Business performance

Retail banking

Retail banking recorded growth in gross loans (30%) and

deposits (41%) mainly due to merger effect, and the positive

effect of the tourist season in July and August. A major part of

the retail loan portfolio was dominated by housing loans (60%

of gross retail loans), while consumer loans occupied 40% of

gross retail loans. Growth in gross retail loans was recorded

mainly by increase in housing loans volume by 36%, whereas

consumer loans grew by 23%, boosted by the merger and Q4

campaign period.

The bank expanded its offer to citizens by launching the

bancassurance product, thus enabling the clients to buy

online quickly, easily, cheaply, and completelysafely,

accident

and property insurance policies. The bank offered a cash loan

to individuals in the maximum amount of EUR 25,000 for up to

10 years and in this way offered the market a cash loan with

the largest amount and the longest repayment period. In a

joint project, the bank and Mastercard provided the first self-

service payment terminal in Montenegro.

Figure 62:

3-year market share evolution

Market share by total assets

Market share in loans to corporate

Market share in loans to individuals

Market share in deposits from customers

25.0%

20.0%

15.0%

10.0%

5.0%

0.0%

31 Dec 201931 Dec 202031 Dec 2021

16.9%

18.1%

22.9%

11.9%

12.6%

8.3%

14.5%

14.1%

11.9%

8.7%

11.7%

12.8%

Corporatebanking

Corporate banking segment recorded growth in gross

loans (42%) and deposits (36%) due to merger effect. The

loan portfolio predominantly consisted of large corporates

portfolio, which increased by 40% YoY. The growth in gross

loans was recorded mainly due to merger effect and an

increase of SME loans and used overdrafts by 47%. The

increase in overall interest income in corporate segment

comes from increase in volumes.

During 2021, a credit line from the EBRD was launched for the

purpose of implementing the project ‘Women in Business’

(WiB), which aims to support women in business and their

business.

14.1%

market share in total assets.

EUR

11.4 million

result b.t.

![]()

89

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Komercijalna Banka,

Podgorica

On 12 November 2021, the merger of Komercijalna Banka,

Podgorica with NLB Banka, Podgorica was completed. Until

12 November 2021 Komercijalna Banka, Podgorica was part of

the core segment, one of the standalone member banks of the

Group, so, the key performance indicators of the bank for 2021

are represented in the below table.

Table 26:

Keyperformance indicators of Komercijalna Banka, Podgorica

(i)

in EUR thousand

2021

Key performance indicators

Net interest income5,306

Net non-interest income537

Total costs-6,049

Impairments and provisions-5,658

Result before tax-5,864

Result after tax-5,761

(i)

Data on a stand-alone basis as included in the consolidated financial statements

of the Group. For year 2020 comparable data are not available.

![]()

We are always available.

Great-grandmothers paid with cash.

Grandmothers paid with cheques.

Mothers pay digitally.

What will the next generation come up with?

In order to keep up with the ever faster global changes, we develop solutions with the same features as the modern

world: they are fast, efficient, handy and smart. With innovative digital solutions, we ensure that all banking services

are available anyplace, anytime, while at the same time we use advanced safety technology to help protect privacy.

![]()

91

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

The segment is focused on the Group’s

activities on international financial markets,

including treasury operations. In the

challenging environment of low interest rates

on financial markets, continuous focus was

on prudent liquidity reserves management.

Financial Markets inSlovenia

Contribution to NLB Group

Figure 63:

Contributionto NLB Group

Financial performance

Table 27:

Performance of the Financial Markets in Slovenia segment

in EUR million consolidated

20212020

Change YoY

Net interest income26.423.52.912%

o/w ALM

(i)

17.116.50.64%

Net non-interest income-2.316.2-18.4-

Total net operating income24.139.6-15.5-39%

Total costs-8.6-7.6-1.0-14%

Result before impairments and provisions15.532.0-16.6-52%

lmpairrrents and provisions0.3-1.31.6-

Result before tax15.830.8-15.0-49%

31 Dec 202131 Dec 2020

Change YoY

Balances with Central banks2,982.21,998.1984.249%

Banking book securities2,977.52,945.831.71%

Interest rate on banking book securities0.68%0.77%-0.09 p.p.

Wholesale funding873.5143.5730.0-

Interest rate on wholesale funding-0.46%0.54%-1.00 p.p.

Subordinated liabilities288.5288.30.20%

Interest rate on subordinated liabilities3.70%3.64%0.06 p.p.

(i)

Net interest income from assets and liabilities with the use of FTP.

Net interest income

Net interest income was EUR 2.9 million (12%) higher YoY,

mostly due to the changed FTP policy which partially

transferred the costs of placing the excess liquidity from

treasury to the retail and corporate segments to de-stimulate

the deposit collection. Otherwise, the revenues from

treasury activities were YoY lower due to significantly lower

reinvestment yields of banking book securities and excess

liquidity, additionally reflected in the negative effect from

higher placements with the CB at negative interest rates.

Result b.t.

6%

Net interest income

6%

Net non-interest income

Lower net non-interest income, EUR 18.4 million YoY, due to the

one-off effect from the sale of debt securities, which positively

impacted performance in 2020.

Assets increase mostly offset

by wholesale funding

Increase in balances with CBs (EUR 984.2 million YoY) mostly

due to increase in wholesale funding by EUR 730.0 million

derived from participation in the ECB‘s liquidity providing

operation TLTRO-III (EUR 750 million). Banking book securities

registered a minor increase by EUR 31.7 million or 1%.

![]()

92

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Business performance

The Group’s ALM

Focus

The purpose of the Group ALM process is to strategically

manage the Group’s balance sheet with respect to the

interest rate, currency, and liquidity risk considering the

macroeconomic environment and financial markets

development.

Organisation

Monitoring and management of the Group’s exposure to

market risk is decentralised. Uniform guidelines and limits

for each type of risk are set for individual Group member.

The exposure of an individual Group member is regularly

monitored and reported to the Group ALCO.

Balance sheet management

From the interest rate risk perspective, the surplus liquidity

position of the Group contributed to further growth of fixed

interest rate loans, mostly housing loans, and investments

in high quality debt securities. In terms of funding, the non-

banking sector deposits continued to increase in the form

of sight deposits and savings accounts, partly as a result

of the increased propensity to save due to the COVID-19

pandemic. The Group manages its positions and stabilises

its interest margin by actively adjusting pricing policy and by

charging maintenance fees, whereas for managing interest

rate risk exposure the Group keeps outstanding plain vanilla

derivatives. Active profitability management has been

supported by a highly disciplined deposit pricing policy,

enabling the response to a very competitive loan market all

over the Group’s strategic markets.

The Group’s FX risk is measured and managed with the use

of a combination of a sensitivity analysis, VaR, and stress test

scenarios. In terms of the liquidity risk management, each

Group member is responsible for ensuring adequate liquidity

via the necessary sources of funding and their appropriate

diversification, and for managing liquid assets and fulfilling

the requirements of regulations governing liquidity.

Liquiditymanagement

Focus

The Group’s liquidity management focuses on ensuring a

sufficient level of liquidity reserves to settle all due liabilities,

minimising the cost of maintaining liquidity and optimising

the structure of liquidity reserves. To ensure an appropriate

level of liquidity for different situations, emergencies and crisis

conditions are anticipated and therefore described in the

liquidity contingency plan.

Organisation

Liquidity management in the Group is decentralised. Each

Group member manages its own liquidity on operational and

strategic levels, while Financial Markets in Slovenia manage

liquidity of the Bank.

Finland

Austria

Netherlands

Germany

Belgium

France

N. Macedonia

Slovenia

Serbia

Other

0% 5% 10% 15% 20% 25% 30%

3%

3%

4%

4%

4%

7%

7%

13%

24%

30%

Corporate

Subodrinated debt

Agency

GGB

Covered bond

Senior Unsecured

Government sec.

0% 10% 20% 30% 40% 50% 60% 70% 80%

7%

10%

77%

0%

1%

2%

3%

Figure 64:

Banking book securities portfolio of NLB Group by asset class and geographical structure as at 31 December 2021

77%

government securities in the Group’s

banking book portfolio.

Geographical structure

Asset class distribution

![]()

93

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Liquid assets

For settling due liabilities, the Group uses its liquid assets,

which are comprised of liquidity reserves (see the subchapter

Liquidity Position

in the chapter

Overview of Financial

Performance

) and other liquid assets. The latter includes

funds held on accounts with other banks and money market

placements which are according to LCR calculation treated as

inflows. Likewise, liquid assets are managed by each Group

member on its own.

Banking book securities portfolio

At year-end, the banking book debt securities portfolio

constituted 23.7% of the Group’s total assets. The purpose

of the banking book securities is to provide liquidity, along

with stabilisation of the interest margin, and interest rate

risk management. The portfolio is well diversified from the

geographical, asset class and maturity profile perspective.

From 2020, the Group turned its attention to the new and fast-

developing market of ESG bonds. Currently, these bonds have

a small share in the whole portfolio (EUR 106.2 million), but it is

expected to grow in the future.

in EUR million



20222023-20242025-20262027+Total

Domestic securities

(the Group strategic markets)

489.3774.4741.9498.22,503.8

- Slovenia53.3100.7172.4329.4655.9

- Other SEE435.9673.7569.5168.81,847.9

International securities498.8706.3541.4810.12,556.5

Total988.01,480.71,283.31,308.35,060.3

3.5 years

average maturity of the Group’s banking

book securities portfolio.

Characteristics of banking book

securities portfolio

The average maturity of banking book securities is

approximately 3.5 years as at year-end.

The average yield achieved in 2021 on the Group’s banking

book securities portfolio was 0.68% (2020: 0.77%).

Wholesalefunding

Purpose

Wholesale funding activities in the Group are conducted with

the aim of achieving diversification, improving structural

liquidity and capital position, and fulfilling regulatory

requirements, especially ensuring compliance with the MREL

requirement.

The Bank was not active on the wholesale market in 2021, but

has instead optimized its long-term funding structure with the

repayment of certain credit lines.

Table 28:

Maturity profile of NLB Group’s banking book securities as at 31December 2021

![]()

94

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Financial performance

Table 29:

Results of the Non-Core Members segment

in EUR million consolidated

20212020

Change YoY

Net interest income1.31.20.111%

Net non-interest income5.94.21.639%

Total net operating income7.25.41.833%

Total costs-11.4-12.91.512%

Result before impairments and provisions-4.1-7.43.344%

lmpairrrents and provisions5.42.92.589%

Result before tax1.3-4.65.8-

31 Dec 202131 Dec 2020

Change YoY

Segment assets

95.9131.2-35.3-27%

Net loans to customers24.345.0-20.7-46%

Gross loans to customers53.995.0-41.1-43%

Investment property and property &

equipment received for repayment of loans

65.670.2-4.6-7%

Other assets6.016.0-10.0-63%

Non-performing loans (gross)45.071.3-26.3-37%

Result before tax

The segment recorded EUR 1.3million profit before tax. The

higher net non-interest income was achieved also due to the

positive effect attributable to the segment from the settlement

of a legal dispute (EUR 0.4 million).

Total assets decreased

A decrease of the total assets of the segment YoY (EUR 35.3

million) was in line with the divestment strategy of the non-

core segment.

The Non-Core Members segment includes

the operations of non-coreGroup members.

The main objective in the Non-Core segment

remains a rigorous wind-down of all non-core

portfolios and the consequent reduction of

costs. The implementation of the wind-down

has been pursued with a variety of measures,

including the sales of portfolios, sales of non-

core entities, sales of individual assets, the

collection or restructuring of individual assets,

and active management of real-estate assets.

Non-Core Members

EUR 41.1

million

reduction of gross loans to

customers in 2021.

![]()

95

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Business performance

The wind-down of the Non-Core

segment in 2021 included:

•Divestment of non-core Group members

•

Sale of the Bank’sequity participations

•

Active management of real-estate assets

Divestment of non-core

Group members

Liquidation process

A liquidation process was initiated in all non-core leasing

and trade finance subsidiaries and some real estate

subsidiaries. In 2021, the liquidation processes of BH-RE d.o.o.

Sarajevo and Prvi faktor d.o.o. Sarajevo were completed,

and the companies were deleted from the court register. The

divestment process has been running with thoughtful cost

management and well-established collection procedures.

Decrease of non-core portfolio

New business has been suspended in all non-core Group

members which are in the process of being wound-down. The

decrease of the cumulative non-core subsidiaries’ portfolio

remains ongoing through regular repayments and collection

measures.

Sale of NLB’s equity participations

Numbers

At the 2021 YE, the overall asset volume of equity participations

is at EUR 0.20 million (2020: EUR 0.28 million).

EUR 25.1

million

the total sales value of real-estate

transactions executed or supported

by the real-estate team in 2021.

Active managementof real estate

assets

Divestment process

The divestment process of still remaining NPL exposures at the

Bank or at the non-core subsidiaries’ level is being facilitated

through a specialised team for repossessing, managing, and

divesting collateral real estate. Real estate expertise and

services are offered to the Group members assisting them in

implementation of the mostefficient divestment manner of the

remaining non-performing portfolio or the repossession of

the collateral real-estates.

Value-preserving strategies

The main task is to ensure value-preserving strategies for the

real estate management, respectivelythe collateralvalue of

NPL claims by either temporarily repossessing real-estate or

ensuring a value-preserving divestment process of the real-

estate or a claim. From 2015 to 2021, real-estate transactions

with a total sales value of EUR 193.8 million were executed

or supported, and directly or indirectly contributed to a EUR

622.6 million of NPL reduction, of which EUR 122.5 million in

2021 alone.

![]()

96

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

The Group has a well-diversified business model. In

accordance with its strategic orientations, it intends to be a

sustainably profitable, predominantly working with clients on

its core markets, providing innovative but simple customer-

orientedsolutions, and activelycontributing to a more

balanced and inclusive economic and social system. Efficient

managing of risks and capital is crucial for the Group to

sustain long-term profitable operations. Risk Management

in the Group is in charge of managing, assessing, and

monitoring risks within the Bank as the main entity in Slovenia,

and the competence centre for seven banking subsidiaries.

Figure 65:

Risk profile of NLB Group as at 31 December 2021

Credit risk

Concentration risk

Credit spread risk

Interest rate riskin banking book

Operational risk

Market risk

Business and Strategic risk

Based on the Group’s business strategy, credit risk is the

dominant risk category, followed by credit spread and

interest rate risk in the banking book and operational risk.

Management of credit risk focuses on moderate risk-taking,

striving to assure a diversified credit portfolio, adequate credit

portfolio quality, the sustainable cost of risk, and optimal

return considering the risks assumed. The Group has limited

exposure to other aforementioned risks, while market risk and

0.8%2.2%

63.2%

3.1%

13.2%

10.4%

7.1%

The self-funded model, strong liquidity,

and a solid capital position continued in

2021, demonstrating the Group’s financial

resilience. Efficient management of risks

and capital is crucial for the Group to

sustain long-term profitable operations.

A robust Risk Management framework is

comprehensively integrated into decision-

making, steering, and mitigation processes

within the Group, with the aim of proactively

supporting its business operations. The Group

is engaged in contributing to sustainable

finance by incorporating environmental,

social, and governance risks into its business

strategies, risk management framework,

and internal governance arrangements.

other non-financial risks are less important from materiality

perspective. The Group integrates and manages ESG risks

within the aforementioned types of risks, namely credit and

operational risk, as part of its risk management framework.

Liquidity risk tolerance is low. The Group must maintain an

appropriate level of liquidity at all times, and also pursue an

appropriate structure of the sources of financing.

Table30:

NLB Group’s Key Risk Appetite indicators (KRIs)

KRIs31 Dec 2021

TCR

17.8%

CET1 ratio15.5%

LCR

252.6%

NSFR185.2%

Cost of Risk-41 bps

NPL (EBA def.)3.4%

NPE (EBA def.)1.7%

Interest rate risk (EVE)-6.4%

COVID-19 did not have a meaningful impact on the quality of

the credit portfolio. Its impacts caused moderate credit quality

deterioration, which resulted in an increase of Stage 2 and

Stage 3 exposures. In Q2 2021, a reversal was observed, mainly

due to successful recovery of on- and off-balance sheet NPLs.

Respectively, the Group’s credit portfolio quality remained

solid, with stable rating structure and portfolio diversification.

Lending growth in the corporate segment remained relatively

moderate, while the retail segment, namely mortgage lending,

experienced a considerable growth in 2021.

The Group is compliant with EBA guidelines on payment

moratoria and is very prudent in identifying any increase in

credit risk. The vast schemes introduced by the governments

in the Group countries providing moratoriums to eligible

clients as part of the COVID-19 pandemic measures were

phasing out during the 2021. Apart from the moratoria, the

Group provided additional liquidity by granting new loans to

creditworthy clients to help them with the specific situation

due to the COVID-19 crisis.

The cost of risk was negative (-41 bps) due to very strong

development in NPL resolution and more favourable

macroeconomic situation compared to the 2020 YE. The

Risk Management

-41 bps

negative Cost of risk on Group level.

![]()

97

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Group faced favourable NPL movement due to repayments in

the segment of large corporate clients, and other successfully

resolved smaller exposures in the region. During the year, the

Group reviewed IFRS 9 provisioning by testing a set of relevant

macroeconomic scenarios to adequately reflect the current

circumstances and the related impacts in the future. The

Group established and developed multiple scenarios on the

level of ECL calculation.

Though COVID-19 coupled with its implications on the

business environment, the Group faced growing excess

liquidity and managed to stay well capitalised. The Group

is perceived as safe heaven and therefore faced growing

excess liquidity, and impacts of the pandemic did not cause

anymaterial liquidity outflows. Significantattention wasput

into the structure and concentration of liquidity reserves by

incorporating early warning systems, while keeping in mind

the potential adverse negative market movements. Excess

liquidity and market demand for fixed interest rate products

resulted in moderate interest rate and credit spread risk

exposure, which stayed within the risk appetite tolerance

toward this risk. The Group’s liquidity and capital position

remained strong in both the Group and banking member

levels.

In 2021, the Group was included into ECB Stress test exercise.

On 30 July, the results of stress tests carried out for important

banks by the ECB to assess the resilience of the financial

institutions have been disclosed. Under the adverse scenario,

CET1 ratio (fully loaded) would fall by maximum 483 bps

(published range 300-599 bps) after three years without

mitigation measures from the 2020 YE. The Group’s results of

adverse depletion were lower than for peer group and SSM

sample banks. Besides, the Group’s data quality and accuracy

were assessed as above average. Final results of the bottom-

up stress test showed that even in a very unfavourable market

conditions defined by the EBA and ECB, the Group holds

sufficient resilience in terms of capitalisation. The qualitative

outcomes were included in the determination of capital

requirements by ECB, namely setting Pillar 2 Guidance.

14

14Further information is available in chapter

Events After the End of 2021

Financial Year

.

The Bank is, as a systemic bank, involved in the Single

Supervisory Mechanism.

Supervision is under the jurisdiction of the Joint Supervisory

Team of:

ECB

BoS

ECB regulations are followed by the Group, where the Group

subsidiaries operating outside Sloveniaare compliant with

the rules set by the local regulators. Third party equvivalent

are approved in Serbia, BiH and North Macedonia, resulting

in alignment of local regulation with CRR rules.

Across the Group, risks are assessed, monitored, managed,

or mitigated in a uniform manner, as defined in the Group’s

Risk management standards, also considering the specifics

of the markets in which individual Group members operate.

Risk Management and control is performed through a

clear organisational structure with defined roles and

responsibilities. The organisation and delineation of

competencies is designed to prevent conflicts of interest,

ensure a transparent and documented decision-making

process, subject to an appropriate upward and downward

flow of information.

Business line Risk Management in NLB is, by encompassing

several professional areas, in charge of:

•formulating and controlling the Group’s Risk Management

policies,

•

setting limits,

•overseeing the harmonisation,

•regular monitoring of risk exposures and limits based on

centralised reporting at the Group level.

The Group puts great emphasis on the risk culture and

awareness across the entire Group. The Group’s Risk

Management framework is forward-looking and tailored to its

business model and corresponding risk profile. The main risk

principles and limits are set forth by the Group’s Risk Appetite

and Risk Strategy, and designed in accordance with business

strategy. The Group performs risk identification process on

regular basis, as part of the ICAAP and ILAAP frameworks. In

this process all topical risks, including ESG related ones, are

comprehensively assessed, monitored and mitigated where

necessary. Special focus is placed on the inclusion of risk

analysis into the decision-making process at strategic and

operating levels, diversification to avoid large concentration,

optimal capital usage and allocation, appropriate risk-

adjusted pricing, and overall compliance with internal rules

and regulations.

Risk Management focuses on managing and mitigating

risks in line with the Group’s Risk Appetite and Risk Strategy,

representing thefoundationof the Group’s Risk Management

framework. Within these frameworks, the Group monitors

a range of risk metrics in order to assure the Group’s risk

profile is in line with its Risk Appetite. In addition, the Group

is constantly enhancing its Risk Management system, where

consistent incorporation of ICAAP, ILAAP, Recovery plan,

and other internal stress-testing capabilities into the Risk

Management system is essential. Moreover, the Group puts

great emphasis on their integration into the overall Risk

Management system in order to assure proactive support for

informed decision-making.

Figure 66:

NLB Group’s Risk Management framework

Business strategy

ICAAP

&

ILAAP

inputs

Risk identification

Risk Appetite (Limit system)

Capital and Financial planning

Results

Recovery plan

Assessment of liquidity and capital (significant

deterioration)

ILAAP

•

Economic and normative

assessment of liquidity

• Stress tests

• Liquidity contingency

plan (LCP)

ICAAP

• Economic and

normative

assessment of

capital

• Stress tests

The uniform stress-testing programme, whichincludes

internally developed models, stress scenarios, and sensitivity

analysis, was further complemented. In 2021, the Group

![]()

98

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

established its own ESG stress testing concept to identify

the most relevant financial vulnerabilities stemming from

climate risk. Such a stress-testing framework is the subject

of a regular internal validation cycle and related procedures

where the Group established comprehensive validation

framework. Namely, the Group supports a strong validation

governance process and controls over applied selected risk

approaches and internal models.

The business and operating environment, relevant for

the Group operations is changing, with trends such as

changing customer behaviour, emerging new technologies

and competitors, actively contributing to a more balanced

and inclusive economic and social system, and increasing

new regulatory requirements. It should be noted that Risk

Management is continuously adapting with the aim of

detecting and managing new potential emerging risks.

Proactive Risk

Management in 2021

Prudent capital level position and

achieved interim MREL targets

One of the key aims of Risk Management is to preserve a

prudent level of the Group’s capital position. The Group

monitors its capital position at the Group and individual

subsidiary bank level in accordance with the Risk Appetite,

also incorporating normative and economic perspectives

as part of the established ICAAP process. As at 31 December

2021, the Group had a very solid capital position and TCR

of 17.8% (1.2 p.p. higher than at the 2020 YE). The CET1 ratio,

representing the capital of highest quality, stood at 15.5% (1.4

p.p. YoY increase).

The higher Group total capital adequacy compared to

the previous year derives from higher capital (increase of

EUR 186.8 million YoY, mainly due to inclusion of negative

goodwill in retained earnings) which compensated the RWA

increase of EUR 58.2 million YoY for the Group. Loan growth

to the corporates and retail and new investments in bonds

contributed to an increase of RWA for credit risk. On the other

hand, the increase was compensated by collateral adequacy

due to third party equivalent, agreements with MIGA,

changed investment policy and successful recovery of NPLs.

Additionally, the closing trading position of Komercijalna

Banka, Beograd resulted in a decrease in RWA for market

risks. RWA for operational risk increased due to higher income

of the Group arising from the acquisition of Komercijalna

Banka, Beograd.

As at 31 December 2021, the Group meets all fully loaded

regulatory requirements. Moreover, enhanced overall

corporate governance in the recent years led to a lower P2R,

which decreased from 3.5% in 2018 to 2.75% applicable in

2021 and 2.60% applicable as of 1 March 2022, while Pillar 2

Guidance remains at low level of 1%.

Figure67:

NLB Group’s Pillar 2 Requirement evolution

201720182019202020212022

(i)

2.60%

2.75%2.75%

3.25%

3.50%3.50%

(i)

Applicable as of 1 March 2022.

MREL requirement forms part of Group’s risk appetite,

whereby its fulfilment is regularly analysed and monitored.

NLB complies all interim targets. More information on MREL is

available in the chapter

Capital and Capital Adequacy

.

Maintaining a solid level and

structure of liquidity

Maintaining a solid level and structure of liquidity represents

the next very important risk target. The liquidity position of

the Group remained stable, and the impacts of the pandemic

did not cause any material liquidity outflows. Strong liquidity

position is held at the Group and individual subsidiary bank

levels. Group LCR slightly decreased to 252.6% (by 4.9 p.p. YoY),

but remained well above the risk appetite limit (130%). The

level of the unencumbered eligible liquid reserves remained at

a high level, representing 38.3% of total assets. The Group has

sufficient liquidity reserves in the form of placements with the

ECB, prime debt securities, and money market placements.

Even in the event of the combined adverse stress scenario, the

Group would survive at least three months under such stress

conditions. The core funding base of the Group predominately

represents retail customer deposits with very stable and

constantly growing base. LTD increased to 60.0% (31

December 2020: 58.8%), remaining at very comfortable level.

In June, the Bank participated in the 8. ECB operation, namely

TLTRO III and had drawn a credit tranche of EUR 750 million

maturing in three years. With TLTRO, the ECB continues to

support lending to enterprises and households. The Bank was

successful in achieving the lending performance threshold

in the special reference period, the positive effect from this

transaction will partially compensate the negative outcome

from holding liquidity reserves.

LCR NLB Group

450%

400%

350%

300%

250%

200%

150%

100%

31 Dec 2020

31 Jan 2021

28 Feb 2021

31 Mar 2021

30 Apr 2021

31 May 2021

30 Jun 2021

31 Jul 2021

31 Aug 2021

30 Sep 2021

31 Oct 2021

30 Nov 2021

31 Dec 2021

Figure 68:

NLB Group’s LCR

![]()

99

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Maintaining the adequate credit

portfolio quality

Maintaining the adequate credit portfolio quality is the

most important goal, with the focus on cautious risk-taking

and quality of new loans leading to a diversified portfolio

of customers. The Group is constantly developing a wide

range of advanced approaches in the segment of credit risk

assessment in line with best banking practices to further

enhance the existing risk management tools, while at the

same time enabling greater customer responsiveness. The

restructuring approach in the Group is focused on the early

detection of clients with potential financial difficulties and their

proactive treatment.

The Group is actively present on SEE markets by financing

the existing and new creditworthy clients. The Group’s

lending strategy focuses on its core markets of retail, SME,

and selected corporate business activities within the region

and EU. On the Slovenian market, the focus is on providing

appropriate solutions for retail, medium-sized companies,

and small enterprise segments, whereas on the corporate

segment, the Bank established cooperation with selected

corporate clients (through different types of lending or

investment instruments). All other banking members in the

SEE region, where the Group is present, are universal banks,

mainly focused on the retail, medium-sized companies, and

small enterprise segments. Their primary goal is to provide

comprehensive services to clients by applying prudent Risk

Management principles.

Lending growth in the corporate segment remained relatively

moderate, while the SME and retail segment experienced a

considerable growth in 2021 after a temporary slowdown in

2020 due to COVID-19 circumstances. The current structure

of credit portfolio (gross loans) consists of 36.2% retail clients,

14.8% large corporate clients, and 18.5% SMEs and micro

companies, while the remainder of the portfolio consists

of other liquid assets. The credit portfolio remains well

diversified, and there is no large concentration in any specific

industry or client segment. The share of retail portfolio in the

whole credit portfolio is quite substantial with still prevailing

segment of mortgage loans.

The majority of the Group’s loan portfolio is classified as

Stage 1 (94.2%), the remaining portfolio as Stage 2 (3.4%), and

Stage 3 and FVTPL (2.4%). The portfolio quality remains very

stable with increasing Stage 1 exposures and a relatively low

percentage of NPLs. The percentage of Stage 1 loan portfolio

Figure 69:

NLB Group structure of the credit portfolio

(i)

(gross loans) by segment (in EUR million) and rating

(ii)

Institutions

539

SME

2,881

Corporates

2,298

Retail

consumer

2,427

State

(iii)

4,202

Retail housing

3,195

ABCDE

61%

63%

65%

60%

63%

28%

30%

28%

33%

3%

32%

4%

4%

3%

3%3%

2%

2%

2%

1%

4%

2%

2%2%

1%

31 Dec 2018

31 Dec 2019

31 Dec 2020 w/o KB

31 Dec 2020

31 Dec 2021

Highest

quality

Default

NPLs

EUR 15.5 billion

(i)

Loan portfolio also includes reserves at CBs and demand deposits at banks.

(ii)

Rating A, B and C are performing exposures. Rating A: investment grade clients with high financial stability; Rating B: clients with high ability to repay their obligations, a significant aggravation of the economic environment would cause problems to them; Rating C:

performing clients with increased level of risk who may encounter problems with settlement of liabilities in the future; Ratings D and E are NPLs: Default clients (article 178 of CRR), including clients in delay >90days and other clients considered ‘unlikely to pay’ with delays

below 90 days. The numbers may not add up to 100% due to rounding.

(iii)

State includes exposures to CBs.

Proactive

risk

management

in 2021.

![]()

100

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

in EUR million

Corporate sector by industryNLB Group%∆ 2021

Accommodation and food service activities156.33.0%15.1

Administrative and support service activities108.12.1%-13.6

Agriculture, forestry and fishing310.76.0%22.0

Arts, entertainment and recreation22.70.4%1.7

Construction industry434.68.4%60.9

Education13.30.3%-0.8

Electricity, gas, steam and air conditioning318.26.1%60.1

Finance120.22.3%-47.5

Human health and social work activities37.90.7%-12.1

Information and communication244.14.7%10.2

Manufacturing1,091.121.1%105.0

Mining and quarrying50.41.0%-29.6

Professional, scientific and techn. act.175.43.4%3.7

Public admin., defence, compulsory social.172.43.3%-47.0

Real estate activities251.34.9%29.7

Services12.00.2%-1.9

Transport and storage573.311.1%-18.8

Water supply43.90.8%2.8

Wholesale and retail trade1,043.120.1%120.0

Other0.50.0%-1.3

Total Corporate sector5,179.5100.0%258.4

Table 31:

Overview of NLB Group loan portfolio by industry as at 31 December 2021

Institutions

3%

Retail

37%

Retail

consumer

43%

Stage 2

3%

Stage 1

94%

Stage 3

2%

FVTPL

0%

State

29%

Retail

mortgages

57%

Corporate sector

Retail sector

EUR 5.6 billion

Figure 70:

NLB Group loan portfolio (measured at amortised cost) by stages as

at 31 December 2021

Corporates

31%

remains almost at the same level as at 2020 YE, i.e., at 95.6%

in the Retail segment, while in the Corporate segment, despite

the adverse economic conditions, improved to the level

of 87.4%, which is a result of cautious lending policy and

successful closure of NPL.

COVID-19 did not have a meaningful impact on the quality

of the credit portfolio. The vast schemes introduced by the

governments in theGroup countries providingmoratoriums

to eligible clients as part of the COVID-19 pandemic measures

had been phasing out during the 2021.

As at 31 December 2021, the exposures where COVID-19

moratoria have been granted amounted to EUR 1,681.5

million, representing 10.8% of the Group’s credit portfolio. The

exposure with remaining COVID-19 moratoria is negligible and

amounts to EUR 24.8 million, while 98.5% of those moratoria

have already expired by 2021 YE. A total of 86.4% of exposure

![]()

101

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

with expired moratoria have no delays, while 2.1% had delays

exceeding 90 days. The Bank is very prudent in identifying any

increase in credit risk.

In addition to moratoria, the governments in Serbia and

Slovenia provided public guarantee schemes for new

financing of clients whose business has been materially

impacted due to the COVID-19 pandemic. As at 31 December

2021, these loans amounted to EUR 177.2 million; none of the

guarantees have been exercised.

Table 32:

NLB Group loan portfolio by stages as at 31 December 2021

in EUR million

Credit portfolioProvisions and FVchanges for credit portfolio

Stage1Stage2Stage3 & FVTPLStage1Stage2Stage3 & FVTPL

Credit

portfolio

Share of

Total

YTD

change

Credit

portfolio

Share of

Total

YTD

change

Credit

portfolio

Share of

Total

YTD

change

Provision

Volume

Provision

Coverage

Provision

Volume

Provision

Coverage

Provisions

& FV

changes

Coverage

with

provisions

and FV

changes

Total NLB Group14,638.094.2%1,987.2532.43.4%-27.6371.42.4%-104.370.40.5%34.06.4%212.157.1%

o/w Corporate4,525.587.4%389.9412.28.0%-14.6241.74.7%-116.850.61.1%26.66.5%136.056.3%

o/w Retail5,371.195.6%591.9120.22.1%-13.1129.72.3%12.618.30.3%7.46.2%76.058.6%

o/w State4,202.4100.0%912.3------1.30.0%----

o/w Institutions538.9100.0%93.2------0.20.0%----

Figure 71:

NLB Group Corporate and Retail loan portfolio (valued at amortised cost) by stages

+9%

YoY

+12%

YoY

2,811

3,207

3,170

4,136

4,526

3,492

3,822

4,779

427

5,371

427

445

412

367

133

104

133133

120

520

286

324

359

242

101

87

111

117

130

3,936

Stage 1 by segment

(in EUR million)

Stage 2 by segment

(in EUR million)

Stage 3 by segment

(in EUR million)

31 Dec 201831 Dec 201931 Dec 2020 w/o KB31 Dec 202031 Dec 2021

CorporateCorporateCorporateRetailRetailRetail

-3%

YoY

-10%

YoY

+11%

YoY

-33%

YoY

New NPLs formation and NPL

management

At the end of 2020, Komercijalna Banka group was acquired

and their NPL were included as an additional NPL formation

in net value (based on consolidation rules), which, along with

the COVID-19 related circumstances, resulted in the NPL

formation of EUR 148 million or 1.1% of the total portfolio. In

2021, NPL formation amounted to EUR 143 million or 0.9%

1.7%

NPE (EBA def.)

![]()

102

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

of the total portfolio and was influenced by harmonisation

process in Komercijalna Banka group. Nevertheless, the

total amount of NPL decreased during 2021. Proactive non-

performing management, including successful repayment of

on- and off-balance sheet exposures, and more favourable

macroeconomic situation across the region than initially

expected, resulted in a negative cost of risk.

Figure 73:

NLB Group gross NPL formation (in EUR million)

58

80

60

78

20172018201920202021

Formation / gross loans (stock)

20

21

16

35

36

37

60

212105

64

56

148

143

CorporateSMERetail

0.9%1.1%0.6%0.7%0.7%

Precisely set targets in the Group’s NPL Strategy and various

proactive workout approaches facilitated the management of

the non-performing portfolio. The Group’s approach to NPL

management puts a strong emphasis on restructuring and use

of other active NPLmanagement tools, such as foreclosure

of collateral, the sale of claims, and pledged assets. In 2021,

the multi-year declining trend of the non-performing credit

portfolio stock continued, mostly due to repayments, collection,

sale of claims, and cured clients. The non-performing credit

portfolio stock in the Group decreased at 2021 YE in comparison

with 2020 YE to EUR 367.4 million (2020 YE: EUR 474.7 million).

The combined result of contraction in non-performing credit

portfolio stock and credit growth of a higher quality portfolio

led to 2.4% of NPLs, while the internationally more comparable

NPE ratio, based on the EBA methodology, stood at 1.7%. The

Group’s indicator gross NPL ratio, defined by the EBA, is equal

to 3.4% and is below the regulatory defined threshold for

establishment of NPL strategy framework.

Figure 74:

NLB Group NPL, NPL ratio and Coverage ratio 1

(i)

(in EUR million)

4,000

3,500

3,000

2,500

2,000

1,500

1,000

500

0

100

90

80

70

60

50

40

30

20

10

0

31 Dec

2016

31 Dec

2017

31 Dec

2018

31 Dec

2019

31 Dec

2020

31 Dec

2021

Coverage ratio 1NPLratioNPLs

76.1%

1,299

13.8%

77.5%

844

9.2%

77.1%

622

6.9%

89.2%

375

3.8%

81.8%

475

3.5%

86.1%

367

2.4%

(i)

By internal definition.

Due to extensive experience gained in the last few years

in dealing with clients with financial difficulties, resulting

primarily from legacy portfolios, the Group has developed

an extensive knowledge base both in the prevention of

financial difficulties for clients, to restructure viable clients

in case of need, and to efficiently work out exposures with

no realistic recovery prospects. This extensive knowledge

base is available throughout the Group, and risk units, as

well as restructuring and workout teams are properly staffed

and have the capacity to deal, if needed, with considerably

increased volumes in a professional and efficient manner.

An important Group strength is the NPL coverage ratio 1

(coverage of gross NPLs with impairments for all loans),

which remains high at 86.1%. Furthermore, the Group’s NPL

coverage ratio 2 (coverage of gross NPLs with impairments

for NPL) stands at 57.9%, which is well above the EU average

as published by the EBA (45.1% for Q3 2021). As such, it

enables a further reduction in NPLs without significantly

influencing the cost of risk in the coming years. The decrease

in coverage indicators at the end of 2020 was influenced

by the special treatment of NPLs from the acquired entities.

NPLs of Komercijalna Banka group are initially recognised at

fair value, without any additional credit loss allowances. The

latter is also reflected in the lower coverage ratio CR2 than the

NLB Group banks average at the end of 2021 in Komercijalna

Banka, Beograd and NLB Banka, Podgorica, which merged

with Komercijalna Banka, Podgorica in November 2021.

The Group strives to ensure the best possible collateral for

long-term loans, namely mortgages in most cases. Thus,

the real-estate mortgage is the most frequent form of loan

collateral for corporate and retail clients. In the corporate

loans, it is followed by government and corporate guarantees.

In retail loans, the other most frequent types of loan collateral

are loan insurances by insurance companies and guarantors.

The Group is following the ECB guidelines to banks on NPLs

with regards to the evaluation of collateral.The establishment

of market values for collateral for NPLs is by means of

individual evaluation when NPL status is established. The value

of collateral is then regularly monitored on a yearly level and

updated by either independent evaluation (over prescribed

threshold) or with the use of statistical re-evaluation for smaller

values of NPL. For statistical re-evaluation the indexes from the

government agency or other relevant official data sources are

used. The value of collateral is with statistical approach always

updated only downwards, never upwards. Only if the individual

appraisal shows a higher value of collateral, the upwards re-

evaluation would be performed. If the data from statistics would

show significant decline in the real estate market, individual

evaluations for such types of real estate would be performed

and values corrected accordingly.

NO DELAYS1-30 DPD31-90 DPD>90 DPD

30 Sep 202031 Dec 202030 Sep 202131 Dec 2021

100%

90%

80%

70%

60%

50%

40%

30%

20%

10%

0%

81.8%

88.9%

84.8%

86.4%

14.1%

7.4%

11.5%

9.3%

2.4%

1.7%

2.2%

1.5%1.6%

2.1%2.1%2.1%

Figure 72:

% of Days past due for expired COVID-19 moratoria in NLB Group

![]()

103

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Low market risk in the trading book

Regarding market risks in the trading book, the Group

pursues a low-risk appetite for market risk in the trading book.

The exposure to trading (according to the CRR) is only allowed

to be carried by the parent Bank as the main entity of the

Group and is very limited. During the year 2021, the position of

trading book of Komercijalna Banka, Beograd decreased to

the minimum extent. The Bank intends to further maintain a

small trading portfolio, mainly to monitor market signals in the

global markets. Respectively, it does not constitute a material

risk to the Group’s operations, while its tolerance for interest

rate and credit spread risk in trading book is very low.

The Group carries its main business activities in euros, and the

subsidiary banks, in addition to their domestic currencies, also

operate in euros, which is the reporting currency of the Group.

The Group’s net open FX position from transactional risk is

low, and at less than 1.10%

of capital. Regarding structural FX

positions on a consolidated level, assets and liabilities held

in foreign operations are converted into euro currency at the

closing FX rate on the balance sheet date. FX differences of

non-euro assets and liabilities are recognised in the other

comprehensive income, and therefore affect shareholder’s

equity and CET1 capital.

Proactivemanagement of interest

rate risk in the banking book

The Group’s exposure to interest rate risk is moderate and

arises mainly from banking book positions. In the recent years,

the Group recorded the growth of fixed interest rate loans and

the long-term banking book securities on the assets side, and

the transformation of deposits from term to sight as a result of

the low interest rate environment and excessive liquidity.

The Group’s interest rate positions were slightly affected by

moratoriums during the year 2021, which were mostly short-

term, from 3 to 6 months, and consequently not very material.

The Group places excess liquidity mainly into banking book

securities with fixed IR, while in current negative interest rate

environment there is also higher demand for products with

fixed IR. The interest rate exposure to interest rate risk remains

modest, within the risk appetite limits. If market interest rates

would increase, the net interest income of the Group would be

positively affected, whereas ifthey decreased, negative effects

would be lower due to zero floor clauses included in a number

of loan contracts. When assessing EVE sensitivity, the Group

members apply different scenarios. For most members, the

worst-case regulatory scenario is in the case of increase of IR

by 200 bps. From the EVE perspective, the estimated capital

sensitivity of 200 bps equals -6.4% of the Group’s capital.

Robust operational risk

management

In the area of operational risk management, where the Group

has established robust operational risk culture, the main

qualitative activities refer to the reporting of loss events and

identification, assessment, and managementof operational

risks. On this basis, constant improvements of control

activities, processes, and/or organisation are performed.

Besides that, the Group also focuses on proactive mitigation,

prevention,and minimisation of potentialdamage. Special

attention is dedicated to the stress-testing system, based on

Figure75:

NLB Group’s EVE evolution

Table 33:

NPL, NPL ratio

(i)

and Coverage ratio by NLB Group members

in EUR thousands

NLB Group member

NPL

31 Dec 2021

% NPL

31 Dec 2021

NPL CR 1

31 Dec 2021

NPL CR 2

31 Dec 2021

NLB, Ljubljana130,392.11.5%75.1%60.6%

NLB Banka, Skopje59,728.34.3%101.2%64.7%

NLB Banka, Podgorica42,165.77.0%54.0%39.1%

NLB Banka, Sarajevo19,045.53.1%106.3%87.6%

NLB Banka, Prishtina15,613.71.9%243.2%91.6%

NLB Banka, Banja Luka9,371.21.3%189.3%61.0%

NLB Banka, Beograd9,489.01.5%93.4%57.6%

Komercijalna Banka, Beograd36,342.91.4%63.5%21.7%

Total NLB Group banks322,148.42.0%89.7%57.2%

Total NLB Group367,409.12.4%86.1%57.9%

(i)

By internal definition.

-3.7%

-4.8%

-5.5%

-6.1%

-6.1%

-6.4%

-7.0%

-7.1%

-7.1%

-7.2%-7.2%

-7.3%

-8.1%

-9.0%

-8.0%

-7.0%

-6.0%

-5.0%

-4.0%

-3.0%

-2.0%

-1.0%

0.0%

31 Dec

2018

31 Mar

2019

30 Jun

2019

30 Sep

2019

31 Dec

2019

31 Mar

2020

30 Jun

2020

30 Sep

2020

31 Dec

2020

31 Mar

2021

30 Jun

2021

30 Sep

2021

31 Dec

2021

![]()

104

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

a scenario analysis referring to the potential high severity,

low frequency events, and modelling data on loss events.

Furthermore, key risk indicators, servicing as an early warning

system for the broader field of operational risks (such as HR,

processes, systems, and external conditions) are regularly

monitored, analysed, and reported, with the aim to improve

the existing internal controls and enabling reacting on time.

During the COVID-19 pandemic in Slovenia and the SEE, the

Group has taken necessary measures to protect its customers

and employees by ensuring the relevant safety conditions

and making sure that the services offered by the Group are

provided without anydisruption.The Groupcontinuously

offered necessary services to clients, especially through digital

channels (mobile banking, video calls, telebanking), which

the Group continues to develop at an accelerated pace. A

crisis management team is established in the Bank and other

banking members with full engagement of the Management

Board members. Special attention was paid to continuous

provision of services to clients, their monitoring, health

protection measures, and the prevention of cyber fraud.

In addition, the Group was also diligently managing other,

non-financial risks, referring to the Group’s business model

or arising from other external circumstances, within the

established ICAAP process.

IncorporatingESG risks

The Group is engaged in contributing to sustainable

finance by incorporating ESG risks into its business

strategies, risk management framework, and internal

governance arrangements. With the adoption of the NLB

Group Sustainability programme, the Group implemented

sustainability elements into its business model. NLB Group

Sustainability Committee oversees the integration of the ESG

factors into the NLB Group business model. Thus, sustainable

finance integrates ESG criteria into Group’s business and

investment decisions for the lasting benefit of Group’s clients

and society.

ESG risks do not represent a new risk category, but rather an

aggravating factor for the existing types of risks. The Group

integrates and manages them within the established risk

management framework, namely in the area of credit and

operational risk. The management of ESG risks follows ECB

and EBA guidelines with tendency of their comprehensive

integration into all relevant processes. The availability of ESG

data in the region where the Group operates is still lacking.

Nevertheless, the Group strives to obtain relevant clients’

data as prerequisite for adequate decision-making and

corresponding proactive management of ESG risks.

In recent years, the Bank signed Framework Agreements

with the EBRD, the Contract of Guarantees with MIGA and

committed to the UN Principles of Responsible Banking.

Consequently, the Group established mechanism for

environmental and social screening of current or potential

financing applications against the MIGA and EBRD Exclusion

List and applicable environmental and social laws. The

management of ESG risks addresses the Group’s overall credit

approval process and relatedcredit portfoliomanagement.

Sustainable financing is implemented in accordance

with the Group’s ESMS. Beside addressing ESG risks in all

relevant stages of the credit-granting process relevant ESG

criteria were also considered in the collateral evaluation

process. On portfolio level the Group does not face any large

concentration towards specific NACE industrial sectors

exposed to climate risk, whereby the role of transitional risk is

more prevailing.

The Group carefully considers potential reputation and

liability risks which could arise from sustainable financing of

its clients. Special attention is given to the approval of new

products and monitoring of fulfilment of relevant criteria

by the clients. Additional key risk indicators have been

addressed, servicing as an early warning system in the area

of ESG risks. Besides, physical risks, as part of ESG risks in

the area of operational risk, are addressed in the Group’s

business continuity management (BCM). BCM is carried out to

protect lives, goods, and reputation. Business continuity plans

are prepared to be used in the event of natural disasters, IT

disasters, and the undesired effects of the environment to

mitigatetheir consequences.

As systemically important institution, the Group is included into

2022 ECB Climate Stress test exercise. Preparation activities in

the Group for the purpose of this exercise, consisting of three

modules, are already underway. By performing this exercise

ECB intends to assess how banks are prepared for dealing

with financial and economic shocks stemming from climate

risk. The exercise will be conducted in the first half of 2022

after which the ECB will publish aggregate results in July 2022.

Further information on risk management is available in the

Note

6

of the Financial part of the report,

Pillar 3

Disclosures

and

NLB Group Sustainability Report 2021

.

![]()

105

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

IT infrastructure and reliability

High performance confirmed with numbers

IT performance is monitored through a set of relevant

indicators that are linked to the Balanced Scorecard (BSC)

system. The indicators show a high performance of IT

operations and successful risk management in this area.

The availability of the information system in the Bank is at

very high level of 99.98% (2020: 99.92%), and the share of

unplanned interruptions is very low, 0.02% (2020: 0.08%). In

2021, the number of days without system/service interruptions

were at 83.6% (2020: 78.5%). Harmonised Service Level

Agreements (SLA) are in place with users of the information

system, which the Bank managed to fulfil in a very high

proportion. High IT operational performance was also

recorded in the Group members (between 99.90% and

99.99%).

MainIT initiatives

Transformation

The main focus was the transformation of IT in terms of

organisation, a group perspective, processes, people, and

technology. IT supported a more agile way of delivery, to

better partnering with business, and as a result be more

efficient and effective. It also hired new leaders and experts

especially in the areas of IT security and digital banking.

Change of delivery approach

The team managed to reach important achievements in

following new strategic directions in terms of solution delivery.

Managed to migrate first applications from mainframe to

distributed systems, selected multiple new cloud solutions

instead of on-premise, and strengthened resources in digital

and front-end delivery.

Core systems consolidation

IT followed the core banking system strategy and successfully

delivered the proof of concept for consolidated core banking

system. Based on the success of the proof of concept, the core

system consolidation project in Slovenia business entity was

initiated.

The Group continues to provide its clients

sustainable and efficient services supported

through highly reliable and secure technology

platforms. The Bank continues to actively pursue

its technology transformation programme. In

line with the refreshed IT strategy introduced

in 2020, the IT team began delivering on

outlined roadmaps and also successfully

delivered a proof of concept for a consolidated

core banking system. The Group is aiming to

centralise and unify governance, applications,

and infrastructure. The Bank also continued to

rollout an effective online collaboration solution

throughout the Group and enableda majority

of employees to work from home without

interruption to operations. Due to the general

cyber security risks increase, special focus, extra

resources, and investments were made to raise

the overall level of cyber security resilience.

Application architecture

Application architecture is focused on the Group solution

and majority of new solution selections are done as a Group

standard with related Group roadmaps. The IT team has

made significant progress in simplifying applications with the

key achievement being the retirement of the KRAT core system

for syndicatedloans.

Group-wide capabilities extended

Group-wide capabilities were significantly extended (mainly in

the Group competence centre in Belgrade, Serbia) for the new

digital bankingplatform, enterprise integrationplatform, the

business process management platform development within

the region, and the cyber security and infrastructure group.

The competence centre has 46 employees.

Data management

The Bank achieved several new milestones in the

implementation of a Group-wide data management platform

which encompasses an enterprise data warehouse, advanced

analytics, risk management analytics, profitability,data

governance, and consolidated Group regulatory reporting.

In October 2021, the NLB initiative Leveraging information

capital: Fin-tech architecture at the heart of the traditional

IT and Cyber Security

99.98%

the availabilityin NLB.

1,366,984

digital users in the Group.

![]()

106

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

bank, developed as part of the Data Management Project

of the Group, was selected as one of the top 6 finalists in

Gartner’s Eye onInnovation Awardscompetition.

Outlook

In the coming years, the Bank is expected to continue to

invest in newly adopted technologies to support the business

strategy, especially in the areas of digital, data, and customer

relationship management(CRM), consolidating the Group’s

infrastructure, simplifying core systems and to achieving

superior client experience in terms of quality, innovation,

reliability, and security.

Strengthening

the team and extra investments in

cyber

security.

16%

25%

11%

19%

10%

59%

22%

50%

NLB Banka,

Beograd

NLB Banka,

Sarajevo

NLB Banka,

Podgorica

NLB Banka,

Prishtina

NLB Banka,

Banja Luka

NLB Banka,

Skopje

Komercijalna

Banka,

Beograd

NLB

Figure 76:

Digital penetration of the Group’s banks as at 31 December 2021

Cyber security

Strengtheningteam and

implementing new solutions

The Group is giving special focus to cyber security,and

consequently assuring the confidentiality, integrity, and

the availability of data, information, and IT systems that

support banking services and products for clients. Cyber

security in the Group is constantly tested and upgraded by

security assessments, independent reviews, and penetration

testing. Cyber security is regularly discussed at the Bank’s

Information Security Steering Committee, Operational Risk

Committee, and Management Board meetings. During

2021, the Group increased its capacity in terms of human

resources by hiring specialists in different domains. The Group

now has a group team on two locations, in Ljubljana and

Belgrade. Beside increasing capacity in human resources,

improvement was made in detection capabilities by fine tuning

detection systems, as well as by performing hardening on

network devices across the Group. The threat intelligence

process was established and new IT Security strategy was

adopted focusing on unification of IT security systems and

centralisation of processes. A new Group vulnerability

management platform was selected. A technical measures

guideline, as the Group standard for tools and processes, was

also adopted and rolled out to the Group.

All employees educated, continuous

information exchange

All employees in the Group are continuously educated about

the importance of information/cyber security, as well as social

engineering techniques. The Group banks are providing

employees and customers with security notifications,

especially for the occurrence of threats in the (global)

environment with potential impact on the banks’ IT systems,

services, products, and clients. The Bank is also testing the

awareness of its employees with social engineering attack

simulations. Threat intelligence data is shared by the Group

team to all Group members with information on the latest

threats andrecommendations on mitigation measures.

Vision

Mission

Main principles

•increase client satisfaction in all segments with new

digital omnichannel platform, digitize client journeys and

interactions (CRM), and achieve operational excellence;

•have an effective IT architecture using cloud solutions

and open-source software where possible;

•introduce a new way of agile development and

DevOps transformation leading to shorter releases

cycles, automated testing, and less manual tasks;

•ensure the necessary development capacity - hire right talents

with the digital skills and looking forward to execute change;

•introduce modern collaboration tools

and digitize internal processes;

•leverage the investment made in the data platform;

•assure quality, security, and availability of

the IT systems and applications;

•have a highly motivated, effective, and satisfied IT

team working closely with the business side.

IT Strategy 2020-2024

At the end of the 2020, a refreshed IT Strategy was adopted that also incorporates the Group dimension.

Build the best digital

banking IT team in

the SEE region.

Enable the best client and

employee experiences

through reliable, effective,

secure, accessible, and

scalable ITsolutions.

![]()

We are on your team.

The first generation opened clubs.

The next generation won all the national championships.

The third generation raised regional champions.

We will help this generation reach for the stars.

Nothing connects, strengthens the bonds of cooperation or teaches how to win and lose with dignity as well as

sport

does. Especially in a region with such diversely rich sporting history. Since we believe that sport boasts an immense

power for connecting, enhancing physical and spiritual well-being and inclusion, we are proud to support top athletes

and young sports prodigies on a regional level, among those are girls from U13 football team NK Radomlje. This way,

we are becoming one of the largest sponsors of sport in the region.

![]()

108

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

EmployeeHeadcount

Number of employees reduced

The Group continued with optimisation of processes and right

sizing its staffing level. Due to the acquisition of Komercijalna

Banka, Beograd and its subsidiaries in December 2020, the

number of employees at the 2020 YE rose to 8,792 but has

downsized throughout the year to reach 8,185 at the 2021 YE.

Work from home

During the year, the COVID-19 pandemic still influenced

business operations and work was organised in a way to

minimise the risk of infections. The Group continuously

enabled employees, whose presence in the Group’s premises

was not essential to business process, to work from home

(remotely) (the Group: 32%, NLB: 47%). All decisions related

to health and safety were made on time and following the

epidemiological circumstances.

Strive to Be ‘Top Employer’

The Group is continuing to strengthen its HR practises based

on feedback from reputable institutions and benchmarks

As a market leader, the Group realises that

investing in employees is crucial. Engaged

employees contribute significantly to business

goals and results. That’s why the Group continued

with its long-lasting tradition of investing in

employee development, along with searching for

new approaches and introducing new practices

to improve organisational culture, leadership,

and employee experience. COVID-19 pandemic

impacts were felt throughout the year and

so the health and safety environment was of

the highest priority. The Group continuously

enabled the majority of non-branch employees

to work from home, and on average 32% of

employees did so. Due to the COVID-19 situation,

the development activities took place in an

online environment and remained focused on

the challenges of remote work and leadership.

Human Resources

‘Top

Employer’

for the 7

th

consecutive year.

Table 34:

NLB Group headcount by countries as at 31 December 2021 and 2020

Country31 Dec 202131 Dec 2020

Changes YoY

Slovenia

2,619

(NLB: 2,510,

other: 109)

2,691

(NLB: 2,591,

other: 100)

-72

(NLB: -81,

other: 9)

Serbia2,9013,198-297

North Macedonia

877877

0

BiH

(i)

942

1,086-144

Kosovo4634630

Montenegro

(ii)

374

467

-93

Germany110

Switzerland220

Croatia67-1

Group Total

8,1858,792-607

(i)

The sale process of Komercijalna Banka, Banja Luka was concluded in December 2021.

(ii)

The merger of NLB Banka, Podgorica and Komercijalna Banka, Podgorica was completed in November 2021.

![]()

109

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Employment – Hackathon

The strategic direction of the Bank defines employment of new

profiles needed on a Group level. As a trendsetter, the Bank

organised two NLB Hackathons (one for Data Science, and

second one for Open Finance) to recognise talents in its home

region and promote the Bank as a desirable employer.

Engagement of employees

A crucial part of success is the motivation and engagement of

employees. In 2021, a total of 72% of employees participated

in the survey.

15

Compared to the year 2020, the percentage of

engaged employees (loyal and psychologically committed to

the organisation) rose by 10% to 53%.

Figure 77:

NLB Group Employee Engagement 2021

Engaged53%

Not engaged36%

Actively disengaged11%

Preparedto Tackle

Future Challenges

Various training activities to embrace changes

The Group strives for high quality and standards of a

modern learning organisation. Due to the rapidly changing

environment, the Group expanded its offer of trainings with

access to future skills topics, made training more accessible

and on demand, while also still offering classical channels of

training and workshops.

Trainings, e-learning

Due to COVID-19, most of the trainings were conducted online.

The emphasis of online programmes was focused on various

topics from the Banking & Financial area, Leadership &

Management, Sales, IT, to Personal Development, Compliance

and the Work Environment, and ESG & Social Responsibility.

Along with these areas, the Group also made substantial

investment in training employees in Data Analytics & Science

across the Group.

Online learning with access to 7,000+ courses

On 1 March, the Group enabled employees’ access to the

online learning platform Udemy for Business. The aim was to

empower employees over their own development and give

them opportunities to upskill or reskill, and be better prepared

for upcoming challenges.

15NLB Banka, Beograd and Podgorica were exempt from the survey due to the

integration activitieswith KomercijalnaBanka.

with best-in-class HR practises. The Bank was once again

recognised as a ‘Top Employer’ by the Dutch Top Employer

Institute for the 7

th

consecutive year, demonstrating a high

level of expertise and contribution in the areas from people

strategy, leadership, digitalization,talent acquisition and

development, performance management, sustainability,and

a lot more. The Bank will continue ensuring an even more

stimulating work environment in the future.

Continuing a longstanding

tradition of investing

in employees

Organisational culture

Organisational culture is an important driving force of

company development and success, that’s why the Group has

decided to take an active and comprehensive approach to

develop it. Measurement of the organisational culture gave a

roadmap on how to grow and further enhance constructive

organisational styles. This includes involving employees

from all backgrounds, areas, and levels in focus groups, and

provides in-depth insights on the actions that need to be taken

to ensure even higher engagement and success in the areas

of leadership, employee empowerment, and interpersonal

cooperation.

Leadership development

Significant influence on employee satisfaction derives from

their working environment, and leaders on all levels have

a significant role in creating a productive atmosphere. The

Group is actively developing leadership competencies of

senior management to align with the activities of changing

organisational culture. Ensuring the succession for

managerial positions is also of key importance throughout the

Group and one of the strategic activities.

Developing talent

Among its employees, the Group identified talents in the

fields of leadership, professional, and young talents. They

are provided additional opportunities, knowledge, and skills

needed to manage and lead in challenges of the future, as

wellas individual development activities.

Developing NLB Employer Brand

To attract toptalent throughout theregion, theGroup has

identified the need to develop the Employer Brand actively.

The Group has done internal and external surveys, interviews,

and multiple focus groups to identify the relevant employer

value proposition.

In first 10 months, the most often enrolled courses were from

areas of IT Development, Data Analytics & Science, Office

Productivity and Personal Development.

Well-being &Health

Creating a work environment

The Group is always committed to offering knowledge on

good health, creating a work environment that enables quality

interpersonalrelationships, and promotingactivities that

enhance the good health and satisfaction of employees.

Promoting healthy habits and new

health and safety measures

During the pandemic, emphasis was placed on developing

healthy habits. Health trainings were organised to help

employees cope with mental side of new reality and

emphasise benefits of regular physical activity.

The Group continued to make sure that prescribed protective

measures are followed and equipment (masks, gloves, and

disinfectants) was available to employees and clients. It also

encouraged working from home.

On average

32%

of the Group's employees

worked from home in the period

of pandemic.

![]()

110

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Remuneration policy for members

of the Supervisory Board and

Management Board of NLB

Members of the Supervisory Board may receive remuneration

that iscompliantwith the relevant resolutions of theBank’s

General Meeting.

Members of the Management Board receive remuneration

consisting of a fixed part of the salary and a variable part of

the salary. The variable part of remuneration is allocated and

paid in the form of cash and/or instruments.

Remuneration policy for employees

in NLB and in the Group

In 2021, a refreshed Remuneration Policy for employees in

NLB and in the Group was adopted where the basic principles

represent the framework for rewarding employees in NLB and

the Group. The remuneration policy defines fixed and variable

remuneration, the goal-setting system and performance

criteria (KPIs), and sets out the conditions for the allocation

and payment of the variable part of remuneration.

Diversity Policy

Framework

The policy sets the framework in the area of diversity and representation of both genders in the Supervisory Board and

Management Board and the senior management. With the policy, the Bank also sets the framework for diversity with regards to

education, range of knowledge, skills and experience, age,gender, and international experience.

Objectives

•Cover an adequately wide range of knowledge, skills, and expert experience of its members, and be composed with regard to the

following criteria: experience, reputation, management of any conflicts of interest, independence, available time, and collective

suitability of the body as a whole.

•

International experience of its members in different areas.

•

Diversity as regards gender representation.

•Diversity as regards the age structure, which should reflect the age structure in the Bank to the largest extent possible.

The goals of the Policy shall also be reasonably applied to the provision of diversity of the wider management.

Table 35:

Diversity - review of management bodies and senior management in 2021 and plan for 2022

Supervisory Board of NLBManagement Board of NLBSenior Management of NLB

2021Plan for 20222021Plan for 20222021Plan for 2022

Wide range of knowledge, skills

and professional experience

HighHighHighHighHighHigh

International experience of the

members in different areas

HighHighHighHighMedium HighMedium High

Age structure

20-30 = 0020-30 = 0020-30 = 11

30-40 = 0030-40 = 0030-40 = 55

40-50 = 1140-50 = 3540-50 = 1919

50-60 = 8650-60 = 0150-60 = 1313

60+ = 3560+ = 0060+ = 00

Share of women42%42%0%16.7%45%45%

Remuneration system as a motivation for

engagedand committed employees

For an employee working in the companies within the Group, salary is composed of:

Fixed part

Determined according to the complexity of the work for which the

employee has concluded a contract of employment.

Variable part

Depends on the employee’s performance for reaching set goals.

Empoyees are awarded:

1.quarterly or half-yearly compensation and

2.annual rewards related to the business performance of the bank in which they work.

Performance assessment is done by the head of the employee’s organisational unit using a top-

down approach to evaluate the employee’s achievements in relation to goals set for a particular

assessment period (quarter or half-year). The goals are set according to the ‘SMART’ method,

meaning that they have to be specific, measurable, achievable, relevant, and time-bound.

8,185

employees in the Group family.

![]()

111

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Rules andProcedures

Corporate governance of the Bank includes the processes

through which Bank objectives are set and pursued (directed

and controlled), and lately it is becoming an efficient way to

channel investor-driven initiatives relatedto sustainability.

Corporate governance with its principles identifies the

distribution of rights and responsibilities among different

stakeholders in the Bank (Management and Supervisory

Board, shareholders, creditors, auditors, regulators, and

otherstakeholders), and include the rules and procedures for

making decisions in corporate affairs. The most important

rules and procedures are:

Articles of Association of NLB

In accordance with the applicable Banking Act (ZBan-3) and

Companies Act (ZGD-1), the Articles of Association of NLB the

Bank has a two-tier governance system, according to which

the Bank is managed by the Management Board and its

operations are supervised by the Supervisory Board (

https://

www

.

nlb

.

si/corporate-governance

),while shareholders

exercise their rights on meetings of shareholders.

Corporate Governance Statement of NLB

Apart from the binding legal framework, the Bank also follows

the Corporate Governance Code for Listed Companies (valid

since 1 January 2017). The Code defines the governance,

management, and leadership principles based on the ‘comply

or explain’ principle of companies listed on the Slovenian

regulated market (

https://www

.

ljse

.

si

). Deviations from the

recommendations of the mentioned code are published in the

Corporate Governance Statement of NLB, which is adopted

by the NLB Supervisory Board. The mentioned statement

is prepared according to Article 70 (paragraph 5) of the

Companies Act (ZGD-1) and is part of the Business Report in

the NLB Group Annual Report. The mentioned statement is

also published on the Bank’s webpage (

https://www

.

nlb

.si/

corporate-governance

), as well as on the webpage of the

Ljubljana Stock Exchange – SEOnet (

https://

seonet

.

ljse

.

si

).

Corporate Governance Policy of the NLB and

NLB Group Corporate Governance Policy

The corporate governance framework of the Bank, being

the Corporate Governance Policy of NLB (November 2020),

Corporate governance of the Bank is based

on legislation of the RoS, particularly (but not

exclusively) the provisions of the changed

Companies Act (ZGD-1) and the Banking Act

(ZBan-3), the Decision of the BoS on Internal

Governance, the Management Body and

the Adequate Internal Capital Assessment

Procedure for Banks and Savings Banks, the

relevant EBA Guidelines on internal governance,

the EBA Guidelines on the assessment of the

suitability of members of the management

body and key function holders, the EBA

Guidelines on remuneration practices, and

the EU regulations regarding ESG.

is designed jointly by the Management Board and the

Supervisory Board of the Bank. Therein are publicly disclosed

commitments to shareholders, clients, creditors, employees,

and other stakeholders as a whole, how the Bank will be

supervised and managed, as well as decision which corporate

governance code the Bank should follow (

https://www

.

nlb

.si/

corporate-governance

). The Corporate Governance Policy of

NLB should be read together with the NLB Group Corporate

Governance Policy in which the corporate governance

principles and mechanisms of the Group members (NLB

excluded) are defined and governed.

NLB Group Code of Conduct

In the NLB Group Code of Conduct (Code), values, mission,

and core principles of conduct are defined together with

set guidelines to which the Group is committed. The Code

describes the values and the basic principles of ethical

business conduct that the Group respects, promotes, and

expects to be followed in the whole Group (

https://www

.

nlb

.si/

code-of-conduct

). Operating with integrity and responsibility

is a key element of the Group’s corporate culture. It is

important to achieve business goals as well as the way to

achieve them. The Group demands that every employee,

regardless of their job or location of work and every other

stakeholder of the Group, complies with the highest standards

of integrity. The key for achieving these standards is strong

culture of compliance practiced by the Group.

Remuneration Policy for the members

of the Supervisory Board and

Management Board of NLB

In accordance with the fifth paragraph of Article 294a of the

Companies Act, the Bank publicly posted on its website the

Remuneration Policy for the Members of the Supervisory

Board of NLB and the Members of the Management Board

of NLB (version 1), which was adopted by the Supervisory

Board of NLB on 15 October 2021 and approved by the

General Meeting of Shareholders of NLB on its session on 16

December 2021 (

https://www

.

nlb

.

si/corporate-governance

).

The resolution was legitimately passed with the necessary

majority of the votes cast.

Corporate Governance

![]()

112

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

During the year, the Bank also gradually built mechanisms to

assure very important and comprehensive steps in integrating

sustainability into banking operations, the so-called ESMS.

The ESMS is a set of policies, procedures, tools, and internal

capacity to identify and manage a financial institution’s

exposure to the environmental and social risks of its clients/

investees. Significant changes in the lending process of the

Group are one of the most important consequences of the

introduction of the ESMS. The risk policies were upgraded to

follow ECB and EBA guidelines.

The Bank anchored ESMS at different levels within the Bank

and theGroup thusguaranteeing that itreceives attention

from the highest decision-making bodies in the Bank

and in the Group members. With the establishment of the

Sustainability Committee in the fall of 2021, which is a new

advisory Body to the Management Board, the Bank built a

4-level NLB Group Sustainability Governance Structure, as

follows:

More information is available on

https://www

.

nlb

.si/

nlb-sustainability

-framework

.

pdf

and in this report, in

Sustainability

chapter.

Supervisory

Board of the NLB

Sustainability

Team

Sustainability

Committee

Sustainability

working groups

Policy on the Provision of Diversity of the

Management Body and Senior Management

Policy on the Provision of Diversity of the Management Body

and Senior Management regarding selection of members

of the Supervisory Board, the Management Board and B-1

level was confirmed on General Meeting of Shareholders on

10 June 2019. With mentioned policy the Bank follows high

standards of adequate representation of both sexes in the

managing bodies.

In 2020 and January 2021, the Workers’ Council of NLB elected

and appointed employee representatives as members

of the Supervisory Board of NLB, thus four employee

representatives were appointed. As part of employee

participation in theBank’smanagement, the appointment of

four representatives brings additional diversity at all levels,

including the achievement of gender quotas in the Bank’s

governing bodies, and employees’ representatives with their

diverse work experience will be able to contribute to better

employee involvement in governing bodies. The Supervisory

Board yearly follows the implementation of the goals set by

mentioned policy.

NLB Group Sustainability Governance Structure

NLB became the first bank in Slovenia to commit to the UN

Principles for Responsible Banking (September 2020). These

principles represent a single framework for a sustainable

banking industry and are aligned with the 2015 Paris Climate

Agreement and with the objectives of the

UN Sustainable

Development Goals

(UN SDGs) that cover three dimensions

of sustainability: economic, social, and environmental.

In that respect, the Bank upgraded the Corporate Social

Responsibility (CSR) activities with more consistent adherence

to the 2030 Agenda of the UN SDGs.

In 2021, however, the Group moved from raising awareness

to actively implementing sustainability elements into the

business model and established sustainable operations in

the Framework for Sustainable Operations of the NLB Group

(

https://www

.

nlb

.

si/sustainability

). The framework defines the

Bank’s corporate sustainability strategy, vision and mission,

commitment to the UN SDG, sustainable economic activities,

ESG risk management, sustainability governance structure,

responsible banking, and business ethics.

ESG factors and indirect economic factors are

comprehensively recognised and managed according to

GRI (Global Reporting Initiative – Global Standards (GRI GS))

standards. Key ESG information is published in the following

chapters of this report or other related webpages:

Environment (E):

- In

Sustainability

chapter

- In separately published

NLB Group

Sustainability Report

2021

published on the Bank’s webpage

- the chapter

Risk Management

, subchapter

Incorporating

ESG Risks

- the chapter

Statement of Management of Risk

in

Note 6

of the Financial part of the report

Social (S):

- In

Human Resources

chapter

- In the diversity and remuneration chapters in a separate

report on

Pillar 3

Disclosures

according to Basel Standards

Governance(G):

- In this chapter of report

- In the

Corporate Governance Statement of NLB

of this

report and on the Bank’s webpage

https://www

.

nlb

.si/

corporate-governance

and on the webpage of the Ljubljana

Stock Exchange

https://seonet

.

ljse

.

si

![]()

113

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

There were two General Meetings of Shareholders in 2021.

Theshareholders of the Bank gathered on 36

th

General

Meeting on 14 June. Due to COVID-19 pandemic, for the first

time the General Meeting was hybrid, as it was held live and

online. The shareholders took note of the approved NLB

Group Annual Report 2020, the Report of the Supervisory

Board of NLB on the results of the examination of the NLB

Group Annual Report 2020, and Information on the income

ofmembers of the Management Board and Supervisory

Board of the Bank for the previous business year.

The shareholders decided on the allocation of distributable

profit for 2020. The distributable profit of the Bank as at 31

December 2020 was EUR 341,992,219.43.

The General Meeting of NLB granted discharge to the

members of the management and supervisory bodies for the

2020 financial year, adopted amendments and supplements

to the Articles of Association, and appointed Islam Osama

Zekry as a new member of the Supervisory Board.

At the 37

th

General Meeting of Shareholders that was

summoned for 16 December 2021, the shareholders decided

on additional allocation of distributable profit for 2020.

The Bank paid out in three instalments a total of EUR 92.2

million of dividends to the shareholders in 2021.

At the General Meeting, the shareholders also voted on

theRemuneration Policy for the Members of the Supervisory

Board of NLBand the Members of the Management Board

ofNLB.

More information on the work of the General Meeting of the

Shareholders activities is availablein

CorporateGovernance

Statement of NLB

.

Bank’sGoverningBodies

The Bank’s corporate governance is based on a two-tier

system in which the Management Board manages the Bank,

while its daily operations are supervised by the Supervisory

Board.

General Meeting of Shareholders

Supervisory Board

Management Board

General Meeting ofShareholders

The shareholders exercise their rights related

to the Bank’s operations at General Meetings.

The Bank’s General Meeting passes decisions in

accordance with the legislation and the Bank’s

Articles of Association. Decisions adopted by the

General Meeting include, among others: adopt

and amend the Articles of Association, use of

distributable profit, grant a discharge from liability

to the Management and Supervisory Board,

changes to the Bank’s share capital, appoint and

discharge members of the Supervisory Board,

remuneration of members of the Supervisory and

Management Board and authorisation regarding

the characteristics of issues of securities.

The Supervisory Board

The Supervisory Board supervises the

management of the Bank and its duty of diligent

and prudent conduct in line with powers defined

in Companies Act (ZGD-1) and according to

provisions of the Banking act (ZBan-3), other

regulations, and internal rules of the Bank (the

Articles of Association of NLB and Rules of

Procedures of the Supervisory Board of NLB).

In accordance with Articles of Association the

Supervisory Board consists of 12 members, of

which eight members represent the interests

of shareholders, and four members represent

the interests of employees. Members of the

Supervisory Board of the Bank representing the

interests of shareholders are elected and recalled

by the Bank’s General Meeting from persons

proposed by shareholders or the Supervisory

Board of the Bank. Members of the Supervisory

Board of the Bank representing the interests

of employees are elected and recalled by the

Workers’ Council of the Bank. All Supervisory

Board members must be independent experts.

12 (8 are

representatives of

capital, while 4 are

representatives of

workers)

In SB 5 out of 12

members arefemale

(41.67%)

Number of members:Diversity:

There were two changes in the composition of the Supervisory

Board in 2021. The Workers Council of the Bank elected

Tadeja Žbontar Rems as a member of the Supervisory Board

(representative of workers). Her term of office runs from

22 January 2021. Islam Osama Zekry was elected as a new

member of the Supervisory Board on the General Meeting of

Shareholders on 14 June 2021.

![]()

114

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Representatives of capital

Primož Karpe, M.Sc.

Chairman

Term of office:

2016-2020,

renewed term 2020-2024

Andreas Klingen

Deputy Chairman

Term of office:

2015-2019,

renewed term 2019-2023

Link to CVLink to CV

Membership in NLB

Supervisory Board

committees:

•Nomination Committee

(Chairman)

•Audit Committee (Member)

•Operations and IT

Committee (Member)

Membership in NLB

Supervisory Board

committees:

•Nomination Committee

(Deputy Chairman)

•Risk Committee (Chairman)

•Operations and IT

Committee (Member)

Membership in management

bodies of related or

unrelated companies:

•Angler d.o.o. - Director

Membership in management

bodies of related or

unrelated companies:

•Credit Bank of Moscow

- Member of the

Supervisory Board

(i)

•Kyrgyz Investment and

Credit Bank CISC - Member

of the Board of Directors

•Nepi Rockcastle

plc - Member of the

Board of Directors

(i)Till 14 March 2022.

David Eric Simon

Member

Term of office:

2016-2020,

renewed term

2020-2024

Islam Osama Zekry, Ph.D.

Member

Term of office:

2021-2025

Link to CVLink to CV

Membership in NLB

Supervisory Board

committees:

•Audit Committee

(Chairman)

•Risk Committee (Member)

Membership in management

bodies of related or

unrelated companies:

•Jihlavan a.s. - Chairman

of the Supervisory Board

•Czech Aerospace industries

sro - Legal representative

•Central Europe Industry

Partners a.s. - Sole Member

of the Supervisory Board

Membership in NLB

Supervisory Board

committees:

•Operations and IT

Committee (Deputy

Chairman)

•Risk Committee (Member)

Membership in management

bodies of related or

unrelated companies:

•CIB Housing association,

Egypt - President of the

Supervisory Board

•Egyptian AI Council

(Ministry of Communication

and Information

Technology) – Member of

the Supervisory Board

Shrenik Dhirajlal

Davda, M.Sc.

Member

Term of office:

2019-2023

Mark William Lane

Richards, M.Sc.

Member

Term of office:

2019-2023

Link to CVLink to CV

Membership in NLB

Supervisory Board

committees:

•Risk Committee

(Deputy Chairman)

•Remuneration

Committee (Member)

•Audit Committee

(Deputy Chairman)

Membership in NLB

Supervisory Board

committees:

•Operations and IT

Committee (Chairman)

•Remuneration Committee

(Deputy Chairman)

•Risk Committee (Member)

Membership in management

bodies of related or

unrelated companies:

•Vencap International pic

Ukraine (UK) - Director

•BPL Global (Lloyds of

London insurance Broker)

- Non-Executive Director

•Sheffield Haworth Ltd -

Non-Executive Director

Membership in management

bodies of related or

unrelated companies

(i)

:

•PJSC Ukrgasbank -

Independent Member of

the Supervisory Board

(i)Since 8 March 2022 also: IPSO,

UK - Lay Member of the Board.

Gregor Rok Kastelic

Member

Term of office:

2019-2023

Verica Trstenjak, Ph.D.

Member

Term of office:

2020–2024

Link to CVLink to CV

Membership in NLB

Supervisory Board

committees:

•Remuneration Committee

(Chairman)

•Audit Committee (Member)

•Risk Committee (Member)

Membership in NLB

Supervisory Board

committees:

•Nomination Committee

(Member)

Membership in management

bodies of related or

unrelated companies:

•European Union

Agency for fundamental

rights – Member of the

Management Board

Membership in management

bodies of related or

unrelated companies:

•None

Representative of employees

Bojana Šteblaj, M.Sc.

Member

Term of office:

2020–2024

Sergeja Kočar, M.Sc.

Member

Term of office:

2020–2024

Link to CVLink to CV

Membership in NLB

Supervisory Board

committees:

•Nomination Committee

(Member)

•Remuneration

Committee (Member)

Membership in NLB

Supervisory Board

committees:

•Nomination Committee

(Member)

•Remuneration

Committee (Member)

Membership in management

bodies of related or

unrelated companies:

•None

Membership in management

bodies of related or

unrelated companies:

•None

Janja Žabjek Dolinšek, M.Sc.

Member

Term of office:

2020–2024

Tadeja Žbontar Rems, M.Sc.

Member

Term of office:

2020–2024

Link to CVLink to CV

Membership in NLB

Supervisory Board

committees:

•Operations and IT

Committee (Member)

Membership in NLB

Supervisory Board

committees:

•Operations and IT

Committee (Member)

Membership in management

bodies of related or

unrelated companies:

•None

Membership in management

bodies of related or

unrelated companies:

•None

Further information about the work and composition of the

Supervisory Board is available in the chapter

Corporate

Governance Statement of NLB

.

At 31 December 2021, the Supervisory Board had the following members:

![]()

115

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Audit CommitteeRisk CommitteeNomination

Committee

Remuneration

Committee

Operations and

Information

Technology (IT)

Committee

Committees of the Supervisory Board

The Supervisory Board appoints committees that

prepare proposals for resolutions passed by the

Supervisory Board, ensures their implementation,

and performs other expert tasks. The Bank’s

Supervisory Board has five collective decision-

making and advisory committees, namely:

Further information about the work and composition of the

Committees of the Supervisory Board is available in the

chapter

Corporate Governance Statement of NLB

.

David Eric

Simon

,

Chairman

Shrenik

Dhirajlal

Davda

,

Deputy

Chairman

Primož Karpe

,

Member

Gregor Rok

Kastelic

,

Member

Andreas

Klingen

,

Chairman

Shrenik

Dhirajlal

Davda

,

Deputy

Chairman

Islam Osama

Zekry

,

Member

Mark William

Lane Richards

,

Member

David Eric

Simon

,

Member

Gregor Rok

Kastelic

,

Member

Primož Karpe

,

Chairman

Gregor Rok

Kastelic

,

Chairman

Mark William

Lane Richards

,

Chairman

Andreas

Klingen

,

Deputy

Chairman

Mark William

Lane Richards

,

Deputy

Chairman

Islam Osama

Zekry

,

Deputy

Chairman

Verica

Trstenjak

,

Member

Shrenik

Dhirajlal Davda

,

Member

Andreas

Klingen

,

Member

Bojana Šteblaj

,

Member

Sergeja Kočar

,

Member

Bojana Šteblaj

,

Member

Sergeja Kočar

,

Member

Primož Karpe

,

Member

Janja

Žabjek

Dolinšek

,

Member

Tadeja

Žbontar Rems

,

Member

Audit CommitteeRisk CommitteeNomination

Committee

Remuneration

Committee

Operations and

Information

Technology (IT)

Committee

![]()

116

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

The Management Board

The Management Board represents the Bank

and manages its daily operations, independently

and at its own discretion, as provided for by the

applicable laws and the Articles of Association

of NLB. In accordance with the Articles of

Association, the Management Board has three

to seven members (the president and up to six

members) which are appointed and dismissed

by the Supervisory Board. The president

and members of the Management Board are

appointed for a five-year term of office and may

be reappointed or dismissed early in accordance

with the law and Articles of Association.

three members

five-yearterm

of office

Number of members:Mandate:

The Supervisory Board of NLB and, member of the

Management Board and Chief Operating Officer (COO) Petr

Brunclík, agreed on the termination of office with effect on

30 June 2021. The decision was brought about by personal

reasons. As of 22 April 2021, his tasks were taken over by other

members of the NLB’s Management Board.

Further information about the work and composition of the

Management Board is available in the chapter

Corporate

Governance Statement of NLB

.

At the end of 2021, the composition of the Management Board was as follows

16

:

16Further information is available in the chapter

Events After the End of the 2021

Financial Year

.

Blaž Brodnjak

CEO & CMO

Term of office: 2016-2021,

renewed term 2021-2026

Andreas Burkhardt

CRO

Term of office: 2016-2021,

renewed term 2021-2026

Archibald Kremser

CFO

Term of office: 2016-2021,

renewed term 2021-2026

Link to CVLink to CVLink to CV

Other important functions

and achievements:

•More than 21 years of experience at

managerial positions on all levels

of international banking groups.

•Was a chairman or member

of the supervisory boards of 13

commercial banks in six countries,

three insurance companies in

three countries, leading asset

management company in Slovenia

and multinational production group.

Other important functions

and achievements:

•20 years of experience in the

area of banking, especially in

the area of Central Europe.

Other important functions

and achievements:

•More than 21 years of experience

in the financial services

industry in Austria, CEE, and

SEE focusing on finance and

asset management, strategy,

and corporate development,

as well as performance

improvement assignments.

Direct responsibility:

•Strategy and Business Development

•Legal and Secretariat

•Communication

•HR and Organisation Development

•Investment Banking and Custody

•Retail and Private Banking,

Corporate Banking

•Payment Processing

•Cash Processing

Direct responsibility:

•Internal Audit

•Compliance and Integrity

•Global Risk and Credit Risk

– Corporate and Retail

•Workout and Legal Support

•Restructuring

•Evaluation and Control

•Financial Instruments Processing

•Corporate Customer Delivery

•Retail Banking Processing

Direct responsibility:

•Financial Accounting

•Controlling

•Financial Markets

•Group Real Estate Management

•Group Steering

•IT Architecture

•IT Delivery

•Data Management

•IT Shared Service Centre

•NLB Group IT Security

Governance

•IT Infrastructure

•Procurement

Membership in management or

supervisory bodies of related

or unrelated companies:

•Chairman of the Supervisory Board:

NLB Banka, Skopje

•Chairman of the Board of Directors:

NLB Banka, Prishtina

•Member of the Board of Directors:

Komercijalna Banka, Beograd

•President of the Association

of Banks in Slovenia

•President of the Board of

Governors: AmCham Slovenia

•Member of Executive Committee of

the Handball Federation of Slovenia

•Member of the Board of Directors:

Cedevita Olimpija (from

1 February 2022)

Membership in management or

supervisory bodies of related

or unrelated companies:

•Chairman of the Board of Directors:

NLB Lease&Go

NLB Bank, Banja Luka

NLB Bank, Sarajevo

Membership in management or

supervisory bodies of related

or unrelated companies:

•Chairman of the Board of

Directors:

NLB Banka, Podgorica

Komercijalna Banka, Beograd

![]()

117

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

The Management Board also appointed working bodies that operate at a lower level:

Committee for New and Existing

Products

Group Real Estate Management

Sub Committee

Committee for Business IT

Architecture

Data Management CommitteeAnti - Money Laundering

Commission

Corporate Customer Acceptability

Committee

Advisorybodies of the Bank’s Management Board

The Watch List CommitteeThe Risk CommitteeNLB Group Non-Performing Assets Divestment

Committee

NLB Group Sustainability Committee

Chairman: CROChairman: CROChairman: Director of Workout and Legal SupportChairman: CEO

Number of members: 7Number of members: 12Number of members: 7Number of members: 17

The Watch List Committee is a body which monitors

the progress of activities for clients on the Watch list. As

a rule, committee meetings are convened quarterly.

The Risk Committee monitors and periodically

reviews matters related to risk and commercial

risk and prepares materials for the Management

Board to obtain decisions. As a rule, committee

meetings are convened quarterly.

The NLB Group Non-Performing Assets Divestment

Committee monitors operations of Non-Core Group

Members and issues opinions, recommendations,

and initiatives. The Committee shall discuss

the strategies regarding optimal management

of the Group members and shall monitor

realisation of their strategic objectives. As a rule,

committee meetings are convened quarterly.

Committee oversees the integration of the ESG

factors to the NLB Group business model in a

focused and coordinated way across the company

and issues opinions, recommendations, initiatives

and takes relevant decisions when needed. As a

rule, committee meetings are convened quarterly.

Collective decision-making bodies

Different committees, commissions, boards, and working bodies may be appointed by the Management Board for execution of individual tasks within powers of the Management Board.

Corporate Credit CommitteeAssets and Liabilities

Management Committee

of the NLB Group

NLB Operational Risk

Committee

The Change the Bank

Committee

The Group Real Estate

Management Committee

The Sales CommitteePrivate Individual Credit

Committee

Chairman: CROChairman: CFOChairman: CROChairman: CEOChairman: CFOChairman: Executive

Assistant to MB for CIB area

Chairman: Director of

Credit Risk – Retail

Number of members: 8Number of members:

equal to the number of the

appointed members of

the Management Board

Number of members: 16Number of members:

equal to the number of the

appointed members of

the Management Board

Number of members: 3Number of members: 13Number of members: 5

The Committee determines

credit ratings and makes

decisions on the reclassification

of clients and approves

commercial banking investment

transactions and limits that are

beyond the competencies of

the directors. The Committee

adopts decisions on investment

transactions in commercial

banking within the statutory

powers in the areas of corporate

banking in the Bank (all

companies, banks, and financial

institutions), operations with

clients in intensive care, and NPL.

As a rule, committee meetings

are convened once a week.

The Committee

monitors conditions in

the macroeconomic

environment and analyses

the balance, changes to

and trends in the assets

and liabilities of the Bank

and the Group companies,

drafts resolutions and

issues guidelines for

achieving the structure of

the Bank’s and the Group’s

balance sheet. Committee

meetings are generally

convened once amonth.

The Committee

is responsible for

monitoring, guiding, and

supervising operational

risk management in the

Bank, and for transferring

this methodology to the

Group members. As a

rule, the Committee meets

once every two months.

The Committee is

responsible for adopting

decisions related to the

development portfolio with

the aim of transforming

the Bank and decisions

related to adopting the

development guidelines.

As a rule, the Committee

meetings are convened

once a month.

The Committee is in

charge of giving opinions

on acquisition/purchase

price of real property and

additional investments

in real property provided

as collateral for NPL,

the selling price of own

real property, and the

acquisition/purchase

price for the real property

mortgaged in the sale

of receivables. As a rule,

Committee meetings are

convened once a week.

The Sales Committee

adopts decisions on

the management of the

range of products and

services and the relations

with the clients in the

area of sales. As a rule,

Committee meetings are

convened once a week.

The Committee decides

on the approval of loans

and other investment

proposals, the conditions

of which deviate from

standard banking products

and services, and which

represent additional risks

for the Bank. As a rule,

meetings are convened

when necessary.

![]()

118

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

NLB Group’s Corporate

Governance

As the parent bank, NLB implements the

corporate governance of the Group members

in compliance with EU and BoS legislation, the

local legislation, and regulatory requirements

applicable to respective Group members,

while also considering internal rules, ECB

Guidelines, and other applicable regulations.

The roles, authorisations, and responsibilities of individual

bodies and organisational units, as well as the manner to

coordinate their operations to achieve the set business

goals, are stipulated comprehensively in the NLB Group

Corporate Governance Policy. In the Bank, the Group

Steering Department is the principal partner of the Bank’s

Management Board in the governance of strategic and non-

strategic Group companies, and is responsible for appropriate

corporate governance, the alignment of strategies, and the

objectives achieved by subsidiaries.

In recent years, the concept of corporate governance of the

Group has been upgraded, and the role of members of the

Management Board of the Bank in management of other

Group members strengthened. The target composition of

supervisory bodies in the Group members was established,

the functioning of the supervisory bodies optimised, and

the reporting and standards related to the harmonisation of

operations simplified.

In line with strategic aspirations, the concept of ‘country

managers’ was fully introduced with the main goal to support

and steer the Group members, as well as to be a strong link

between Group members and the Bank. They also facilitate

best practice sharing on different levels. Stream coordinators

were introduced to address the facilitation of more in-depth

knowledge of competence lines and greater integration

between streams and the Group members, the increasing

transmission of current information, needs, and other

requirements from the Group members, and exploitation of

synergies at the Group level and coordination of regional

projects.

Legal and organisational structure of the banking

group, including a description of the internal

governance arrangements, the arrangements with

regard to close links and the arrangements regarding

the governance of subsidiaries are available on the

Bank’s webpage (

http://www

.

nlbgroup

.

si/profile

).

The Group is governed:

In accordance with fundamental corporate rules

through various bodies of the Group members:

•By voting at general meetings of the Group members

•By exercising supervision through the supervisory bodies of

the Group members

•With proposals for appointing the management of the

Group members

•With proposals for appointing representatives of the Bank to

supervisory bodies

•

Through participation of Bank’s representativesin various

committees and commissions of the Group members

Through mechanisms that ensure efficient

business monitoring and governance, such as:

•Harmonisation of operations in accordance with the so-

called ‘competence line principle’

•NLB Group Management Board Meetings, NLB Group

Leadership meetings, NLB Group ALCO meetings, etc.

•

Development activities carried out via cross-functional

working groups, group projects, competence centres,

centres of excellence, etc.

•Through additional supervision of NLB Group members

carried out by control functions (risk management, internal

audit, compliance, AML, information, and physical security)

and external supervising authorities (ECB, local regulators,

external auditors).

![]()

119

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

A culture of compliance is integrated into the day-to day

business of the Bank to support its operations, to contribute

to its strong internal control environment, and to ensure that

compliance risks are mitigated.

Group-wide ethics and

integritystandards

Within the framework of the programme of ensuring business

compliance, the Group also deals with the ethics and integrity

The Group addresses the challenges of high

regulation and strict regulatory requirements

with a systematic approach to mitigating

compliance risks. It is important to ensure

that employees and decision-makers

know and understand the purpose and

objectives of the regulations. The Group is

continuously strengthening the compliance

function and diligence of its operations.

of the organisation. For that reason, all of the employees are

included in yearly training and awareness-raising activities

in the areas of general ethics, anticorruption, anti-money

laundering, information security, etc. The values of the Group,

embedded in the Group Code of Conduct, provide guidance

and principles of expected behaviour regarding ethical

conduct and require appropriate conduct from all employees

at any level of the organisation, including its contractors.

The regime on inside

information (MAR)

In line with the Market Abuse Regulation (MAR), and other

relevant regulations, the Bank has a system in place on the

level of the Bank and its entire Group for managing and

publicly disclosing inside information in a manner that enables

it to comply with the obligations related to inside information

identification and disclosure in accordance with the rules and

regulations applicable at any time. Also, the Bank has a system

in place implementing the market abuse prevention regime

in accordance with MAR to prevent insider trading, market

manipulation, and illegal disclosure of inside information.

Compliance and Integrity

The Compliance

and Integrity in the

Bank addresses the

following risk areas:

Fraud prevention

and investigation

AML/CTF

Privacy data

protection and

information security

Regulatory compliance

Corruption prevention

Fit and proper

assessment

procedures (as part of

assessing reputation,

financial strength,

time availability, and

conflict of interests)

Conflict of interests,

gifts and hospitality

management

Identification,

assessment, and

management of

compliance, and

integrity risks at the

Bank and the

Group levels

Oversight,

monitoring, steering,

and managing the

Group compliance

function and

programme

(i)

Business ethics and

corporate integrity

Physical / technical

security

(i)

Established by standards for compliance and integrity for the Group and implementation of monitoring by off-site data analysis and onsite visits.

537

new laws, draft laws, regulations,

and other information regarding

regulatory environment of the

Bankreviewed.

![]()

120

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Information security and

personal dataprotection

The information security area, inter alia, focused on

implementation of measures for increasing the level of

information/cyber security, as well testing the cyber security

resilience of information systems (pen-tests).

Furthermore, in line with the plan, several internal

assessments/compliance checks according to ISO/IEC 27001

standard were carried out in 2021, including assessment

of information security at outsourcing providers. Special

obligatory e-trainings for all employees in the area of

information security and social engineering were prepared

and executed all as part of prevention measures in this area.

The Bank runs its operations in line with GDPR requirements,

including the retention and processing of personal data, dedicated

Data Privacy Officer, education, and training of employees. The

new Slovenian Personal Data Protection Act (ZVOP-2) was not

adopted in 2021 as expected. If necessary, further alignments will

be made when the national legislation is in place.

Prevention

Based on the assessment of compliance risks (so-called ECRA

– Enterprise Compliance Risk Assessment) the management of

the Bank and in particular Compliance and Integrity can plan its

activities; all with the aim to reduce or mitigate the compliance

and integrity risks. As part of compliance programme,

Compliance and Integrity is also involved, inter alia, in risk

assessments regarding new and changed products, fit and

proper assessments for key function holders, outsourcing, and

other changes materially affecting the Bank’s business.

As a standard Compliance function, several workshops

and compulsory e-education on ethics, the prevention of

corruption, conflicts of interest, protection of personal data,

AML/CTF, Information Security, Physical Security, and other

relevant topics related to everyday work were prepared.

For all employees, yearly e-trainings are mandatory on

subjects such as prevention of insider trading and market

manipulation, ethics, anti-corruption, mitigation ofconflict

of interests, personal data protection, information security,

and similar themes. The Group seeks to promote a corporate

culture that facilitates compliance, and by continuously

raising awareness, for example through communication via its

monthly compliance newsletter, detailing not only important

regulatory changes, but also current information and case

studies on different compliance and ethics topics.

Prevention ofMoney

Laundering and Terrorism

Financingand Financial

SanctionsCompliance

The Bankcomplieswith national regulations on Anti-Money

Laundering and Combating the Financing of Terrorism

(AML/CFT), including the European Banking Authority

(EBA), BoS and other competent authorities’ guidelines and

standards. The RoS is a member of the EU, and thus subject

to the European AML/CFT Directives, the means by which

the EU transposes the

Financial Action Task Force (FATF)

recommendations throughout the EU. For the Bank, it is of

paramount importance to effectively mitigate the risk of

money laundering, financing of terrorism and breaches of

financial sanctions. For these reasons, the rules, procedures,

and technology in AML/CFT area are subject to strict and

unified policies and standards. The same principles are also

applied for setting out the Bank’s framework on financial

sanctions. In the previous year, the Bank upgraded and

introduced further enhancements of AML governance in

line with directions set by the BoS. Through the system of

regular reporting and constant onsite and off-site control, the

headquarters effectivelymonitors the implementation and

execution of standards throughout the Group.

The Bank regularly performs customer due diligence,

following the risk-based approach and, in the case of

enhanced risk, performs additional measures both in

the segment of ‘Know your customer,’ as well as ongoing

monitoring of the transactional activities. In the case of

detected deviations, also considering the AML/CTF indicators,

the AML unit of the Bank ensures the review and, if required by

AML/CFT legislation, reports the customers and transactions

to the competent Financial Intelligence Unit. In its Acceptance

Policy, the Bank has also adopted additional measures to

prevent onboarding of customers that do not correspond to its

risk appetite. The Bank also ensures a high level of awareness

on the AML/CFT area and the area of financial sanctions with

regular training of all employees of the Bank.

39

cases investigated.

169

complianceprocesses and other

reviews.

![]()

121

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Internal Audit is the independent, objective, and advisory

control body responsible for a systematic and professional

assessment of the effectiveness of risk management

procedures, completeness, and functionality of internal

control systems, and the management of the Group

operations on an ongoing basis. The Internal Audit provided

impartial assurance to the Management Board and

Supervisory Board on the management of risks in key areas,

i.e., cyber security, Linux and Windows server platforms,

restructuring – retail, ICAAP process, personal accounts,

outsourcing process, liquidity and credit risk management,

lending processes (loans to retail – overdraft facilities,

credit cards facilities, non-performing loans, leveraged

transactions), corporate real estate management, cash

management in branches, and others.

Performedaudits

The Internal Audit performs its tasks and responsibilities on its

own discretion and in compliance with the annual audit plan

as approved by the Management Board and confirmed by the

Supervisory Board. Based on its internal methodology and

comprehensive risk analysis for 2021, the Internal Audit of NLB

conducted 43 audit assignments (of that, three audits on a

Group level), seven were postponed due to objective reasons.

Furthermore, auditors conducted 27 branch inspections,

one joint audit with the local auditors, and two internal audit

quality reviews, both in the Group. Auditors were also involved

in several strategic projects as advisor. The majority of the

recommendations given in 2021 were implemented within the

agreed deadlines.

Implementation of

uniform rules

Internal Audit increases efficiency. It focuses on monitoring

the implementation of audit recommendations, training and

education, updating the internal audit charter and manual,

advising management, and ensuring high quality and

professional operations of the internal audit function within

the Group. The Internal Audit also introduces uniform rules of

operation of the internal audit function and regularly monitors

the compliance with these rules within the Group.

Internal Audit reviews key risks in the Group’s

operations, advises management at all levels,

and deepens understanding of the Bank’s

operations. It provides independent and impartial

assurance regarding the management of key

risks, management of the Bank, operation

of internal controls, and thereby strengthens

and protects the value of the Bank.

The higheststandards

werefollowed

Internal Audit and other internal audit services in the Group

operate in accordance with the:

Internal Audit

69

planned and extraordinary

audits conducted in the Bank.

28

Internal Audit experts.

Banking Act (ZBan-3) or other

relevant laws which regulate the

operations of aGroup member

Code of Ethics of

an Internal Auditor

Code of

Internal

Auditing

Principles

International

Standards

for the

Professional

Practice

of Internal

Auditing

![]()

122

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Corporate Governance Statements

![]()

123

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Statement of Management’s

Responsibility

In accordance with the provisions of Article 134 (2

nd

paragraph) ofthe Market and Financial Instruments Act

17

,

theManagement Board hereby confirms the statements

made in the business report, which are in accordance with

the attached financial statements as at 31 December 2021, and

represent the actual and fair financial standing of the Bank

and the NLB Group as well as their operating results in the

year that ended 31December 2021.

The Management Board confirms that the business report

gives a fair view of developments and operating results of the

Bank and the Group and their financial standings, including

a description of the key types of risks and Group companies

included in the consolidation are exposed as a whole.

Ljubljana, 11 April 2022

17(ZTFI-1, Official Gazzete of the RoS, No. 77/18, 17/19 – corr., 66/19 in 123/21).

Management Board of NLB

Archibald Kremser

CFO

Andreas Burkhardt

CRO

Blaž Brodnjak

CEO & CMO

![]()

124

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report



Corporate consultancy regarding capital structure

operational strategy and related matters and

consultancy and services in connection with corporate

mergers and acquisitions



Monetary intermediation on interbank markets



Advice on portfolio management



Safekeeping of securities and other related services



Credit rating services: collecting analysing and

disseminatinginformationregarding creditworthiness



Leasing of safe deposit boxes



Investment services and transactions and ancillary

investment services in accordance with the Market and

Financial Instruments Act (ZTFI)

It may perform the following additional financial services,

pursuant to Article 6 of the ZBan-3:



insurance agency service pursuant to the law governing

the insurance industry



custodian services according to the law governing

investment funds and management companies



credit brokerage for consumer and other types of loans

Authorisation to perform banking services is published on the

official web page of the BoS

(

https://www

.

bsi

.

si/en/financial-stability/institutions-under-

supervision/banks-in-slovenia

/8

/nova-ljubljanska-banka-

dd-ljubljana

).

Authorisation toPerform

Banking Services

In accordance with the provisions of Article 14 (1

st

paragraph)

of the Regulation on Books of Accounts and Annual Reports

of Banks and Savings Banks (

Official Gazette of the RoS

, No.

184/21) adopted by the BoS on the basis of the authorisation

from Article 109 of the Banking Act,

18

(ZBan-3), NLB hereby

lists all types of financial services which, in accordance with

the authorisation of the BoS, took place during the period for

which the business report was prepared.

NLB has the authorisation to perform banking services

pursuant to Article 5 of the ZBan-3. Banking services are the

acceptance of deposits and other repayable funds from the

public and the granting of credits for its own account.

The bank has an authorisation to perform mutually

recognised and additional financial services.

It may perform the following mutually recognised financial

services, pursuant to Article 5 of the ZBan-3, namely:



Accepting deposits and other repayable funds from the

public



Granting of loans including:

•

consumer loans

•

mortgage loans

•purchase of receivables with or without recourse

(factoring)

•financing of commercial transactions, including export

financing based on the purchase of non-current non-

past-due receivables at a discount and without recourse,

secured by financial instruments (forfeiting)



Payment services



Issuing and managing other payment instruments (eg

travellers’ cheques and bank bills of exchange) insofar

as such services are not included in the services referred

to in the previous point



Issuingof guarantees andother commitments



Trading for own account or for the account of clients:

•

in money-marketinstruments

•in foreign legal tender, including currency exchange

transactions

•

in standardized futures and options

•

in currency and interest-rate instruments

•

in transferable securities



Participation in securities issues and the provision of

associated services

18Official Gazette of the RoS, No. 92/21 and 123/21.

![]()

125

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Corporate Governance

Statement of NLB

Pursuant to Article 70, paragraph 5, of the Companies

Act (ZGD-1)

19

NLB hereby gives the following Corporate

Governance Statement of NLB as a part of the Business

Report of the NLB Group Annual Report 2021. The main

function of this statement is the prompt informing of investors

on the coherence of the Bank’s corporate governance system.

1.STATEMENT OF COMPLIANCE

WITHTHECORPORATE

GOVERNANCE CODE

NLB, as a public company whose shares are listed on Prime

Market of the Ljubljana Stock Exchange, hereby discloses the

compliance with the Slovenian Corporate Governance Code for

Listed Companies, adopted by the Ljubljana Stock Exchange

and Slovene Directors’ Association, on 27 October 2016 (valid

from 1 January 2017) as the code that applies for the bank.

Information contained in this point represents a 'Statement of

Compliance with the Corporate Governance Code' as definedin

Article 24 of the Ljubljana Stock Exchange Rules, dated 27 May

2020 (

https://ljse.si/en/rules-and-regulations/252

).

1.1.References to the Code on

Corporate Governance

The recommended best corporate governance practices

contribute to a transparent and understandable corporate

governance system, which promotes both domestic and foreign

investor confidence, as well as the confidence of employees,

other stakeholders (regulators, suppliers, etc.), and the general

public. A decision on which code the Bank will follow was made

jointly by the Management Board and the Supervisory Board

of the Bank by adopting the Corporate Governance Policy of

NLB (November 2020). In 2022, the Group will actively analyse

the changes made with a renewed version of the Slovenian

Corporate Governance Code for Listed Companies, that will

be the first used for preparation of the Corporate Governance

Statement of NLB for the business year 2022.

NLB also has its own corporate governance code. The NLB

Group Code of Conduct is a standardised document for all

members of the Group that defines values, lays down the

19The Companies Law (ZGD- 1; Official Gazette of the RoS, No. 65/09 and

consecutive changes).

standards of ethical business conduct, and serves as the

guideline for all our relationships regardless of whether

it involves clients, competitors, business partners, state

authorities, regulators, shareholders, or internal relationships

between employees. At the same time, it is the basis of the

Group values and basic principles of conduct which provide

specific conduct guidelines to its employees. The aim of this

approach is to ensure compliance with all applicable laws,

regulations, and standards. It is published on the Bank’s web

page (

https://www.nlb.si/compliance-and-integrity

).

Compliance with the aforementioned Code is explained in

the Corporate Governance Statement of NLB on ‘comply or

explain basis,’ in which the Bank provides explanation regarding

deviations, reasoning for non-compliance with a certain

recommendation, or alternative practices performed mostly due

to stricter banking regulation. The statement refers to the Bank’s

system of corporate governance from the beginning to the end of

financial year, which also corresponds to the beginning and the

end of the calendar year (from 1January until 31 December).

Corporate Governance Statement of NLB is included in the

Business Report of the NLB Group Annual Report (published

on

https://www.nlb.si/financial-reports

), and is also published

as a separate report on the Bank’s website under chapter

on Corporate Governance (

https://www.nlb.si/corporate-

governance

), as well as on the website of the Ljubljana Stock

Exchange (

https://seonet.ljse.si

).

NLB strives to increase the level of its business transparency

and informs the shareholders and other expert community

in line with Guidelines on Disclosure for Listed Companies

(Ljubljana Stock Exchange, 18 December 2020) on electronic

communications system of the Ljubljana Stock Exchange

(

https://ljse.si/en/rules-and-regulations/252

) and in line with

Rules and Regulation of the Luxembourg Stock Exchange, as

well as in line with Rules of the London Stock Exchange through

Regulatory News Services (RNS) of the London Stock Exchange.

The Corporate Governance system of the Bank and all

relevant information on Bank’s management that exceeds the

requirements of article 70 of the Companies Act (ZGD-1) are

published in the chapter of

Risk Management

of this annual

report, where ESG Risk Management for the year 2021 is

described, as well as in the

Sustainability

chapter of this annual

report, and the NLB Group Sustainability Report 2021 (

https://www.

nlb.si/sustainability

). Some other aspects about the functioning

of the Bank’s managing bodies are described in the chapter of

Corporate Governance

of this annual report, as well as in the

Corporate Governance Policy of NLB (November 2020) published

on the NLB’s website (

https://www.nlb.si/corporate-governance

).

Information on the Diversity Policy and Remuneration Policy is also

described in the Pillar 3 Disclosures according to Basel standards

(

https://www.nlb.si/financial-reports

).

2.COMPLIANCE WITH THE

SLOVENIAN CORPORATE

GOVERNANCE CODE FOR

LISTED COMPANIES

The Bank does not follow or partially implements or adhere

to different, in most cases stricter, banking regulations with

regard to the following recommendations:

Recommendation no. 8.5

: In the reasoning of the proposals for the

General Meeting, NLB does not cite eventual conflicts of interest

because they are already included into the Fit & Proper procedure.

Recommendation no. 10.1

: In assessing candidate’s eligibility

for a Supervisory Board member, statutory criteria are

applied, however candidates don’t have a certificate

evidencing their specialised professional competence for

membership on a Supervisory Board, such as the Certificate

of the Slovenian Directors’ Association, or any other relevant

certificate. However, all strict conditions must be fulfilled

according to banking legislature.

Recommendation no. 12.2

: The Rules of Procedure of the

Supervisory Board of NLB do not include the list of all types

of transactions for which the Management Board needs prior

approval of the Supervisory Board, but refer to Article 24 of the

Articles of Association. The mentioned rules also do not include

the Supervisory Board evaluation, education, and training

of the members of the Supervisory Board. The mentioned

provisions are part of other internal documents or decisions of

the managing bodies.

Recommendation no. 12.3

: The Rules of Procedure of the

Supervisory Board of NLB do not include the scope of topics

and timeframe to be respected by the Management Board in

its periodic reporting of the Supervisory Board. However, the

scope of topics and time frames of periodic reporting to the

Supervisory Board are included in annual Action Plan of the

Supervisory Board and Articles of Association. Professional

![]()

126

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

services of the Bank take care that timely information is

provided to the Supervisory Board.

Recommendation no. 15.3

: NLB does not follow this

recommendation because the President of the Supervisory

Board is at the same time President of the Nominations

Committee.

Recommendation no. 17.1

: In 2021, the Supervisory Board

members (representatives ofcapital and representatives

of workers) did not receive attendance fees, but received

payments for performing their function based on the decisions

of the General Meeting of shareholders dated 21 October

2019 and 15 June 2020. Remuneration of the members of the

Supervisory Board is regulated by the Remuneration Policy

for the Members of the Supervisory Board of NLB and the

Members of the Management Board of NLB adopted by the

Supervisory Board on 15 October 2021 and by the General

Meeting of shareholders on 16 December 2021. The voting on

mentioned policy by the General Meeting of shareholders was

consultative.

Recommendations no. 21.4 to 21.6

: In 2021, NLB did not pay

variable remuneration in the form of NLB’s shares to any

member of the NLB Management Board, nor do stock option

plans and comparable financial instruments make up most

of the variable remuneration of any member of the NLB

Management Board. In relation to the payment of variable

remuneration in ordinary or preference shares of NLB, or

share linked instruments, or equivalent non-cash instruments

NLB complies with the recent changes introduced by the

Banking Act (ZBan-3)

20

that came into force on 23 June

2021. In accordance with point 3 of the second paragraph

of Article 190 of the ZBan-3, at least 50% of the variable

remuneration of (among other) each member of the NLB

Management Board shall comprise ordinary or preference

shares of NLB, or share linked instruments, or equivalent

non-cash instruments (hereinafter collectively: Instruments).

This requirement applies to both the non-deferred and the

deferred part of variable remuneration (which are different

from recommendations 21.4 and 21.6, which provide that

variable remuneration given as shares, as well as the

execution of stock options and any other rights to acquire

shares or be remunerated based on share price movements,

must not be made possible for at least three years after such

rights were awarded). When the variable remuneration of an

individual Identified Staff for a particular year does not exceed

20 Banking Act (ZBan-3; Official Gazette of the RS, No 92/21).

EUR 50,000 and does not exceed one third of his/her total

remuneration for such year, ZBan-3 allows for an exception

from the requirement that a part of variable remuneration

must be paid in Instruments. On 15 October 2021, the

Supervisory Board of the bank adopted a new Remuneration

Policy of Members of the Management Board of NLB and the

Members of the Supervisory Board of NLB, which was also

adopted by the General Meeting of shareholders of the Bank

on 16 December 2021. The voting on mentioned policy by the

General Meeting of shareholders was consultative.

Recommendation no. 25.3

: The Bank does not follow the

recommendation on rotation of audit companies (at least once

every seven years); however, the Bank complies with the Banking

Law (ZBan-3) that allows longer period. However, the audit firm

did replace the audit partner responsible for the audit of NLB

and the Group financial statements for year 2020 and 2021.

Recommendation no. 27.4

: NLB draws up its financial

calendar which is published on Banks’ website (

https://www.

nlb.si/financial-calendar

) and includes the date of the Annual

General Meeting, however, it doesn’t provide information on

the dividend payment date. The dividend payment date is

announced in the publication of the Agenda and Proposed

Resolutions to be passed at the Annual General Meeting

(

https

://www

.

nlb

.

si/general-meetings

). The dividend payment

date is determined based on KDD Operations Rules (Central

Securities Clearing Corporation).

Recommendation no. 29.2

: The Bank performs the corporate

sustainability reporting according to Global Reporting

Initiative Standards (GRI). Another institution suitable for

independent external assessment of corporate sustainability

reporting will verify the correctness of information in the

corporate sustainability report presumably for business year

2022 (this also includes GRI standards). However, the bank

already adopted a decision that in 2022 an independent

external verification of the work of calculating the carbon

footprint will be performed by renowned natural science and

technology researchinstitute in Slovenia.

Recommendation no. 29.9

: NLB does not publish the rules of

procedure of its bodies (Management Board and Supervisory

Board and its committees) on its website. However, each year

the Bank discloses the composition, competences, and work of

its managing bodies in the Corporate Governance Statement of

NLB and publishes it in the NLB Group Annual Report, on Bank's

website (

https://www.nlb.si/corporate-governance

), as well as

on the web page of the Ljubljana Stock Exchange

(

https://seonet.ljse.si

).

3.MAIN FEATURES OF INTERNAL

CONTROL AND RISK

MANAGEMENT SYSTEMS IN

RELATION TO FINANCIAL

REPORTING

NLB is governed by the provisions of the Capital Requirements

Regulation (CRR), with amendment, together with all

applicable delegated acts, Banking Act (ZBan-3) and the

Regulation on Internal Governance Arrangements, the

Management Body and the Internal Capital Adequacy

Assessment Process for Banks and Savings Banks regulating,

and relevant EBA Guidelines, among other, the Bank’s

obligation to set up, maintain appropriate internal control,

and risk management systems. Due to the above, the NLB has

developed a steady and reliable internal governance system

encompassing the following:

•a clear organisational structure with precisely defined

transparent and consistent internal relations in the area of

responsibility;

•

effective risk management processes for identifying,

measuring or assessing, managing, and monitoring risks,

including risk appetite, risk strategy, ICAAP, ILAAP, recovery

plan, and the reporting of risks to which the Group is

exposed or could be exposed in its operations;

•incorporating main strategic risk guidelines into annual

business plan review, budgeting process, and other relevant

decision-making;

•suitable internal control mechanisms that include

appropriate administrative and accounting procedures;

•the appropriate remuneration policies and practices that

are in line with prudent and effective risk management, and

thus promote risk management.

3.1.

Internal control mechanisms

Suitability of the internal control mechanisms are determined

by the independence, quality and validity of:

•the rules for and controls of the implementation of the

Bank's organisational procedures, business procedures,

and work procedures (internal controls) and

•

the internal control functions and departments (internal

control functions).

![]()

127

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

3.1.1.

Internal Controls

In August 2021, the Bank upgraded a system of internal

controls by adopting a revised Policy Internal Control System

that isharmonizedwith internationalregulatory requirements

and standards (CRR, Banking Act, BIS, COSO, regulation of the

BoS, EBA et al). A system of internal controls means a set of

rules, procedures, and organisational structures aimed at:

•ensuring efficient and consistent implementation of NLB's

strategiesand operations,

•ensuring efficient and consistent processes and procedures

in the NLB,

•protection of the value of NLB's assets,

•

ensuring the reliability and integrity of accounting and

management data and information,

•ensuring the operation and operation of the NLB in

accordance with all applicable rules and regulations.

The system of internal controls in NLB is designed to ensure

that for each key risk there is a process or other measure to

reduce or manage that risk and that process or measure is

effective for that purpose.

The aforementioned policy introduces a new description of

the three lines of defence, namely:



Firstlevel (or line) controls are implemented into business

and nonbusiness organisational units (OU): controls

are designed to ensure the proper implementation

of business activities ie the Bank's operations

Supervision in each individual business area is carried

out by the competent organisational unit (OU) which is

responsible for the implementation of procedures;



Secondlevel controls are divided between Risk

Management and Compliance control functions

(including AML/CTF and Information security

management) that carry out independent controls and

supervision over the operation of the first line of defence

The business compliance function sees to the supervision

of the correct implementation and ensuring compliance

(line controls) with the regulatory framework its

consistent interpretation at the Group level as well as

to identifying assessing preventing and monitoring

overall risks to compliance and integrity in the NLB The

risk management function directs risk management and

control by defining policies and methodologies for risk

assessment and management;



The third level of controls is performed by the internal

audit function which assesses and regularly checks

the completeness functionality and adequacy of the

internal control system Internal audit is completely

independent of both the first line and the secondlevel

control functions

In the event of deficiencies, irregularities of breaches

identified in the process of implementation of internal

controls the breaches are discussed at the Operational

Risk Committee (which is collective decision-making body

appointed by the Management Board of the Bank that is

established for execution of individual tasks within powers

of the Management Board of the Bank). The mentioned

committee adopts decisions so that appropriate actions are

taken and informs the Management Board of the Bank about

deficiencies and actions taken on that behalf.

3.1.2.

Internal Control Functions

The internal control functions are part of the system of the

internal governance in the Bank. Internal control functions

include:

a)The Internal Audit Function

The Internal Audit function is organised according to

the Charter on the Internal Audit of NLB adopted by the

Management Board on 13 November 2018 (and supplemented

on 13 August 2019), to which the Supervisory Board of NLB

gave its approval (30 November 2018 and 6 September 2019).

The Charter of the Internal Audit of NLB is the umbrella

document about the understanding and role of the

Internal Audit in NLB, which defines the purpose, powers,

responsibilities, and tasks of the Internal Audit in line with

the International Standards for the Professional Practice of

Internal Auditing. The Charter lays down the position of the

Internal Audit in the organisation, including the nature of

the relationship between the functional responsibility of the

Head of the Internal Audit to the supervisory body, grants

authorisations to internal auditors for accessing records,

employees, premises, and equipment relevant for performing

their tasks, and defines the area and activities of the Internal

Audit.

The Management Board has set up an independent internal

audit function which gives assurances and advice about risk

management, internal controls system, and management of

the NLB. The mission and the principal task of the Internal

Audit is to consolidate and secure the value of the Bank by

issuing objective assurances based on risk assessment,

with consultancy and deep understanding of the Bank’s

operations. In addition to that, the Internal Audit carries out

regular control of the quality of operation of the other internal

audit departments in the Group and takes care of constant

developmentof the internal auditingfunction.

Pursuant to the provisions of the law, the Bank has organised

the internal audit as an independent organisational unit,

primary responsible to the Supervisory Board of the NLB and

secondary to the Management Board of the Bank.

The Supervisory Board of NLB must issue its approval of the

appointment, remuneration, and dismissal to the Head of the

Internal Audit, which ensures their independence and so, the

independence of the work of the Internal Audit.

b)The Risk Management Function

The Risk Management Function is organised according to the

Charter of the Risk Management Function of NLB adopted by the

Management Board, in agreement with the Supervisory Board

of NLB. The Charter on Functioning of the Risk Management

Function of NLB is the framework document on understanding

and role of the risk management function; it defines the

purpose, validity, and method of operation, as well as the

authorisations and responsibilities of the risk management

function according to the requirements of the Banking Act (ZBan-

3) and the Regulation on Internal Management Arrangements,

Management Body, and Internal Capital Adequacy Assessment

Process for Banks and Savings Banks.

The risk management function represents an important part

of overall management and governance system in the Group.

This function in NLB is organised within the Risk stream,

covered by the member of the Management Board in charge

of risk (Chief risk officer - CRO). The risk stream covers the

following organisationalunits:

•Global Risk

•Credit Risk – Corporate

•Credit Risk - Retail

•

Evaluation and Control

•Restructuring

•Work-out and Legal support

The risk management function is performed by the Global

Risk. In accordance with the competences, authorisations,

and responsibilities Global Risk is represented by its General

Manager. The Global Risk is in functional and organisational

terms separate from other functions where business decisions

are adopted and where potential conflict of interest may

arise with the risk management function. The head of the risk

![]()

128

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

management function has direct access to the Management

Board of the NLB and at the same time unhindered and

independent access to the Supervisory Board of NLB and the

Risk Committee of the Supervisory Board of the NLB.

In members of the Group, the risk management function is

organised according to the local legislation, considering

the bases for set-up, organisation, and activities in risk

management in the members, as defined in the document

'Risk Management Standards in the NLB Group.' The

described standards on risk management provide the

members of the Group the bases with which they have to align

their organisation, strategic risk-taking guidelines, internal

policies, methodologies, and reporting system.

Risk management and control is performed through a

clear organisational structure with defined roles and

responsibilities. The organisation and delineation of

competencies is designed to prevent conflicts of interest,

ensure a transparent and documented decision-making

process, subject to an appropriate upward and downward

flow of information. The competence line Risk Management in

NLB, encompassing several professional areas, is in charge

for formulating and controlling the Group’s risk management

policies, setting limits, overseeing the harmonisation, regular

monitoring of risk exposures, and limits based on centralised

reporting at the Group level.

The Group puts great emphasis on the risk culture and

awareness across the entire Group. Group’s Risk Management

framework is forward-looking and tailored to its business

model and corresponding risk profile.

c)The Compliance Function, Information Security Function,

and AML/CTF Function

Compliance and Integrity in the Group in its role as internal

control function performs control activities with respect to the

main following areas:

•anti-money laundering and counter-terrorist financing

(separately for NLB and the Group)

•information security and data protection,

•

personal data protection,

•

regulatory compliance management,

•

preventionof fraud and internal investigations,

•

security,

•development of compliance risk methodologies, and setting

and monitoring ethics and integrity standards;

•harmonisation of policies and practices within the Group

(Competence lineCompliance and Integrity).

Compliance and Integrity is an organisational unit of the Bank,

placed directly under the Bank’s Management Board in the

organisational structure. The Bank adopted Integrity and

Compliance Policy of the NLB and the NLB Group (Version 1,

December 2016), which regulates the method and scope of

the activities of the compliance function in the Bank. Separate

policies regulate different areas which are organised within

the Compliance and Integrity in NLB. Supervision over

compliance of operations is within the competence of the

Compliance and Integrity. This enables the Compliance

and Integrity to operate independently from other Bank’s

departments.

The director of Compliance and Integrity does not perform

any other function at the Bank that could possibly lead to

conflict of interests. To ensure his independence, the director

reports to the Management Board and to a specific member

of the Bank’s Management Board responsible for compliance

area (including information security, personal data protection,

and AML/CTF functions), which additionally ensures

independence of operation of the Compliance and Integrity.

As information security, AML/CTF, and Group AML functions

are organised within Compliance and Integrity, CISO for NLB,

Group CISO, DPO (Data Protection Officer), head of AML/

CTF area for NLB and head of Group AML are ensured full

independence through equal reporting lines as the director

of Compliance and Integrity and have direct access and

separate reporting line to the Bank’s Supervisory Board.

Following NLB’s model, the compliance function has been

established in the core members of the Group, as well based

on the Group standards for the compliance and integrity area.

Through specific binding standards in the area of compliance

and integrity, there is a harmonised system of standards and

practices in the area of compliance and integrity in place in

the entire NLB Group, in core and non-core members.

3.2.

Financial reporting

With the aim of ensuring appropriate financial reporting

procedures, NLB pursues the adopted Policy on Accounting

Controls. The accounting controls are providedthrough

the operation ofthe complete accounting function with

the purpose of ensuring quality and reliable accounting

information, and thereby accurate and timely financial

reporting. The principal identified risks in this area are

managed with an appropriate system of authorisations, a

segregation ofduties, compliance withaccountingrules,

documenting of all business events, a custody system, posting

on the day of a business event, in-built control mechanisms in

source applications, and archiving pursuant to the laws and

internal regulations. Furthermore, the policy precisely defines

primary accounting controls, performed in the scope of

analytical bookkeeping, and secondary accounting controls,

i.e., checking the efficiency of implementation of primary

accounting controls. With anefficient mechanism ofcontrols

in accountingreporting, NLB ensures:

•A reliable decision-making and operation support system

•Accurate, complete, and timely accounting data, the

resulting accounting, and other reports of the Bank

•Compliance with legal and other requirements.

Financial statements of NLB and consolidated financial

statements of the NLB Group are audited by the auditing

company Ernst & Young d.o.o., Ljubljana. The mentioned

auditing company was appointed as the auditor of NLB by the

General Meeting of shareholders of the Bank for the financial

years 2018 to 2022 (27 June 2018). The auditing company

verifies the business report in accordance with the provisions

of the Companies Act (ZGD-1).

4.INFORMATION ON POINT 4,

PARAGRAPH 5, OF THE ARTICLE

70 OF THE ZGD-1 regarding

points 3, 4, 6, 8, and 9 of

paragraph 6 ofthesamearticle

Explanation regardingsignificant direct and indirect

ownership of the company’s securities in the sense of

achieving a qualified stake as determined by the act

regulating acquisitions

(Point 3 of the sixth paragraph of Article 70 of the ZGD-1)

![]()

129

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Significant direct and indirect ownership of the company’s

securities in terms of achieving a qualifying holding as defined

in the Takeovers Act (as of 31 December 2021).

Shareholder

Number of

shares

Percentage

of shares

Nature of

ownership

RoS

5,000,00125.00shares

Brandes Investment

Partners, L.P.

(i)

/>5 and <10GDRs

EBRD

(i)

/>5 and <10GDRs

Schroders plc

(i), (ii)

/>5 and <10GDRs

(i)

In the form of GDRs.

(ii)

Further information is available in chapter

Events after the end of the 2021

financial year

.

More information on the Bank’s Share Capital is available on

the website:

https://www

.

nlb

.

si/shares

.

Explanation regardingthe holders of securities that carry

special control rights

(Point 4 of the sixth paragraph of Article 70 of the ZGD-1)

The Bank did not issue any securities carrying special

controlling rights.

Explanation regarding restrictions related to voting rights, in

particular: (i) restrictions of voting rights to a certain stake or

certain number of votes, (ii) deadlines for executing voting

rights, and (iii) agreements in which, based on the company’s

cooperation, the financial rights arising from securities are

separated from the rights of ownership of such securities

(Point 6 of the sixth paragraph of Article 70 of the ZGD-1)

The shares of the Bank are freely transferable, subject to the

provisions of the Articles of Association of the Bank which

require the approval of the Supervisory Board, namely for the

transfer of shares of the Bank by which the acquirer, together

with the shares held by the holder before such an acquisition

and the shares held by third parties for the account of the

acquirer, exceeds the share of 25% of the Bank’s voting

shares. Approval for the transfer of shares is issued by the

Supervisory Board.

The Bank rejects the request for approval of transfer shares

if the acquirer, together with the shares held by the acquirer

before the acquisition and the shares held by third parties for

the account of the acquirer, exceeded the 25% share of the

Bank with voting rights, increased by one share.

Notwithstanding the provision mentioned in the first

paragraph, approval for the transfer of shares is not required

if the acquirer of the shares has acquired them for the account

of third parties, so that it is not entitled to exercise voting rights

from these shares at its sole discretion, while at the same time

committing to the Bank, it will not exercise voting rights on

the basis of the instructions of an individual third party for

whose account it has acquired the shares if, together with the

instructions for voting, it does not receive a written guarantee

from that person that this person has shares for his own

account, and that this person is not, directly or indirectly, a

holder of more than 25% of the Bank’s voting rights.

The acquirer who exceeds the share of 25% of the Bank’s

shares with voting rights and does not require the issuance

of approval for the transfer of shares, or does not receive the

approval of the Bank, may exercise the voting right from 25%

of the shares with the voting rights.

There are no restrictions other than those mentioned and

those thatare regulatory.

Explanation on the (i) company’s rules on appointment or

replacement of members of the management or supervisory

bodies, and (ii) changes to company’sArticles of Association

(Point 8 of the sixth paragraph of Article 70 of the ZGD-1)

The appointment or replacement of members of the

management or supervisory bodies

The Management Board

The Management Board of the Bank is comprised of three

to seven members, one of whom is appointed President

of the Management Board of the Bank. The number of

Management Board members is determined by a resolution

of the Bank’s Supervisory Board. The President and other

members of the Management Board are appointed and

recalled by the Supervisory Board of the Bank; the President

of the Management Board may propose to the Chair of

the Supervisory Board of the Bank to appoint or recall

an individual member or the remaining members of the

Management Board of the Bank.

The President and members of the Management Board

shall be appointed for a period of five years and may be

re-appointed for another term of office. The President

and members of the Management Board may be recalled

prior to the expiry of their term of office in accordance with

applicable laws and Articles of Association. Each member

of the Management Board of the Bank may prematurely

resign her/his term of office with a period of notice of three

months. A written notice shall be delivered to the Chair of

the Supervisory Board of the Bank. The notice term may

be shorter than three months if requested by the resigning

member of the Management Board of the Bank in his/her

notice and is subject to the approval of the Supervisory Board

of the Bank.

A member of the Bank’s Management Board may only be

a person who fulfils the legally prescribed conditions for a

management board member under the law on banking and

who obtained a licence from the BoS or the ECB, if executing

the competences and tasks from Item (e) of paragraph 1 of

Article 4 of Regulation (EU) no. 1024/2013 for the performance

of the function of a bank’s management board member

under the law regulating banking. The Bank assesses

every candidate following the Bank’s Policy governing the

Fit & Proper assessment prior to the appointment.

The Supervisory Board

The Supervisory Board of the Bank consists of a total of 12

members, of which eight members represent the interests

of shareholders and four members represent the interests

of employees. Members representing the interests of

shareholders shall be elected and recalled by the Bank’s

General Meeting from persons proposed by shareholders or

the Supervisory Board of the Bank and members representing

the interests of employees shall be elected and recalled by

the Workers’ Council of the Bank. Members of the Supervisory

Board representing the interests of shareholders are elected

by an ordinary majority of votes cast by shareholders.

The term of office of the Supervisory Board members

commences on the day their appointment enters into force

(start of term of office) and lasts up until the end of the Bank's

Annual General Meeting of shareholders which decides on the

use of accumulated profit for the fourth business year since

the start of their term of office, unless otherwise stipulated

at the time of appointment of individual members. In this

context, the first year is deemed the business year in which the

members of the Supervisory Board of the Bank started their

term of office.

The general meeting of the Bank may dismiss an individual

or all members of the Supervisory Board (representatives of

shareholders) even before the expiration of their term of office.

![]()

130

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

A resolution on a dismissal shall be valid if adopted with at

least a three-quarter majority of all votes cast.

The Supervisory Board of the Bank shall at its first meeting

after an appointment elect from among its members a Chair

and at least one Deputy Chair of the Supervisory Board of

the Bank. A member representing the interests of employees

cannot be elected Chair or Deputy Chair of the Supervisory

Board of the Bank. All the supervisory board members shall

be independent professionals as defined by the Articles of

Association.

A member of the Bank’s Supervisory Board may only be a

person who fulfils the legally prescribed conditions for a

supervisory board member under the law on banking and

who obtained a licence from the BoS or the ECB, if executing

the competences and tasks from Item (e) of paragraph 1 of

Article 4 of Regulation (EU) no. 1024/2013 for the performance

of the function of a bank’s supervisory board member

under the law regulating banking. The Bank assesses every

candidate following the Bank’s Policy governing Fit & Proper

assessment prior to the appointment.

Amendments to Articles of Association

A qualified majority of at least 75% (seventy-five per cent)

of the votes cast by shareholders at the general meeting of

the Bank’s shareholders is required for the adoption of any

amendments of the Articles of Association.

Explanation regardingthe authorisation of the members

of the management, particularly authorisations to issue or

purchase own shares

(Point 9 of the sixth paragraph of Article 70 of the ZGD-1)

With the aim of ensuring NLB treasury shares for the payment

of variable part of the remuneration to the employees

of NLB in the form of NLB shares, the General Meeting

of shareholders of NLB on 10 June 2019, authorised the

Management Board for redeeming treasury shares in the

period of 36 months from the adoption of the resolution at the

General Meeting. The authorisation is valid for acquiring up

to 36,542 NLB treasury shares, while the total percentage of

sharesacquired based onthis authorisation, together with

the treasury shares already in possession of NLB, may not

exceed 10% of NLB share capital (2,000,000 shares). When

disposing its treasury shares which NLB acquired based

on thisauthorisation, the pre-emptiveright ofthe existing

shareholders to acquire shares is excluded in full in case

treasury shares are disposed of for the purpose of paying the

variable part of remuneration to the employees of NLB in the

form of NLB’s shares. In 2021, however, NLB did not purchase

treasury shares.

5.INFORMATION ON THE WORK

AND KEY POWERS OF THE

SHAREHOLDERS’ MEETING

AND OF ITS KEY POWERS,

AND A DESCRIPTION OF

SHAREHOLDERS’ RIGHTS

AND THE METHOD OF THEIR

EXERCISING

Competences of the Bank’s General Meeting are stipulated in

the Companies Act (ZGD-1), the Banking Act (ZBan-3), and the

Articles of Association of the Bank. The General Meeting is a

body of the Bank through which shareholders exercise their

rights, which include among others: decisions on corporate

changes (amendments of the Articles of Association, increase

or decrease of share capital) and legal restructuring (mergers,

acquisitions), adopting decisions on all statutory issues

in respect of appointing and discharging members of the

Supervisory Board (representatives of shareholders), and

appointment of an auditor, distribution decisions (appropriation

of distributable profit), and the granting of discharge from

liability to the Management and Supervisory Board.

The General Meeting is convened by the Management Board.

The General Meeting may be convened by the Supervisory

Board in cases where the Management Board fails to convene

the General Meeting or where a convocation is necessary to

ensure unhindered operations of the Bank. The Supervisory

Board may amend the agenda of the General Meeting

convened in line with the bylaws.

As a rule, the General Meeting of the Bank shall be convened

at the registered office of the Bank, yet it may also be

convened at another venue specified by the convenor. The

Management Board may stipulate that shareholders may

attend or vote before or at the General Meeting by electronic

means without physical presence. The General Meeting of

shareholders shall adopt resolutions by simple majority of the

votes cast, unless the applicable laws or the Bank’s Articles

of Association stipulate a larger majority or other conditions

(adoption and amendments of the Articles of Association,

issue of convertible bonds or other equity securities, exclusion

of pre-emptive right of existing shareholders, decrease

in share capital, the status restructuring of the Bank, or

liquidation of the Bank and discharge of Supervisory Board

members).

The shareholders have the right to participate at the general

meeting of the Bank, the voting right, pre-emptive right to

subscribe for new shares in case of share capital increase, the

right to profit participation (dividends), and the right to a share

in surplus in the event of liquidation or bankruptcy of the Bank

and the right to be informed.

According to Article 296 of the Companies Act, NLB informs

shareholders on their rights as shareholders in an Information

on the Rights of Shareholders that is published among the

documents for convocation of each General Meeting (i.e., on

expansion of the agenda, proposals by shareholders, voting

proposals by shareholders, and the shareholders right to be

informed).

There were two General Meetings of shareholders in 2021. The

shareholders of NLB gathered on 36th General Meeting on

14 June 2021. Due to COVID-19 pandemic, for the first time the

General Meeting was hybrid, as it was held live and online. The

shareholders took note of the approved NLB Group Annual

Report 2020, the Report of the Supervisory Board of NLB

on the results of the examination of the NLB Group Annual

Report 2020, and Information on the income of members of

the Management Board and Supervisory Board of NLB for the

previous business year.

The shareholders decided on the allocation of distributable

profit for 2020. The distributable profit of NLB as of 31

December 2020 was EUR 341,992,219.43. Distributable profit in

the amount of EUR 24,800,000.00 was about to be paid to the

shareholders as dividends in two instalments. In accordance

with the recommendation of the ECB, the Regulation of the

BoS and adopted resolution of the General Meeting the first

instalment of dividends in the total amount of EUR 12 million

was paid on 22 June 2021 (EUR 0.60 per share), while the

second instalment of dividends in the total amount of EUR 12.8

million (EUR 0.64 per share) was paid on 18 October 2021.

The General Meeting of NLB granted discharge to the

members of the Management Board and Supervisory

![]()

131

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Board for the 2020 financial year and adopted amendments

and supplements to the Articles of Association of NLB and

appointed Islam Osama Zekry as a new member of the

Supervisory Board.

At the 37th General Meeting of shareholders on 16 December 2021,

the shareholders decided on additional allocation of distributable

profit for 2020, as the BoS's decision restricting the payment of

dividends expired at the end of September 2021. Therefore, an

additional EUR 67.4 million of distributable profit (EUR 3.37 per

share) was paid to the shareholders on 24 December 2021.

NLB paid out a total of EUR 92.2 million as dividends (or 4.61

EUR per share) to shareholders in 2021 (EUR 12 million on 22

June, EUR 12.8 million on 18 October and EUR 67.4 million on

24 December), thereby reaffirming NLB Group's stable and

successful business operations and strong capital position.

At the General Meeting, the shareholders also voted on

the

Remuneration Policy for the Members of the Supervisory

Board of NLB and the Members of the Management Board of

NLB

required by the latest amendments to the Companies Act,

applicable to all the companies whose securities are traded

on an organised market. In the future, NLB will put it forward

to vote at the General Meeting upon any material amendment

or at least every four years.

6.INFORMATION ABOUT THE

COMPOSITION AND WORK

OF THE MANAGEMENT AND

SUPERVISORY BODY AND ITS

COMMITTEES

6.1.

The Management Board

Composition of the Management Board

The Management Board is the decision-making and

representation body of the Bank. It manages the company, makes

business decisions autonomously and independently, adopts

the development strategy, ensures sound and effective risk

management, acts with the highest professional integrity, protects

business secrets, and is held accountable for the legality of the

Bank’s operations within the limits set by the relevant regulations.

At the beginning of 2021, the Management Board of the Bank

consisted of Blaž Brodnjak, CEO, Archibald Kremser, CFO,

Andreas Burkhardt, CRO, and Petr Brunclík, COO, since the

Supervisory Board reappointed the president and members

of the Supervisory Board (Blaž Brodnjak as the CEO, Archibald

Kremser as the CFO, and Andreas Burkhardt as the CRO of

NLB) on its session on 12 November 2020.

On 21 April 2021, the Supervisory Board of NLB and Petr

Brunclík agreed on the termination of office that went into

effect on 30 June 2021. As at 22 April 2021, his tasks were taken

over by other members of the NLB Management Board.

Material changes that occurred in the Management Board

after the end of the business year 2021 are described in special

statement at the end of this Corporate Governance Statement

of NLB.

Work of the Management Board

In 2021, the Management Board continued to work on the

implementation of the NLB Group Strategy. The very solid

financial results of NLB Group in 2021 enabled the Bank to pay

out a total of EUR 92.2 million as dividends to the shareholders

in 2021 (EUR 12 million on 22 June, EUR 12.8 million on 18 October,

and EUR 67.4 million on 24 December), thereby reaffirming

NLB Group's stable and successful business operations and

strong capital position. Combining these dividend pay-outs,

privatisation proceeds, and the residual value of the RoS,

NLB has fully repaid the amount it received for the 2013

recapitalisation. After successful acquisition of Komercijalna

Banka, Beograd in December 2020, the Management Board

immediately started working on its harmonisation with NLB

Group's standards. The Management Board worked on

intensive digitalisation and emphasis on top quality user

experience, as well as a commitment to sustainable operations

and development. The Management Board worked on a

commitment to sustainable operations and development and

implementation of the ESG factors and their inclusion in the

NLB Group business model. All year long, the Management

Board took all necessary actions in order to lower the impact

and consequences of COVID-19 epidemic in the Group.

A detailed information on composition and the amount of

remuneration of the Management Board can be found in

Appendices C.1 and C.3 of this statement.

6.2.

The Supervisory Board

In accordance with the two-tier governance system,

the Bank’s Supervisory Board issues approvals to the

Management Board related to the Banks’ business policy

and financial plan, approves the strategy of the Bank and

the Group, the internal control system organisation, and

gives consent to the Annual Plan of the Internal Audit and

to financial transactions defined in Articles of Association.

The Supervisory Board acts in accordance with the highest

ethical standards of management, considering the prevention

of conflicts of interest. The Supervisory Board performs its

tasks in accordance with the provisions of the applicable

legislation governing the operations of banks and companies,

the Bank’s Articles of Association, and its Rules of Procedure

of the Supervisory Board of NLB. The Supervisory Board may

engage legal and other consultants and institutions required

by itself or its committees to perform their tasks.

Composition of the Supervisory Board

In accordance with changes made to the Articles of

Association of NLB (June 2020) that enabled workers’

participation in the Bank’s management bodies, the

Supervisory Board consists of 12 members, out of which eight

are representatives of the capital, and four are employee

representatives (elected and appointed by the Workers

Council of NLB).

At the beginning of 2021, the Supervisory Board of NLB

consisted of 11 members, of which eight were representatives

of shareholders (in addition to Primož Karpe, President and

Andreas Klingen, Deputy members were also Mark William

Lane Richards, Shrenik Dhirajlal Davda, Peter Groznik, David

Eric Simon, Gregor Rok Kastelic, and Verica Trstenjak), and

three were representatives of employees (Sergeja Kočar,

Bojana Šteblaj, and Janja Žabjek Dolinšek). In January 2021,

however, the Workers Council of NLB elected Tadeja Žbontar

Rems as a member of the Supervisory Board of the NLB – the

representativeof the workers. With thementioned election,

the composition of the Supervisory Board was complete.

Because the term of office of member of the Supervisory

Board Peter Groznik expired in the middle of the year, the

General Meeting of shareholders on 14 June 2021 elected Islam

Osama Zekry as a new member of the Supervisory Board.

Statement of Independence of the Members of the

Supervisory Board

In accordance with the Article 20 of the Articles of

Association of the NLB all Supervisory Board, members

must be independent experts. Persons representing the

interests of employees in the Supervisory Board of the Bank

are considered independent despite the existence of an

employment relationship with the Bank upon fulfilling certain

terms and conditions.

![]()

132

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

A statement of independence, in which they declare

themselves on their meeting of the criteria of conflict of

interest, is provided by a candidate for a function of a member

of the Supervisory Board, upon each change that would

mean change of his/her independence status once yearly.

It is published on the Bank’s webpage (

https://www.nlb.si/

corporate-governance

).

Work of the Supervisory Board

In 2021, the Supervisory Board met at seven regular and

12 correspondence sessions. Upon receiving reports from

its committees, the Supervisory Board acquainted itself or

adopted the following most important decisions:

•

NLB Group StrategyImplementation Progress Report;

•Annual NLB Group Report for 2020; Report of the

Supervisory Board of NLB on the Results of Examining the

Annual NLB Group Report for 2020; Corporate Governance

Statement of NLB;Risk Management Statement of NLB;

Annual Report of Internal Audit for 2020; Comprehensive

Opinion of the Internal Audit for 2020;

•The Corporate Social Responsibility Report for 2020;

The NLB Group Sustainability Programme; ESC Internal

Documentary Framework (Lending Policies); NLB Group

Sustainability Framework; Confirmation of Pillar III

disclosures of the NLB Group for 2020;

•Proposals to convene the regular General Meeting of

shareholders for14 June 2021 and extraordinary meeting for

16 December 2021;

•Information on the Supervisory Board election; Membership

in the committees of the Supervisory Board; Conflict of

interest Management; Information of departure of the

member of the Management Board; Self-assessment of

the collective suitability of the members of the Supervisory

Board; Supervisory Board self-assessment and Action

Plan; Achievements of the goals of the Management Board

in 2020; Annual self-assessment of employees performing

special work; Information on award of variable part of

salary of the members of the Management Board and

employees performing special work; Future setup of the

Governing Body; Fit & Proper assessment for candidates for

membership of the Supervisory Board – representatives of

employees;

•Appointments of the Director of Global Risk and the Director

of Compliance & Integrity and their performance;

•NLB Group Financial Plan 2021 and financial projections

2022-2025; Interim Reports on the NLB Group Operations;

Benchmark analysis of the NLB Group; NLB Group Budget

2022 and Financial Projections 2023 – 2025; Information on

cost optimisation;

•NLB Group Risk Appetite; NLB Group Risk Strategy; Regular

risk reports for NLB and NLB Group; Outcome of the

Pragmatic SREP 2020; NLB Group Recovery Plan for 2021;

Report on the Top 50 groups of clients by exposure in the

NLB Group, Restructuring TOP 20; Revised ILAAP – Internal

liquidity adequacy process; Revised ICAAP – Internal

Capital Adequacy Process; Reputation Risk Management;

Foreclosed Strategy for 2021 – 2025;

•Internal Audit’s Annual Report for 2020; Internal Audit

Plan (2022 & long - term plan, Action Plan for Compliance

&Integrity for 2022; Regular periodic reports on Internal

Audit; Compliance and Security, and on Information Security

Assurance in NLB;

•Reports on the Documents received from the BoS and the

ECB; Reports on the implementation of the requirements

of the BoS and ECB and on the implementation of the

requirements;

•Renovation of Internal Act on Internal Controls System; Rules

and Procedures for the Sustainability Committee; Review of

the Diversity Policy; New RemunerationPolicy for employees

for the NLB and the NLB Group; The Remuneration Policy

of the Members of Supervisory Board of NLB and the

Management Board of NLB;

•Investment Relations periodic Reports; NLB Workers’

Council Report;

•

Implementation ofIT Strategy; Data Centres in the NLB

Group; Strategy update; IT Security KPI’s update; Status of IT

– periodic Reports; Cor Banking System Consolidation;

•Consent to legal transactions with MIGA, Washington,

Serbia Merger Scenarios; Information on Project Matthew;

Expected sale of a subsidiary bank; large exposures,

sale of receivables, write-offs of claims, approvals of

transactions with persons in special relations with the Bank;

establishment of new companies in Serbia and Macedonia,

etc.

Composition and the amount of remuneration of the

Supervisory Board members is described in the Appendices

C.2 and C.4 of this statement.

6.3.The Supervisory Board Committees

All five Committees for the Supervisory Board function as

consulting bodies of the Supervisory Board of NLB and

discuss the material and proposals of Management Board

of NLB for the Supervisory Board meetings related to a

particular area. The Supervisory Board has the following

committees.

•

The AuditCommittee

•The Risk Committee

•

The Nomination Committee

•

The Remuneration Committee

•The Operations and IT Committee

Committees are composed of at least three members of the

Supervisory Board. The Worker’s Council can nominate one

Supervisory Board member – a representative of the workers

into each committee. The member of the Committee may only

be appointed from among the members of the Supervisory

Board. The term of office of Chair, the Deputy Chair, and

members of the Committee should not exceed their term of

office as Supervisory Board members. The responsibilities of

committees are defined in Rules of Procedure of the particular

Committee of the Supervisory Board of NLB.

Composition of the aforementioned Committees in 2021 is

described in detail in the Appendix C.2 of this statement.

6.3.1.

The Audit Committee of the Supervisory Board ofNLB

The Audit Committee monitors and prepares draft resolutions

for the Supervisory Board on accounting reporting, internal

control and risk management, internal audit, compliance, and

external audit, and as well monitors the implementation of

regulatory measures.

At the end of 2021, the composition of the committee was

as follows: David Eric Simon (Chairman), Shrenik Dhirajlal

Davda (Deputy Chairman), Primož Karpe, Gregor Rok

Kastelic (members). Changes in membership of the committee

that occurred during the year are reflected in the chart on

Supervisory Board Committees (C4 below).

The Audit Committee’s tasks are defined by relevant law, the

Bank’s Articles of Association, Rules of Procedure of the Audit

Committee of the Supervisory Board of NLB, resolutions of

the Supervisory Board and other regulations, from which the

Committee especially monitors and prepares proposals of

resolutions for the Supervisory Board for the area:

•

Accounting and financial reporting

•

Internal control and risk management

•

Internal audit

•

Compliance of operations

•

External audit

![]()

133

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

There were seven regular sessions and three correspondence

sessions of the Audit Committee in 2021. The following is a

summary of key topics considered by the Audit Committee:

•NLB Group 2020 Annual Report, Overall Opinion of Internal

Audit for 2020; Corporate Governance Statement of NLB;

Statement on Management of Risk of the NLB, NLB Group

on Sustainable Operations in 2020;

•Regular interim reports on the operations of the NLB Group,

Business Performance Indicatory for NLB and NLB Group,

quarterly Internal Audit Reports, Compliance and Integrity

Reports, Reports on Information security assurance in NLB;

•

Audit Plan 2021, Internal Audit Plan (2022 & long-term), Action

Plan for Compliance and Integrity for 2022;

•Regular reports on overdue material recommendations

of the Internal Audit; Reports on the documents received

from the BoS and ECB and on the implementation of the

requirements of the BoS and ECB; Policy of the Internal

Controls System; Rules of Procedure of the NLB Group

Sustainable Committee;

•Performance assessment of the Director of the Compliance

and Integrity and the Director of the Internal Audit;

•Self-assessment of the Audit Committee.

6.3.2.The Risk Committee of the Supervisory Board of NLB

The Risk Committee monitors and drafts resolutions for the

Supervisory Board in all risk areas relevant to the Bank’s

operations. It is consulted on the Group’s current and future risk

appetite, the corresponding risk profile and risk management

strategy, and helps carry out control over senior management

concerning implementation of the risk management strategy.

At the end of 2021, the composition of the committee was as

follows: Andreas Klingen (Chairman), Shrenik Dhirajlal Davda

(Deputy Chairman), Islam Osama Zekry, Mark William Lane

Richards, Gregor Rok Kastelic, David Eric Simon (members).

Changes in membership of the committee that occurred

during the year are reflected in the chart on Supervisory

Board Committees (C4 below).

There were five regular sessions of the Risk Committee in 2021.

Following is a summary of key topics considered by the Risk

Committee:

•Statement of Management of Risk of the NLB

•NLB Group Risk Appetite

•Regular quarterly risk reports of NLB and the NLB Group

•NLB Group Risk Strategy;

•

Internal liquidity adequacy process (ILAAP), The Internal

Capital Adequacy Assessment Process (ICAAP) in NLB Group

•NLB Group Recovery plan for 2021

•NLB Group Non-performing Exposure and Foreclosed

Assets Strategy for 2020 -2024 and semi-annual

implementation reports

•

Reputation risk management – management mechanisms

•Information on Pillar III Disclosures of the NLB Group

for 2020; and Acknowledgement of quarterly Pillar III

Disclosures

•Quarterly Information on status of information security in

NLB and NLB Group

•Report on Top 50 groups of clients by exposure in the NLB

Group; Report on Top 20 largest restructuring cases

•Initiation of procurement process for selection of statutory

auditor for financial years from 2023 onwards; Auditing of

the electronic (ESEF) format of financial statements

•Issuing subordinated Tier 2 bonds

•Proposals for the issuance of prior consent of the

Supervisory Board of NLB for a legal transaction based

on which the Bank’s total exposure to individual client or

a group of related clients would reach or exceed 10% of

the Bank’s eligible capital; consents to early repayments;

approval of overdraft on business account of a client and

final write-offs of receivables

•Report on the material court proceedings for NLB and NLB

Group members

6.3.3.The Nomination Committee of the

Supervisory Board ofNLB

The Nomination Committee drafts proposed resolutions for

the Supervisory Board concerning the appointment and

dismissal of the Management Board members; recommends

candidates for Supervisory Board members; recommends

to the Supervisory Board the dismissal of members of

the Management Board and the Supervisory Board

(representatives of capital); prepares the content of executive

employment contracts for the President and members of

the Management Board; evaluates the performance of the

Management Board and the Supervisory Board; and assesses

the knowledge, skills, and experience of individual members

of the Management Board and Supervisory Board and the

bodies as a whole.

At the end of 2021, the composition of the committee was as

follows: Primož Karpe (Chairman), Andreas Klingen (Deputy

Chairman), Verica Trstenjak, Sergeja Kočar, Bojana Šteblaj

(members). Changes in membership of the committee

that occurred during the year are reflected in the chart on

Supervisory Board Committees (C4 below).

There were seven regular sessions and one correspondent

session of the Nomination Committee in 2021. The following

is a summary of key topics considered by the Nomination

Committee:

•The Supervisory Board election process and candidate

selection; Bases for the Fit & Proper assessments of

candidates;The suitability matrix – the self-assessment of the

collective suitability of the Members of the Supervisory Board;

•The Management Board expansion process; New

organisational structure;

•Review of the Diversity Policy; Rules and Procedures for the

selection of candidates.

6.3.4.

The Remuneration Committee of the

Supervisory Board ofNLB

The Remuneration Committee carries out expert and

independent assessments of the remuneration policies and

practices andformulates initiatives formeasures related

to improving the management of the Bank’s risks, capital,

and liquidity; prepares proposals for remuneration-related

decisions of the Supervisory Board; and supervises the

remuneration of senior management performing the risk

management and compliance functions.

At the end of 2021, the composition of the committee was as

follows: Gregor Rok Kastelic (Chairman), Mark William Lane

Richards (Deputy Chairman), Shrenik Dhirajlal Davda, Sergeja

Kočar, and Bojana Šteblaj (members). Changes in membership

of the committee that occurred during the year are reflected in

the chart on Supervisory Board Committees (C3 below).

There were four regular and five correspondence sessions

of the Remuneration Committee in 2021. The following is a

summary of key topics considered by the Remuneration

Committee:

•Annual self-assessment of employees performing special

work in accordance with the Remuneration Policy;

•Realisation of goals of Management Board of NLB for 2020

and proposal for goals for 2021;

•Information on the award of variable part of salary to

members of the Management Board and employees

performing special work in control function for the year

2020;

•Proposal for the payment of the non-deferred part of the

variable pay for 2019 and payment of the deferred variable

part of salary for 2016 and 2017 for the Bank's Management

Board;

![]()

134

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

•Proposal of new Remuneration Policy of members of

the Supervisory Board of NLB and members of the

Management Board of NLB.

6.3.5.The Operations and IT Committee of

the Supervisory Board of NLB

The Committee shall monitor and prepare draft resolutions

for the Supervisory Board, whereby the main tasks that it

performs are the following: monitors the implementation of

the IT Strategy, Information Security Strategy, and Operations

Strategy; monitors key operations and IT KPI’s and service

quality indicators; monitors key operations and IT projects

and initiatives; monitors operating risks in the area of

Operations, IT and Security; monitors the recommendations

for ensuring and increasing the level of information/cyber

security issued by CISO, addresses the report on potential

violations, events, and incidents in the area of IT security;

and monitors the Target Operating Model implementation in

the areas of IT, the Security Operating System, Competence

Centre, andOperations.

At the end of 2021, the composition of the committee was as

follows: Mark William Lane Richards (Chairman), Islam Osama

Zekry (Deputy Chairman), Andreas Klingen, Primož Karpe,

Tadeja Žbontar Rems, Janja ŽabjekDolinšek (members).

There were five sessions of the Operations and IT Committee

2021. The Operations and IT Committee acknowledged itself

with:

•

IT Strategyprogress update;IT Strategy implementation

activities

•

CashProcessingOptimisation update;Cost optimisation

update

•Report on further progress of the Leveraging Information

Capital project

•New digital platform DEMO; Information on projects

•KB IT Security update; GCC Belgrade – status of activities

and plan

•Date centres in Belgrade; Proof on concept on Core Banking

System; Consolidation of the Core Banking System

•

Budgeting Group activities

6.4.Remuneration Policy for the Members of the

Supervisory Board of NLB and Members

of the Management Board of NLB

The General Meeting of shareholders on 16 December 2021

adopted the Remuneration Policy of the members of the

Supervisory Board of NLB and members of the Management

Board of NLB (for the Supervisory Board members the policy

is based on previously adopted resolutions of the General

Meeting) that was changed due to recent amendments to

the Companies Act (ZGD-1), and is to be followed by all the

companies whose securities are traded on the regulated

market.

In accordance with the Companies Act (ZGD-1) mentioned

policy is published on the NLB website (

https://www.nlb.si/

corporate-governance

), together with the date and voting

results. Remuneration of the members of the Management

Board and the members of the Supervisory Board for 2021 can

be found in Appendices C3 and C.4 of this statement and in

the chapter on the

Related

Party Transactions

of this annual

report (Financial report).

7.

DESCRIPTION POLICY ON THE

PROVISION OF DIVERSITY OF

THE MANAGEMENT BODY AND

SENIORMANAGEMENT

Policy on the Provision of Diversity of the Management Body

and Senior Management was adopted by the General Meeting

of shareholders on 10 June 2019. With mentioned Policy, NLB

defines target diversity pursued with respect to adequate

representation of members of the Management Board and

the Supervisory Board and Senior Management from the

perspective of education, range of knowledge, skills and

experience, age, gender, and international experience, as

appropriate for the NLB with regard to its characteristics.

The Bank implements the principles of this policy through other

policies and procedures, namely Policy on the selection of

suitable candidates for members of the Supervisory Board and

the Policy on the selection of suitable candidates for members

of the Management Board, as well as procedures of the

Nomination Committee of the Supervisory Board. Key criteria for

the selection of candidates were supplemented by criteria that

include experience, reputation, management of potential conflict

of interests, independence, time availability, and conditions for

achieving collective suitability of the Supervisory Board.

Mentioned diversity policy is periodically reviewed by the

Nomination Committee of the Supervisory Board.

Implementation and the results achieved by the diversity

policy during the reporting period:

a)The Supervisory Board

We estimate that the goals for 2021 were achieved, as the

members of the Supervisory Board as a whole met at a high

level the requirements related to the set of knowledge, skills,

professional experience, and requirements related to relevant

international experience in various fields; which is maintained

in 2022. It is also estimated that the representation of women is

42% of the share, and it is planned in this amount for 2022.

Regarding the age structure, it is also considered appropriate,

as the members of the Supervisory Board are represented

in the age groups from 40 to 60+, which is also planned for

2022, with a slight increase in the share of members in the age

group above 60 years (from 3 members to 5).

b)The Management Board

We estimate that the goals for 2021 have been achieved as the

members of the Management Board as a whole meet at a high

level the requirements related to the set of knowledge, skills,

professional experience, and requirements related to relevant

international experience in various fields; this is also planned

for 2022.

There wereno women represented in the Management

Board in 2021, however, the plan for 2022 was that the share of

women would increase to 16.7% or one woman was expected

to be represented among the members of the Management

Board. As stated below this goal was realised already in

January 2022.

Regarding the age structure, in 2021 all members of the

Management Board were in the age group of 40 to 50,

however, in 2022 with additional members elected to the

ManagementBoard caused that the representation of

this class increased (from 3 to 5), and one member of the

Management Board will move to the age group from 50 to 60

years.

c)Senior Management

For 2021, we estimate that the goals were achieved, as

senior management at a high level met the requirements

relating to the range of knowledge, skills, and professional

experience. Regarding the requirements related to

international experience in various fields, it is estimated

![]()

135

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

that senior management has largely relevant international

experience, which is planned to the same extent in 2022. It is

also estimated that 45% of women in senior management

appropriate and will be maintained as such in 2022.

Regarding the age structure, it is also considered appropriate,

as senior management in the age structure is very dispersed

and is thus represented in all age groups from 20 to 60 years,

which is maintained in the same ratio in 2022.

Additional information on the framework, objectives, and

chart with set goals of the Diversity Policy can be found in the

chapter

Human Resources

of this annual report.

Statement on changes that occurred between the end of

accounting period up to the publication ofthis statement

In accordance with Guidelines on Disclosure for Listed

Companies, Point 6.3.2 (Ljubljana Stock Exchange, 18

December 2020) NLB hereby states that the following changes

occurred between the end of accounting period up to the

publication ofthis statement.

On 20 January 2022, the Supervisory Board appointed three

new members to the Management Board, namely Hedvika

Usenik, Antonio Argir, and Andrej Lasič. They all come from

NLB or the Group, have extensive experience and proven

value creating a track record. All three of them are currently

executive assistants to the NLB Management Board: Hedvika

Usenik for Retail and Private Banking, Antonio Argir for the

NLB Group, and Andrej Lasič for Corporate and Investment

Banking.

The reasons that the Supervisory Board adopted a decision

to enlarge the Management Board from three to six

members are the fact that NLB has successfully acquired the

Komercijalna Banka, Beograd, that the Group's strategy also

focuses on intensive digitalisation and emphasis on top quality

user experience. Also, the fact that the bank is implementing

its commitment to sustainable operations and development,

which all require and will require also in the future even more

comprehensive, coordinated, and efficient management, both

of individual business areas and the Group as a whole, as well

as exploitation of all the synergies within the Group.

The Bank's Management Board, supplemented with three new

members, is properly equipped for this challenge and offers

the best combination of various knowledge, experience, and

competencies. A five-year term of office for the new members

will start after they have obtained a licence of the banking

regulator, so until then they will continue to perform the

functions of executive assistants to the Management Board.

Ljubljana, 11 April 2022

Supervisory Board ofNLBManagement Board of NLB

Primož Karpe

Chairman

Archibald Kremser

CFO

Andreas Burkhardt

CRO

Blaž Brodnjak

CEO & CMO

![]()

136

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Table 36:

Composition of Management in financial year 2021 (C.1)

Name and Surname

Position held

(President, Member)

Area of work

covered within the

Management Board

First appointment to

the position

Conclusion of the

position/term of

office

CitizenshipYear of birthQualificationProfessional profile

Membership in supervisory

bodies in companies not

related to the company

Blaž BrodnjakPresident

CEO

6 July 20166 July 2026

Slovene1974

MBA

Banking/Finance

Banks' Association

of Slovenia,

AMCham Slovenia,

Handball Federation

of Slovenia

Andreas BurkhardtMember

CRO

18 September 2013

6 July2026

German1971

MBA

Banking/Finance

Archibald KremserMember

CFO

31 July 20136 July 2026

Austrian1971

MBA

Banking/Finance

Petr BrunclíkMember

COO

18 May 2020

30 June 2021

Czech1979MSc

Information

technologies and

applied informatics

![]()

137

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Table 37:

Composition of Supervisory Board and Committees in financial year 2021 (C.2)

Name and

Surname

Position held

(Chairman,

Deputy

Chairman,

Member)

First

appointment to

the position

Conclusion of

the position /

term of office

Representative

of the company's

capital structure /

employees

Attendance at

SB session in

regard to the

total number

of SB session

(for example

5/7) applicable

on his/her

mandate

GenderCitizenshipYear of birthQualification

Professional

profile

Independence

under Article 23 of

the Code (YES/NO)

Existence of

conflict of

interest, in the

business year

(YES/NO)

Membership in

supervisory bodies in

other companies or

institutions

Primož KarpeChairman

10 February

2016

2024

Representative

of the company's

capital structure

7/7

maleSlovene1970MSc

Banking/

Finance

YESYESAngler d.o.o.

Andreas

Klingen

Deputy

Chairman

22 June 2015

2023

Representative

of the company's

capital structure

7/7

maleGerman1964

University

Degree

Banking/

Finance

YESNO

Kyrgyz Investment

and Credit Bank

CISC, Credit Bank

of Moscow

(i)

, Nepi

Rockcastle plc

David Eric

Simon

Member4 August 20162024

Representative

of the company's

capital structure

7/7

maleBritish1948

Higher

National

Diploma in

Business

Studies

Banking/

Finance

YESNO

Jihlavan a.s., Czech

Aerospace industries

sro, Central Europe

Industry Partners a.s.

Peter GroznikMember

8 September

2017

14 June 2021

Representative

of the company's

capital structure

3/3maleSlovene1971PhD

Finance,

industry,

investment

banking

YESNO

MSIN d.o.o., Ljubljana,

CETIS d.d., Ljubljana

Mark William

Lane Richards

Member

10 June 2019

2023

Representative

of the company's

capital structure

7/7

maleBritish1966MSc

Banking/

Finance

YESNO

BPL Global (Lloyds

of London insurance

Broker), Sheffield

Haworth Ltd, Vencap

International pic

Ukraine (UK)

Shrenik

Dhirajlal

Davda

Member

10 June 2019

2023

Representative

of the company's

capital structure

7/7

maleBritish1960MScFinanceYESNOPJSC Ukrgasbank

(ii)

Gregor Rok

Kastelic

Member

10 June 2019

2023

Representative

of the company's

capital structure

7/7

maleSlovene1968MSc

Banking/

Finance

YESNO

Verica

Trstenjak

Member

15 June 2020

2024

Representative

of the company's

capital structure

7/7

femaleSlovene

1962

PhD

Law

YESNO

EU Agency for

Fundamental

Rights, Vienna

Sergeja KočarMember

17 June 2020

2024

Representative

of the company’s

employees

7/7

femaleSlovene1968MScManagementYESNO

Bojana ŠteblajMember

17 June 2020

2024

Representative

of the company’s

employees

7/7

femaleSlovene

1962

MScManagementYESNO

Janja Žabjek

Dolinšek

Member

20 November

2020

2024

Representative

of the company’s

employees

7/7

femaleSlovene1957MScITYESNO

Tadeja Žbontar

Rems

Member

22 January 2021

2025

Representative

of the company’s

employees

7/7

femaleSlovene1957MScITYESNO

Islam Osama

Zekry

Member

14 June 2021

2025

Representative

of the company's

capital structure

4/4

maleEgyptian1977PhDITYESNO

CIB Housing

association,

Egypt, Egyptian AI

Council (Ministry

of Communication

and Information

Technology)

(i)

Till 14 March 2022.

(ii)

Since 8 March also: IPSO, UK.

![]()

138

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Name and Surname

Membership in committees (audit,

nominal, income committee, etc.)

First appointment to the position

Conclusion of the position/term of

office

Chairman/Deputy Chairman/

Member

Attendance at sessions of SB's

Committees in regard to the total

number of SB's session (applicable

on his/her mandate)

Shrenik Dhirajlal DavdaRemuneration Committee

28 June 2019

2023Member

4/4

Gregor Rok KastelicRemuneration Committee

28 June 2019

2023Member/Chairman

4/4

Mark William Lane RichardsRemuneration Committee

26 June2020

2024Deputy Chairman

4/4

Peter GroznikRemuneration Committee

26 June 202014 June2021

Member

4/4

Bojana ŠteblajRemuneration Committee8 April 20212024Member2/2

Sergeja KočarRemuneration Committee

26 June2020

2024Member3/3

Primož KarpeNomination Committee15 April 20162024Chairman

7/7

Andreas KlingenNomination Committee19 February 20162023Deputy Chairman

7/7

Peter GroznikNomination Committee6 October 2017

14 June 2021

Member3/7

Verica Trstenjak

Nomination Committee

26 June 2020

2024Member

7/7

Sergeja KočarNomination Committee

26 June 2020

2024Member

7/7

Bojana ŠteblajNomination Committee8 April 20212024Member2/2

David Eric SimonAudit Committee7 April 20162024Chairman

7/7

Primož KarpeAudit Committee15 April 20162024Member

7/7

Shrenik Dhirajlal DavdaAudit Committee28 June 20192023Member/Deputy Chairman

7/7

Gregor Rok KastelicAudit Committee

28 June2019

2023Member

7/7

Janja Žabjek DolinšekAudit Committee

28 January2021

12 August 2021Member

4/4

Andreas KlingenRisk Committee19 February 20162023Chairman

6/6

Peter GroznikRisk Committee6 October 2017

14 June 2021

Member/Deputy Chairman3/3

Shrenik Dhirajlal DavdaRisk Committee

8 July 2021

2025Deputy Chairman2/2

David Eric SimonRisk Committee7 April 20162024Member

6/6

Mark William Lane RichardsRisk Committee

28 June2019

2023Member

6/6

Gregor Rok KastelicRisk Committee

26 June 2020

2023Member

6/6

Islam Osama ZekryRisk Committee

8 July 2021

2025Member2/2

Tadeja Žbontar RemsRisk Committee

28 January 2021

12 August 2021Member2/2

Mark William Lane RichardsOperational and IT Committee

28 June 2019

2023Chairman5/5

Shrenik Dhirajlal DavdaOperational and IT Committee

28 June20198 July 2021

Deputy Chairman5/5

Andreas KlingenOperational and IT Committee

28 June2019

2023Member4/5

Primož KarpeOperational and IT Committee15 April 20162024Member5/5

Bojana ŠteblajOperational and IT Committee

26 June2020

12 April 2021Member2/2

Tadeja Žbontar RemsOperational and IT Committee8 April 20212024Member3/3

Janja Žabjek DolinšekOperational and IT Committee8 April 20212025Member3/3

Islam Osama ZekryOperational and IT Committee

8 July 2021

2025Deputy Chairman2/2

External member in committees (audit, nominal, income committee, etc.) - The Banking Act (ZBan-2) that came into effect on 13 May 2015 contains provision stipulating that, irrespective of provision of Companies Act (ZGD-1)

only members of the Supervisory Board can be appointed to Supervisory committees.

Name and Surname

Attendance at sessions of SB's

Committees in regard to the

total number of SB's session

(for example 5/7)

GenderQualificationYear of birthProfessional profile

Membership in supervisory

bodies in companies not

related to the company

none



![]()

139

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Table 38:

Composition and amount of remuneration of the Management Board members in the financial year 2021 (C.3)

Name and

Surname

Position held

(President,

Member)

Fixed income

- gross (1)

Variable income - gross

Deferred income

(3)

Severance pay

(4)

Bonuses (5)‘Draw- back’ (6)

Total gross

(1+2+3+4+5-6)

Total net

(i)

on the basis of

quantity criteria

on the basis of

quality criteria

Total (2)

Blaž BrodnjakPresident441,770.2043,750.0043,750.0087,500.0042,710.850.002,310.190.00574,291.24241,568.49

Archibald

Kremser

Member420,808.8841,666.6741,666.6783,333.3442,710.850.0034,116.830.00580,969.90244,905.39

Andreas

Burkhardt

Member405,091.5440,104.1740,104.1780,208.3442,710.850.0032,671.820.00560,682.55237,273.57

Petr BrunclíkMember221,963.097,316.727,316.7214,633.440.00385,000.0030,091.680.00651,688.21327,310.24

(i)

This chart does not include other benefits and cost refunds.



Table 39:

Composition and amount of remuneration of members of the Supervisory Board and committee members in the financial year 2021 (in EUR) (C.4)

Name and Surname

Position held (Chairman,

deputy Chairman,

member, external

member of Committee)

Payment for the

performance of services -

gross per year (1)

Attendance fees for SB

and committees - gross

per year (2)

Total gross (1+2)Total net

(i)

Travel expensesBenefits

Primož KarpeChairman96,000.00-96,000.0074,400.004,629.06447.47

Andreas KlingenDeputy Chairman90,000.00-90,000.0090,000.004,946.99447.47

Islam Osama ZekryMember38,607.52-38,607.5225,432.705,704.85447.47

David Eric SimonMember81,000.00-81,000.0062,775.005,251.42447.47

Peter GroznikMember32,800.00-32,800.0023,855.440.000.00

Mark William

Lane Richards

Member81,000.00-81,000.0053,358.722,642.98447.47

Shrenik Dhirajlal DavdaMember72,000.00-72,000.0047,430.002,367.17447.47

Gregor Rok KastelicMember81,000.00-81,000.0053,358.72758.31447.47

Verica Trstenjak

Member65,790.32-65,790.3243,339.320.00447.47

Sergeja KočarMember11,855.76-11,855.768,622.690.00447.47

Bojana ŠteblajMember15,655.26-15,655.2611,386.050.00447.47

Janja Žabjek DolinšekMember6,839.40-6,839.404,974.270.00447.47

Tadeja Žbontar RemsMember26,656.31-26,656.3119,387.120.00447.47

(i)

After the prepayment of income taxes which is not taken into account in potential subsequent balancing payments of personal income taxes.

![]()

140

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Statement of

Management ofRisk

NLB’s Management Board and Supervisory Board provide

herewith a concise statement of the Risk Management

according to Article 17 of the Decision on Internal Governance

Arrangements, the Management body and the Internal

Capital Adequacy Assessment Process for Banks and Savings

banks (Official Gazette of the RoS, no. 73/2015 and 115/2021),

Regulation (EU) 575/2013, article 435 (Risk management

objectives and policies), point (e) and (f), as well as EBA

Guidelines on Internal Governance (EBA/GL/2021/05), and EBA

Guidelines on Disclosure requirements (EBA GL/2016/11).

Risk Management in the Group, representing an important

element of the Group’s overall corporate governance, is

implemented in accordance with the set strategic guidelines,

established internal policies, and procedures which take into

account the Europeanbanking regulations, the regulations

adopted by the BoS, the current EBA guidelines, and the

relevant good banking practices. EU regulations are followed

by the Group, where the Group subsidiaries operating

outside Slovenia are also compliant with the rules set by the

local regulators. The Group gives high importance to the

risk culture and awareness of all relevant risks within the

entire Group. Maintaining risk-awareness is engrained in the

business strategy of the Group. The business and operating

environment, relevant for the Group’s operations, is changing

with trends such as changing customer behaviour, emerging

new technologies and competitors, sustainable financing, and

increasing new regulatory requirements. Respectively, Risk

Management is continuously adapting with aim to detect and

manage new potential emerging risks.

The Group uses the ‘three lines of defence framework’ as an

important element of its internal governance, wherebythe

Risk Management function acts as a second line of defence.

The Group’s has enhanced overall corporate governance

which reflects in the lowering of the SREP requirement in

recent years. A robust and comprehensive Risk Management

framework is defined and organised with regard to the

Group’s business and risk profile, based on a forward-looking

perspective to meet internally set strategic objectives and

all external requirements. A proactive Risk Management

and control system is primarily based on the Risk appetite

and Risk strategy, which are consistent with the Group’s

Business strategy, and focused on early risk identification and

efficient Risk Management. Set governance and different Risk

Management tools enable adequate oversight of the Group’s

risk profile, proactively support its business operations, and

its management by incorporating escalation procedures

and using different mitigation measures when necessary.

In this respect, the Group is constantly enhancing and

complementing the existing methods and processes in all Risk

Management segments.

The Group is engaged in contributing to sustainable finance

by incorporating environmental, social and governance

(ESG) risks into its business strategies, risk management

framework, and internal governance arrangements. With the

adoption of the NLB Group Sustainability programme, the

Group implemented sustainability elements into its business

model. The goal of this strategic, organisation-wide initiative

is to ensure sustainable financial performance of the Group

by considering ESG risks and opportunities in its operations,

and to actively contribute to a more balanced and inclusive

economic and social system. Thus, sustainable finance

integrates ESG criteria into Group’s business and investment

decisions for the lasting benefit of Group’s clients and

society. The NLB Group Sustainability Committee oversees

the integration of the ESG factors to the Group business

model. The management of ESG risks addresses the Group’s

overall credit approvalprocess and relatedcredit portfolio

management. It follows ECB and EBA guidelines with tendency

of their comprehensive integration into all relevant processes.

The availability of ESG data in the region where the Group

operates is still lacking, nevertheless the Group strives to

obtain relevant clients’ data as prerequisite for adequate

decision-making.

The Group plans a prudent risk profile, optimal capital usage,

and profitable operations in the long run, considering the

risks assumed. The Business strategy, the Risk appetite, the

Risk strategy, and the key internal risk policies of the Group,

approved by the Management Board and the Supervisory

Board of NLB, specify the strategic objectives and guidelines

concerning risk assumption, and the approaches and

methodologies of monitoring, measuring, mitigating,

and managing all types of risk at different relevant levels.

Moreover, the main strategic risk guidelines are consistently

integrated into the regular business strategy review, the

budgeting process, and other strategic decisions, whereby

informed decision-making is assured. The Group is regularly

monitoring its target risk appetite profile and internal capital

allocation, representing the key component of proactive

management. Risk limits usage and potential deviations from

limits or target values are regularly reported to the respective

committees and/or the Management Board of the Bank, the

Risk Committee of the Supervisory Board, and the Supervisory

Board of the Bank.

Additionally, the Group established a comprehensive stress

testing framework and other early warning systems in different

risk areas, with the intention to contribute to setting and

pursuing the Group’s business strategy, to support decision-

making on an ongoing basis, to strengthen the existing internal

controls, and to enable a timely response when necessary.

The stress-testing framework includes all material types of risk

and different relevant stress scenarios or sensitivity analysis,

according to the vulnerability of the Group’s business model.

Stress-testing has an important role when assessing the

Group’s resilience to stressed circumstances, namely from

profitability, capital adequacy, and forward-looking perspective

about liquidity. As such, it is embedded into the Group’s Risk

Management system, namely Risk appetite, ICAAP, ILAAP, and

the Recovery plan, as an important component of sound Risk

Management. Beside internal stress-testing, the Group as a

systemically important bank also participates in the regulatory

stress test exercises carried out by the ECB.

The Group is one of the largest Slovenian banking and

financial groups with an important presence in the SEE

region. In accordance with its strategic orientations intends

to be a sustainably profitable, predominantly working with

clients on its core markets, providing innovative but simple

customer-oriented solutions and activelycontributing to a

more balanced and inclusive economic and social system.

The Group has a well-diversified business model. Efficient

managing of risks and capital is crucial for the Group to

sustain long-term profitable operations. Based on the Group’s

business strategy, credit risk is the dominant risk category,

followed by credit spread risk on banking book portfolio,

interest rate risk in banking book, operational risk, liquidity

risk, market risk, and other non-financial risks. Regular risk

identification and their assessment is performed within ICAAP

process with the aim of assuring their overall control and

effective Risk Management on an ongoing basis.

Managing risks and capital efficiently at all levels iscrucial

for the Group’s sustained long-term profitable operations.

Management of credit risk, representing the Group’s most

important risk, focuses on the taking of moderate risks –

diversified credit portfolio, adequate credit portfolio quality,

sustainable cost of risk and ensuring an optimal return

![]()

141

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

considering the risks assumed. The liquidity risk tolerance is

low. The Group must maintain an appropriate level ofliquidity

at all times to meet its short-term liabilities, even if a specific

stress scenario is realised. Further, with the aim of minimising

this risk, the Group pursues an appropriate structure of

sources of financing. The Group limited exposure to credit

spread risk, arising from the valuation risk of debt securities

portfolio servicing as liquidity reserves, to the moderate level.

The Group’s basic orientation in the management of interest

rate risk is to limit unexpected negative effects on revenues

and capital that would arise from changed market interest

rates and, therefore, a moderate tolerance for this risk is

stated. When assuming operational risk, the Group pursues

the orientation that such risk must not significantly impact

its operations. Risk appetite for operational risks is low to

moderate, with a focus on mitigation actions for important

risks and key risk indicators servicing as an early warning

system. The conclusion of transactions in derivative financial

instruments at NLB is primarily limited to servicing customers

and hedging Bank’s own positions. In the area of currency

risk, the Group thus pursues the goals of low to moderate

exposure. The tolerance for all other risk types, including non-

financial risks, is low with a focus on minimising their possible

impacts on the Group’s operations. ESG risks do not represent

a new risk category, but rather an aggravating factor for the

existing types of risks, such as credit and operational risk. The

Group integrates and manages them within the established

risk managementframework.

The main NLB Group Risk Appetite Statement objectives are

following:

•

preservation of regulatory capital adequacy,

•

preservation of internal capital adequacy,

•fulfilment of the MREL requirement,

•

maintenance of low leverage,

•improvement in the quality of the credit portfolio, sufficient

NPL coverage, sustainable credit risk volatility, sustainable

cost of risk across the economic cycle, sustainable industry

concentration, sustainable exposure to project financing,

•

maintenance of a solid liquidity position, maintaining stable

customers’ deposits as the main funding base,

•

diversification of risk in exposures to banks and

sovereigns,

•

limited exposure to credit spread risk,

•limited exposure to interest rate risk,

•limited exposure to foreign exchange risk,

•sustainable tolerance to net losses from operational risk.

Sustainable ESG financing in accordance with Environmental

and Social Management System (ESMS) will be integrated

in the Group's Risk appetite statement in the year 2022.

Additional key risk indicators and targets in the area of ESG

are going to be addressed based on NLB Group Sustainability

programme and ESMS.

The values of the most important risk appetite indicators

of the Group, as at the end of year 2021, reflecting the

interconnection betweenstrategicbusiness orientations, risk

strategy, and targeted risk appetite profile, were following:

•Total capital ratio 17.8%,

•Tier 1 capital ratio 15.5%,

•Common Equity Tier 1 ratio (CET1) 15.5%,

•Leverage ratio 10.2%,

•Cost of risk -41 bps,

•The share of non-performing exposure (NPE%) by EBA 1.7%,

•Non-performing loans coverage ratio 2 (NPL CR 2) 57.9%,

•Loan-to-deposit ratio (LTD) 60.0%,

•LCR 252.6%,

•NSFR 185.2%,

•EVE sensitivity (of 200 bps) -6.4% of capital,

•Transactional FX risk 1.10% of capital,

•Net losses from operational risk 1.6% of capital requirement

for operational risk.

COVID-19 did not have a meaningful impact on the quality

of the credit portfolio. The Group is compliant with EBA

guidelines on payment moratoria and is very prudent in

identifying any increase in credit risk. The vast schemes

introduced by the governments inthe Groupcountries

providing moratoriums to eligible clients as part of the

COVID-19 pandemic measures had been phasing out during

the 2021. With respect to the COVID-19 pandemic and its

implications on the business environment, the Group faced

growing excess liquidity and managed to stay well capitalised.

Consequently, the Group concluded the year 2021 as self-

funded, with a strong liquidity and solid capital position,

demonstrating the Group’s financial resilience. The acquired

Komercijalna Banka group has a similar business model to

the Group’s, and so, its impact on the Group’s risk profile at

the end of the year 2020 was moderate with no other major

impacts during the year 2021. Otherwise, there were no other

transactions of sufficiently material nature to impact on the

Group’s risk profile or distribution of the risks on the Group

level.

A Condensed Statement of the management of risk is

also published on the Bank’s intranet with the aim of strict

adherence of the Banks’ employees at daily operations of the

Bank, as regards the definition and importance of a consistent

tendency of the adopted risks, and ways to take into account

when adopting its daily business decisions.

Ljubljana, 11 April 2022

Supervisory Board ofNLBManagement Board of NLB

Primož Karpe

Chairman

Archibald Kremser

CFO

Andreas Burkhardt

CRO

Blaž Brodnjak

CEO & CMO

![]()

142

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Statement on Non-

financial Operation

In line with Article 70.c of the Companies Act (ZGD-1),

21

the

Bank reports on non-financial operation separately from the

NLB Group Annual Report 2021. The Bank’s disclosures of non-

financial operation are prepared in NLB Group Sustainability

Report 2021 (

https://www.nlb.si/sustainability

), by applying

the GRI Sustainability Reporting Standards (GRI) and thus

ensuring compliance with the requirements of the regulations

regarding the disclosure of non-financial information.

As part of the NLB Group Sustainability Report 2021, the Bank

publishes UNEP FI PRB Self-Assessment Report on how the

Bank is implementing the UN Principles for Responsible

Banking (UN PRB). The UN PRB set out the banking industry’s

role and responsibility in shaping a sustainable future and in

aligning the banking sector with the objectives of the UN SDGs

and the 2015 Paris Climate Agreement.

Ljubljana, 11 April 2022

21

Official Gazette of the RoS, No. 65/09, 33/11, 91/11, 32/12, 57/12, 44/13 –

Resolution of the Constitutional Court 82/13, 55/15, 15/17, 22/19 – Business

Secret Act, 158/20 – Integrity and Corruption Prevention Act-C and 18/21).

Management Board of NLB

Archibald Kremser

CFO

Andreas Burkhardt

CRO

Blaž Brodnjak

CEO & CMO

![]()

We are attentive to what

you cherish themost.

52 years ago, we celebrated Earth Day for the first time.

40 years ago, we introduced recycling.

2 years ago, we committed to low-carbon economy.

What will the next generations commit to?

The rising importance of environmental and social issues plays an important role in the quality of life in our local

region. By incorporating sustainability in our banking services, we not only strengthen relations with our clients,

employees, suppliers, investors and broader communities, but also take care of present and future generations.

We do not perceive sustainability as merely a letter on a piece of paper, but as a string of decisions, measures

and actions that will provide new opportunities for the generations to follow.

![]()

144

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

rights on the basis of the instructions of an individual third

party for whose account it has acquired the shares if, together

with the instructions for voting, it does not receive a written

guarantee from that person that this person has shares on his

own account and that this person is not, directly or indirectly, a

holder of more than 25% of the Bank’s voting rights.

The acquirer who exceeds the share of 25% of the Bank’s

shares with voting rights, and does not require the issuance

of approval for the transfer of shares, or does not receive the

approval of the Bank, may exercise the voting right from 25%

of the shares with the voting rights.

There are no restrictions other than those mentioned and

those thatare regulatory.

1.3Qualifying holdings

This information is included in the chapter

Corporate

Governance Statement of NLB

.

1.4Securities carrying special controlling rights

This information is included in the chapter

Corporate

Governance Statement of NLB.

1.5The employee share scheme, if used by the

company, for shares to which the scheme

relates and about the method of exercising

control over this scheme, if the controlling

rights are not exercised directly by employees

The Remuneration policy for employees performing special

work defines the payments with financial instruments

according to the applicable banking law, however, there was

no payout in instruments in 2021.

1.6

Explanation regarding restrictions

related to voting rights

This information is included in the chapter

Corporate

Governance Statement of NLB

.

1.7

All agreements among shareholders

which are known to the company and

could result in restrictions relating to the

transfer of securities or voting rights

The Bank is not aware of such agreements.

1.

Informationpursuantto the

Companies Act (ZGD-1), Article 70,

paragraph 6

1.1Structure of the Bank’s share capital

The Bank has issued only ordinary registered no-par value

shares, the holders of which have a voting right and the

right to participate at the General Meeting of the Bank’s

shareholders, the pre-emptive right to subscribe for new

shares in case of a share capital increase, the right to profit

participation (dividends), the right to a share in the surplus in

the event of liquidation or bankruptcy of the Bank, and the

right to be informed. All shares belong to a single class and

are issued in book-entry form.

Information regarding the shareholder structure of NLB (as at

31 December 2021) is available in the subchapter

Shareholder

Structure of NLB

in the chapter

Key Highlights

.

1.2All restrictions relating to the transfer of

shares and the restrictions on voting rights

The shares of the Bank are freely transferable, subject to the

provisions of the Articles of Association of the Bank which require

the approval of the Supervisory Board, namely for the transfer

of shares of the Bank by which the acquirer, together with the

shares held by the holder before such an acquisition and the

shares held by third parties for the account of the acquirer,

exceeds the share of 25% of the Bank’s voting shares. Approval

for the transfer of shares is issued by the Supervisory Board.

The Bank rejects the request for approval of transfer shares

if the acquirer, together with the shares held by the acquirer

before the acquisition and the shares held by third parties for

the account of the acquirer, exceeded the 25% share of the

Bank with voting rights, increased by one share.

Notwithstanding the provision mentioned in the first

paragraph, approval for the transfer of shares is not required

if the acquirer of the shares has acquired them on the account

of third parties, so that it is not entitled to exercise voting

rights from these shares at its sole discretion, while at the

same time committing to the Bank, it will not exercise voting

1.8The company’s rules on the appointment

or replacement of management and

supervisory board members and

changes of the articles of association

This information is included in the chapter

Corporate

Governance Statement of NLB

.

1.9

Authorisations given to management,

particularly authorisations to issue

or purchase own shares

This information is included in the chapter

Corporate

Governance Statement of NLB

.

1.10All major agreements to which the company

is a party and which take effect, are

changed or cancelled following a change

in control over the company resulting from

a bid, as laid down by the Act governing

M&A, and the effects of such agreements

There are no major agreements to which the Bank is a party,

and which would take effect, be changed, or cancelled

following a change in control over the Bank resulting from a

bid.

1.11All agreements between the Bank and its

management or supervision bodies or its

employees which envisage compensation

if, due to a bid as laid down by the Act

governing M&A, these persons resign, are

dismissed without a well-founded reason,

or their employment is terminated

In line with the employment contracts of the members of the

Management Board, in case the Supervisory Board recalls a

member of the Management Board ‘for other business and

economic reasons,’ such a member of the Management Board

of NLB is entitled to compensation for early termination of

his term of office. The member of the Management Board

shall not be entitled to compensation for early termination

of the term of office if he is employed in the Bank or in the

Group after the termination of the term of office. In the event

of resignation, the member of the Management Board shall

Disclosure onShares and Shareholders ofNLB

![]()

145

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

not be entitled to any compensation for early discontinuation

of the term of office, unless otherwise decided by the

Supervisory Board.

2.

Numberof shares held by

members oftheSupervisory

Board and Management Board

Table 40:

Number of shares held by members of the Supervisory Board and

Management Board

Shares held as at

31 December 2021

Name of member of

Supervisory Board

Number%

Primož Karpe1,1360.006%

Andreas Klingen1,1980.006%

David Eric Simon

(i)

5820.003%

Islam Osama Zekry——

Gregor Rok Kastelic——

Shrenik Dhirajlal Davda——

Mark William Lane Richards——

Verica Trstenjak

——

Sergeja Kočar610.000%

Bojana Šteblaj——

Janja Žabjek Dolinšek——

Tadeja Žbontar Rems——

Name of member of

Management Board

Number%

Blaž Brodnjak1,5000.008%

Archibald Kremser7910.004%

Andreas Burkhardt4510.002%

Petr Brunclík

278

0.001%

(i)

David Eric Simon holds 2,910 GDRs, which is equal to 582 shares (as 1 share

represents 5 GDRs).

3.

Stock option agreements

The Bank has no stock option agreements in relation with

listed shares.

4.

Dividendtaxation

Withholding tax

In 2021 a Slovenian payer was required to deduct and withhold

the amount of Slovenian corporate or personal income tax from

dividend payments made to the certain categories of payees:

•Individuals: 27.5%

•Intermediaries: 27.5%

•Legal entities (other than Intermediaries): 15%

In 2022, the tax rate for individuals and intermediaries has

changed from 27.5% to 25%.

There are some exemptions if dividends are

paid to intermediaries and legal entities

For the purposes of Slovenian tax legislation, the GDR

depositary will qualify as an intermediary. Therefore, the

dividends paid by the custodian to the GDR depositary will

be subject to the deduction and withholding of Slovenian

tax at the rate of 25% (in 2021 27.5%). A holder, an owner of a

GDR or a beneficial owner will be entitled, if and to the extent

applicable, to claim a refund of the withholding tax.

In the case of legal entities, the exemptions are related to the

characteristics of thelegal entities.

Application of Double Tax Treaties

If the payee is not an intermediary, Slovenian tax authorities

may approve the application of a lower tax rate specified in

the double tax treaty between the RoS and the country of

residence of the payee if the Slovenian payer provides certain

information on the payee and a confirmation that the payee is

a resident for taxation purposes in such a country, issued by

the tax authorities of such a country.

Refund of Withholding Tax

If the Slovenian tax was deducted and withheld at a higher tax

rate than it would be paid if a Slovenian payer would make the

dividend payment directly to such person as a payee or higher

tax rate, than the one specified in the double tax treaty, the

payee of the dividend is entitled to the refund of the overpaid

tax. The tax refund is enforced by filing a claim to the Financial

Administrationof the RoS.

Legal persons

Dividends with respect to the shares received by a legal

person who is a Slovenian resident are exempt from Slovenian

corporate income tax (

davek oddohodkov pravnih oseb

).

Individuals

The amount of tax withheld from a dividend payment received

by anindividual constitutes the final amount of Slovenian

Personal Income Tax (

dohodnina

) with respect to such a

dividend payment.

![]()

146

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

assessment of the CHF Law and if outlined legal remedies are

unsuccessful, the Bank estimated a negative pre-tax effect on

the operations of NLB and NLB Group should not exceed EUR

70 - 75 million. The Bank considers this as anon-adjusting event

after the reporting period.

New SREP Decision

On 2 February, the ECB issued a new SREP decision for the

Bank under which it has reduced the P2R from 2.75% to 2.60%,

while P2G remains at 1.00%. The new SREP decision applies as

of 1 March. Consequently, the Bank is as of this date required

to maintain the OCR at the level of 14.10% on a consolidated

basis, consisting of (i) 10.60% TSCR, and (ii) 3.5% CBR.

Geopolitical tensions in Ukraine

In February, Russian Federation began a military invasion of

Ukraine. Group has limited exposure to Russian Federation

and Ukraine which mainly derives from NLB’s investment

in Russian sovereign bonds in the approximate amount of

EUR20 million. The manner and timing of their settlement

in the given circumstances is not determined yet. Since the

beginning of the tensions, the credit spreads widening was

observed, which is currently impacting the Bank’s FVOCI

positions. Further information is available in

Note 9

of the

Financial part of this report.

Sberbank banka d.d. acquisition

On 1 March, the Single Resolution Board (SRB) in coordination

with local regulator BoS decided to adopt a resolution scheme

in respect of Slovenian Sberbank banka d.d. (Sberbank).

Resolution scheme envisaged the application of the sale of

business tool for Sberbank and BoS issued a decision for the

sale of 100% shares issued by Sberbank. Under the resolution

scheme, and following a marketing procedure, the SRB has

decided to transfer all the shares issued by the Sberbank to

NLB. Therefore as of 1 March NLB became a 100% owner of

Sberbank. In the following months activities for integration of

Sberbank within NLB Group will be carried out.

Management Board change

On 20 January, the Supervisory Board appointed Hedvika

Usenik, Antonio Argir and AndrejLasič as members of the

Management Board, thus expanding it to six members in total.

Their five-year term of office will start after they have obtained

their respective licences. Until then, they will continue to act as

executive assistants to the Management Board.

Swiss Francs Law adopted

On 2 February, the Slovenian National Assembly adopted

the Law on limitation and distribution of foreign exchange

risk between creditors and borrowers concerning loan

agreements in Swiss francs (CHF Law). The CHF Law affects all

loan agreements denominated in Swiss francs (regardless of

whether the agreements are still in force) concluded between

banks operating in Slovenia (including NLB) as lenders and

individuals as borrowers in the period from 28 June 2004 to 31

December 2010, and provides for a cap on the exchange rate

between Swiss francs and the Euro to be set at 10% volatility

and shall be applied from the conclusion of any of the affected

loan agreements. NLB intends to use all legal remedies against

the CHFLaw before the Constitutional Court and, if necessary,

in front of relevant European forums. In this respect, the

banks (including NLB) on 28 February filed an initiative with

the Constitutional Court of the RoS to initiate proceedings to

assess the constitutionality of the CHF Law and a proposal for

its temporary suspension of enforcement. The Constitutional

Court of the RoS adopted a decision on 10 March to suspend in

whole the implementation of the CHF Law.The implementation

of the law has been suspended until the final decision of the

Constitutional Court on the conformity of the CHFLaw with the

Constitution. During this time the deadlines set for individual

liabilities of the banks do not apply. Until the final decision of

the Constitutional Court on the constitutionality of the CHF Law

is made, the NLB will act in accordance with the applicable

legislation and courts’ decisions, and will, at the same time,

exercise all legal remedies at its disposal. Based on the

Key information of the acquired bank

in EUR million

2020

2021

Unaudited

Income Statement

Net interest income3026

Net fee and commission income1214

Other income-12

Total income4343

Expenses-29-30

Pre-provision income1313

Provisions and impairments-111

Profit before tax113

Profit after tax110

Balance Sheet

Total assets1,8391,721

Loans and advances to customers1,2001,153

Deposits from non-bank customers1,3401,274

Shareholders' equity184195

Ratios

(i)

in %

Net interest margin

(ii)

1.611.49

Business operating margin

(ii)

2.292.49

ROE a.t.0.525.4

NPL ratio

(iii)

5.54.4

CET1 ratio18.818.7

Source:

Sberbank banka d.d. reports: for 2020 Annual report, for 2021 data from Sberbank

banka d.d.

Notes:

(i) Ratios as calculated by Sberbank banka d.d.

(ii) Based on total assets.

(iii) Non-performing loans and other financial assets / classified loans and other

financial assets (excluding balances with central bank accounts and sight deposits

with banks).

Further information about theacquisitionof Sberbankbanka

d.d. is available on the Bank’s website under

Investor News

.

Supervisory and Management board

transactions with NLBR shares

Between 25 February and 23 March, Primož Karpe, President

of the Supervisory Board, Sergeja Kočar, Member of the

Supervisory Board, Blaž Brodnjak, CEO and CMO, and

Andreas Burkhardt, CRO together acquired 468 ordinary

shares of NLB ISIN: SI0021117344, LJSE ticker NLBR.

Notification of major holdings

On 7 March the shareholding of Schroders in the Bank

changed from 5.061% to 4.95%.

Events After the End of the 2021 Financial Year

![]()

147

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Reconciliation ofFinancial Statements in

Business and Financial Part of the Report

Business reportin EUR millionFinancial reportin EUR thousandsNotes

Net interest income409.4

Interest and similar income477,8294.1.

Interest and similar expenses(68,469)4.1.

Net fee and commission income237.2

Fee and commission income332,5894.3.

Fee and commission expenses(95,413)4.3.

Dividend income0.2Dividend income2234.2.

Net income from financial transactions38.4

Gains less losses from financial assets and liabilities not

measured at fair value through profit or loss

167

4.4.

Gains less losses from financial assets and liabilities held for trading21,1944.5.

Gains less losses from non-trading financial assets

mandatorily at fair value through profit or loss

16,8384.6.

Fair value adjustments in hedge accounting

167

5.5.a)

Foreign exchange translation gains less losses3454.7.

Gains less losses from modification of financial assets(263)4.12.

Net other income(18.3)

Gains less losses on derecognition of non-financial assets2,681

Other net operating income23,2214.8.

Cash contributions to resolution funds and deposit guarantee schemes(35,140)4.10.

Gains less losses from non-current assets held for sale

248

4.15.

Net gains or losses on derecognition of investments in

subsidiaries, associates and joint ventures

(9,298)5.12.b)

Net non-interest income257.6257,559

Total net operating income666.9666,919

Employee costs(231.3)

Administrative expenses(368,851)4.9.

Other general and administrative expenses(137.5)

Depreciation and amortisation(46.5)Depreciation and amortisation(46,528)4.11.

Total costs(415.4)(415,379)

Result before impairments and provisions251.5251,540

Impairments and provisions for credit risk35.8

Provisions for credit losses8,5044.13.

Impairment of financial assets27,3314.14.

Other impairments and provisions(27.1)

Provisions for other liabilities and charges(22,670)4.13.

Impairment of non-financial assets(4,407)4.14.

Impairments and provisions8.88,758

Gains less losses from capital investment in

subsidiaries, associates, and joint ventures

1.1

Share of profit from investments in associates and joint

ventures (accounted for using the equity method)

1,1085.12.d)

Result before tax261.4Profit before income tax261,406

Income tax(13.5)Income tax(13,538)4.16.

Result of non-controlling interests11.5Attributable to non-controlling interests11,464

Result after tax236.4Attributable to owners of the parent236,404

Table 41:

Income Statement of NLB Group for the annual period ended 31 December 2021

![]()

148

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Business reportin EUR millionFinancial reportin EUR thousandsNotes

ASSETS

Cash, cash balances at central banks, and

other demand deposits at banks

5,005.1Cash, cash balances at central banks and other demand deposits at banks5,005,0525.1.

Loans to banks140.7Financial assets measured at amortised cost - loans and advances to banks140,6835.6.b)

Net loans to customers10,587.1

Financial assets measured at amortised cost - loans and advances to customers10,587,1215.6.c)

Non-trading financial assets mandatorily at fair value

through profit or loss - part (only loans)

-5.3.a)

Financial assets5,208.35,208,325

- Trading book

7.7Financial assets held for trading7,6785.2.a)

- Non-trading book5,200.6

Non-trading financial assets mandatorily at fair value

through profit or loss - part (without loans)

21,1615.3.a)

Financial assets measured at fair value through other comprehensive income3,461,8605.4.

Financial assets measured at amortised cost - debt securities1,717,6265.6.a)

Investments in subsidiaries, associates, and joint ventures11.5Investments in associates and joint ventures11,5255.12.d)

Property and equipment, investment property294.6

Property and equipment247,0145.8.

Investment property47,6245.9.

Intangible assets59.1Intangible assets59,0765.10.

Other assets271.1

Financial assets measured at amortised cost - other financial assets122,2295.6.d)

Derivatives - hedge accounting5685.5.b)

Fair value changes of the hedged items in portfolio hedge of interest rate risk7,0825.5.c)

Current income tax assets3,948

Deferred income tax assets38,9775.17.

Other assets91,2215.13.

Non-current assets held for sale7,0515.7.

TOTAL ASSETS21,577.5Total assets21,577,496

LIABILITIES

Deposits from customers17,640.8Financial liabilities measured at amortised cost - due to customers17,640,8095.15.a)

Deposits from banks and central banks71.8

Financial liabilities measured at amortised cost -

deposits from banks and central banks

71,8285.15.a)

Borrowings932.6

Financial liabilities measured at amortised cost -

borrowings from banks and central banks

858,5315.15.b)

Financial liabilities measured at amortised cost - borrowings from other customers74,0515.15.b)

Other liabilities427.6

Financial liabilities held for trading7,5855.2.b)

Financial liabilities measured at amortised cost - other financial liabilities206,8785.15.d)

Derivatives - hedge accounting35,3775.5.b)

Provisions119,4045.16.

Current income tax liabilities5,878

Deferred income tax liabilities3,0455.17.

Other liabilities49,4685.19.

Subordinated liabilities288.5Financial liabilities measured at amortised cost - subordinated liabilities288,5195.15.c)

Equity2,078.7Equity and reserves attributable to owners of the parent2,078,733

Non-controlling interests137.4Non-controlling interests137,390

TOTAL LIABILITIES AND EQUITY21,577.5Total liabilities and equity21,577,496

Table 42:

Statement of Financial Position of NLB Group as at 31 December 2021

![]()

149

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Alternative Performance Indicators

The Bank has chosen to present these APIs, either because

they are in common use within the industry or because they

are commonly used by investors and as such are useful

for disclosure. The APIs are used internally to monitor and

manage operations of the Bank and the Group, and are

not considered to be directly comparable with similar KPIs

presented by other companies. The Bank’s APIs are described

below together with definitions.

Cost of risk

– Calculated as the ratio between credit

impairments and provisions annualized from the income

statement and average net loans to customers.

Table 43:

NLB Group cost of risk calculation

(iii)

in EUR million

NLB Group

20212020

Numerator

Credit impairments and provisions

(i)

-40.847.6

Denominator

Average net loans to customers

(ii)

10,080.97,696.1

Cost of risk (bps)-41

62

(i)

NLB internal information. Credit impairments and provisions are annualized,

calculated as all established and released impairments on loans and provisions

for off balance (from the income statement) in the period divided by the number

of months for reporting period and multiplied by 12. The net established Credit

impairments and provisions are shown with a positive sign, and the net released

Credit impairments and provisions are shown with a negative sign.

(ii)

NLB internal information. Average net loans to customers are calculated as sum

of the balance of the previous year end (31 December) and monthly balances of the

last day of each month from January to month t divided by (t+1).

(iii)

Komercijalna Banka group included from 2021 on.

Cost-to-income ratio (CIR)

– Indicator of cost efficiency,

calculated as the ratio between the total costs and total net

operating income.

Table 44a:

NLBGroup and NLBCIR calculation

in EUR million

NLB GroupNLB

202120202019202120202019

Numerator

Total costs415.4293.9305.0183.6180.5191.1

Denominator

Total net operating income666.9504.5517.2361.5311.7354.7

Cost to income ratio (CIR)62.3%58.3%59.0%50.8 %57.9%53.9%

CIR is adjusted for 2019 to changed schemes prescribed by the BoS.

Table 44b:

NLBGroup’s banking subsidiaries CIR calculation

in EUR million

NLB Banka,

Skopje

NLB Banka,

Banja Luka

NLB Banka,

Sarajevo

NLB Banka,

Prishtina

NLB Banka,

Podgorica

NLB Banka,

Beograd

Komercijalna

Banka,

Beograd

2021202020212020202120202021202020212020202120202021

Numerator

Total cost28.626.515.213.916.215.113.512.317.413.622.220.488.0

Denominator

Total net

operating

income

68.462.733.230.128.126.741.838.728.124.330.326.6128.7

Cost to income

ratio (CIR)

41.8%42.3%45.7%46.1%57.7%56.5%32.4%31.8%61.7%56.0%73.1%76.4%68.4%

![]()

150

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Table 45a:

NLB Group Stage 1 calculation

in EUR million

NLB Group

2021

Numerator

Total (AC) loans in Stage 114,638.0

Denominator

Total gross loans and advances15,541.8

IFRS 9 classification into Stage 194.2%

Table 45b:

NLB Group Stage 2 calculation

in EUR million

NLB Group

2021

Numerator

Total (AC) loans in Stage 2532.4

Denominator

Total gross loans and advances15,541.8

IFRS 9 classification into Stage 23.4%

Table 45c:

NLB Group Stage 3 calculation

in EUR million

NLB Group

2021

Numerator

Total (AC) loans in Stage 3371.1

Denominator

Total gross loans and advances15,541.8

IFRS 9 classification into Stage 32.4%

Table 45d:

NLB Group Stage 1 in the Corporate segment calculation

in EUR million

NLB Group

2021

Numerator

Total (AC) loans in Stage 1 to Corporates4,525.5

Denominator

Total gross loans to Corporates5,179.5

Corporates - IFRS 9 classification into Stage 1

87.4%

Table 45e:

NLB Group Stage 2 in the Corporate segment calculation

in EUR million

NLB Group

2021

Numerator

Total (AC) loans in Stage 2 to Corporates412.2

Denominator

Total gross loans to Corporates5,179.5

Corporates - IFRS 9 classification into Stage 2

8.0%

Table 45f:

NLB Group Stage 3 in the Corporate segment calculation

in EUR million

NLB Group

2021

Numerator

Total (AC) loans in Stage 3 to Corporates241.4

Denominator

Total gross loans to Corporates5,179.5

Corporates - IFRS 9 classification into Stage 3

4.7%

Table 45g:

NLB Group Stage 1 in the Retail segment calculation

in EUR million

NLB Group

2021

Numerator

Total (AC) loans in Stage 1 to Retail5,371.1

Denominator

Total gross loans to Retail5,621.1

Retail - IFRS 9 classification into Stage 195.6%

Table 45h:

NLB Group Stage 2 in the Retail segment calculation

in EUR million

NLB Group

2021

Numerator

Total (AC) loans in Stage 2 to Retail120.2

Denominator

Total gross loans to Retail5,621.1

Retail - IFRS 9 classification into Stage 22.1%

Table 45i:

NLB Group Stage 3 in the Retail segment calculation

in EUR million

NLB Group

2021

Numerator

Total (AC) loans in Stage 3 to Retail129.7

Denominator

Total gross loans to Retail5,621.1

Retail - IFRS 9 classification into Stage 32.3%

FVTPL

– Financial assets measured mandatorily at fair

value through profit or loss (FVTPL) represent the minor part

(0.002% December 2021; 0.30% December 2020) of the loan

portfolio (before the deduction of fair value for credit risk;

loans with contractual cash flows that are not solely payments

of principal and interest on the principal amount outstanding).

Classification into stages is calculated in the internal data

source, by which the NLB Group measures the loan portfolio

quality, and which is also published in the Business Report of

Annual and Interim Reports.

IFRS 9 classification into stages for loan portfolio:

IFRS 9 requires an expected loss model, where an allowance

for the expected credit losses (ECL) are formed. Loans

measured at amortised costs (AC) are classified into the

following stages (before deduction of loan loss allowances):

•

Stage 1

– A performing portfolio: no significant increase of

credit risk since initial recognition, NLB Group recognises an

allowance based on a 12-month period;

•

Stage 2

– An underperforming portfolio: a significant

increase in credit risk since initial recognition, NLB Group

recognises an allowance for a lifetime period;

•

Stage 3

– An impaired portfolio: NLB Group recognises

lifetime allowances for these financial assets. The definition

of default is harmonised with the EBA guidelines.

A significant increase in credit risk is assumed: when a credit

ratingsignificantly deteriorates atthe reporting datein

comparison to the credit rating at initial recognition; when a

financial asset has material delays over 30 days (days past

due are also included in the credit rating assessment); if NLB

Group expects to grant the client forbearance or if the client is

placed on the watch list.

![]()

151

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Leverage ratio

– its calculation uses Tier 1 as the numerator,

and the denominator is the total exposure of all active balance

sheet and off-balance-sheet items after the adjustments are

made in the context of which the exposures from individual

derivatives, exposures from transactions of security funding,

and other off-balance sheet items are especially pointed

out. The leverage ratio is a non-risk based supplementary

measure to the risk-based capital requirements. A minimum

leverage ratio requirement is 3%. The purpose of the leverage

ratio is to limit the size of the Bank balance sheets, and with a

special emphasis on exposures which are not weighted within

the framework of the existing capital requirement calculations.

Table 46:

NLB and NLB Group leverage ratio

in EUR million

NLBNLB Group

202120202019202120202019

Numerator

Tier I1,362.71,347.01,137.61,965.61,768.11,451.2

Denominator

Total Leverage Ratio exposure measure10,041.113,058.811,705.219,229.522,603.916,671.3

Leverage ratio13.6%10.3%9.7%10.2%7.8%8.7%

Liquidity coverage ratio

– LCR refers to high liquid assets held

by the financial institution to cover its net liquidity outflows

over a 30-calendar day stress period.

The LCR requires financial institutions to maintain a sufficient

reserve of high-quality liquid assets (HQLA) to withstand a

crisis that puts their cash flows under pressure. The assets

to hold must equal to or greater than their net cash outflow

over a 30-calendar-day stress period (having at least 100%

coverage). The parameters of the stress scenario are defined

under Basel III guidelines. The calculations presented below

are based on internal data sources.

Table 47:

NLB Group LCR calculation

in EUR million

NLB GroupNLB

31 Dec

2021

30 Nov

2021

31 Oct

2021

30 Sep

2021

31 Aug

2021

31 Jul

2021

30 Jun

2021

31 May

2021

30 Apr

2021

31 Mar

2021

29 Feb

2021

31 Jan

2021

31 Dec

2020

31 Dec

2019

31 Dec

2021

31 Dec

2020

31 Dec

2019

Numerator

Stock of HQLA5,367.15,333.45,222.95,285.75,346.85,350.75,452.84,976.04,941.44,915.34,871.55,027.85,003.03,985.04,698.74,323.43,701.3

Denominator

Net liquidity outflow2,125.02,064.71,993.41,940.51,899.71,966.52,000.21,915.81,918.61,876.41,889.01,945.51,943.11,226.41,493.91,285.41,022.1

LCR

252.6%258.3%262.0%272.4%281.4%272.1%272.6%259.7%257.6%262.0%257.9%258.4%257.5%324.9%314.5%336.3%362.1%

Based on the European Commission’s Delegated Act on LCR.

![]()

152

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Net loan-to-deposit ratio (LTD)

– Calculated as the ratio between

net loans to customers and deposits from customers. There is no

regulatory defined limitation on the LTD, however, the aim of this

measure is to restrict extensive growth of the loan portfolio.

Table 48a:

NLB Group and NLB LTD calculation

in EUR million

NLB GroupNLB

31 Dec 202131 Dec 202031 Dec 201931 Dec 202131 Dec 202031 Dec 2019

Numerator

Net loans to customers10,587.19,644.97,604.75,153.04,595.14,589.2

Denominator

Deposits from customers17,640.816,397.211,612.39,659.68,850.87,760.7

Net loan to deposit ratio (LTD)60.0%58.8%65.5%53.3%51.9%59.1%

Table 48b:

NLB Group’s banking subsidiaries LTD calculation

in EUR million

NLB Banka,

Skopje

NLB Banka,

Banja Luka

NLB Banka,

Sarajevo

NLB Banka,

Prishtina

NLB Banka,

Podgorica

NLB Banka,

Beograd

Komercijalna

Banka, Beograd

31 Dec

2021

31 Dec

2020

31 Dec

2021

31 Dec

2020

31 Dec

2021

31 Dec

2020

31 Dec

2021

31 Dec

2020

31 Dec

2021

31 Dec

2020

31 Dec

2021

31 Dec

2020

31 Dec

2021

Numerator

Net loans to customers1,084.1956.9471.1430.7453.0399.2634.5559.2491.6367.3511.7472.21,795.9

Denominator

Deposits from customers1,399.51,288.8759.9633.5593.0521.6798.8748.3609.8431.7449.5496.33,424.6

Net loan to deposit ratio (LTD)77.5%74.2%62.0%68.0%76.4%76.5%79.4%74.7%80.6%85.1%113.8%95.1%52.4%

![]()

153

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Net interest margin on the basis of interest-bearing assets

– Calculated as the ratio between net interest income

annualized and average interest-bearing assets.

in EUR million

NLB Banka,

Skopje

NLB Banka,

Banja Luka

NLB Banka,

Sarajevo

NLB Banka,

Prishtina

NLB Banka,

Podgorica

NLB Banka,

Beograd

Komercijalna

Banka, Beograd

2021202020212020202120202021202020212020202120202021

Numerator

Net interest income

(i)

50.448.120.118.617.817.834.532.322.020.623.421.888.6

Denominator

Average interest bearing assets

(ii)

1,605.31,453.0844.3756.7645.0611.9900.6817.7550.2499.9678.3643.13,742.6

Net interest margin on interest bearing assets3.1%3.3%2.4%2.5%2.8%2.9%3.8%3.9%4.0%4.1%3.4%3.4%2.4%

Net interest margin on the basis of interest-bearing assets

(quarterly)

– Calculated as the ratio between the net interest

income annualized and average interest-bearing assets.

in EUR million

NLB Group

Q4 2021Q3 2021Q2 2021Q1 2021Q4 2020

Numerator

Net interest income

(i)

424.6411.3405.7395.4298.7

Denominator

Average interest bearing assets

(ii)

20,526.720,314.419,459.118,902.814,739.7

Net interest margin on interest bearing assets (quarterly)2.07%2.02%2.08%2.09%2.03%

Table 49:

NLB Group’s banking subsidiaries net interest margin on the basis of interest bearing assets calculation

Table 50:

NLB Group net interest margin on the basis of interest bearing assets calculation (quarterly)

(iii)

(i)

Net interest income is annualized, and calculated as the sum of interest income and interest expenses in the period divided by the number of days in the period and multiplied by the number of days in the year.

(ii)

NLB internal information. Average interest-bearing assets for individual bank members are calculated as the sum of balance of previous year end (31 December) and monthly balances of the last day of each month from January to reporting month t divided by (t+1).

(i)

Net interest income (quarterly) is annualized, calculated as the sum of interest income and interest expenses in the period divided by the number of days in the quarter and

multiplied by the number of days in the year.

(ii)

NLB internal information. Average interest-bearing assets (quarterly) for the NLB Group are calculated as the sum of monthly balances (t) for the corresponding quarter and

monthly balance at the end of the previous quarter divided by (t+1).

(iii)

Komercijalna Banka group included from 2021 on.

Net interest margin on total assets

– Calculated as the ratio between net interest income annualized, and average total assets.

Table 51:

NLB Group and NLB net interest margin on total assets calculation

in EUR million

NLB GroupNLB

202120202019202120202019

Numerator

Net interest income

(i)

409.4299.6318.5139.1138.9158.1

Denominator

Average total assets

(ii)

20,659.015,086.213,311.711,853.910,336.29,206.3

Net interest margin on total assets2.0%2.0%2.4%1.2 %1.3 %1.7 %

(i)

Net interest income is annualized, and calculated as sum of interest income and interest expenses in the period divided by the number of days in the period and multiplied by

the number of days in the year.

(ii)

NLB internal information. Average total assets for the NLB Group are calculated as sum of balance of the previous year end (31 December) and monthly balances of the last

day of each month from January to month t divided by (t+1). Average total assets for NLB are calculated as the sum of total assets of the previous year end (31 December) and

daily balances in the period (from 1 January to day d – the last day in reporting month) divided by (d+1).

![]()

154

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

NPE

– NPE includes risk exposure to D- and E-rated clients

(includes loans and advances, debt securities, and off-balance

exposures, which are included in report Finrep 18; before

the deduction of allowances for the ECL). Non-performing

exposures measured by fair value loans through P&L (FVTPL)

are taken into account at fair value increased by the amount

of negative fair changes for credit risk.

NPE per cent.

(on-balance and off-balance)/Classified

on-balance and off-balance exposures – NPE per cent. in

accordance with EBA methodology: NPE as a percentage

NPE

– NPE indicator according to the BoS calculation

differs from the EBA methodology in the treatment of debt

instruments measured at FVOCI. The carrying amount of

debt instruments measured at FVOCI is increased by value

adjustments due to impairments.

Table 53:

NLB and NLB Group NPE (Eba def.) (Bos) calculation

in EUR million

NLBNLB Group

202120202019202120202019

Numerator

Total Non-Performing on-balance and

off-balance Exposure in Finrep18

159.5235.1221.0415.5513.0432.7

Denominator

Total on-balance and off-balance

exposures in Finrep18, where carrying

amount of FVOCI is increased by value

adjustments due to impairments

13,872.112,225.511,089.524,339.222,051.016,233.3

NPE per cent.1.1%1.9%2.0%1.7%2.3%2.7%

Table 52:

NLBand NLBGroup NPE (Eba def.) calculation

in EUR million

NLBNLB Group

202120202019202120202019

Numerator

Total Non-Performing on-balance and

off-balance Exposure in Finrep18

159.5235.1221.0415.5513.0432.7

Denominator

Total on-balance and off-balance

exposures in Finrep18

13,869.912,223.111,087.824,328.022,042.316,228.5

NPE per cent.1.1%1.9%2.0%1.7%2.3%2.7%

of all exposures to clients in Finrep18, before deduction of

allowances for the ECL; the ratio is in gross terms.

Where Non-Performing Exposure includes risk exposure to

D- and E-rated clients (includes loans and advances, debt

securities, and off-balance exposures, which are included

in report Finrep 18; before the deduction of allowances for

the ECL). The share of NPEs is calculated on the basis of an

internal data source, with which the NLB Group monitors the

portfolio quality. The calculations presented below are based

on internal data sources.

![]()

155

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

NPL

– Non-performing loans include loans to D- and E-rated

clients, namely loans at least 90 days past due, or loans

unlikely to be repaid without recourse to collateral (before

deduction of loan loss allowances).

NPL per cent.

– The share of non-performing loans in total

loans: non-performing loans as a percentage of total loans

to clients before deduction of loan loss allowances; ratio in

gross terms. Where non-performing loans are defined as

loans to D- and E-rated clients, namely loans at least 90 days

past due, or loans unlikely to be repaid without recourse to

collateral (before deduction of loan loss allowances). The

share of non-performing loans is calculated on the basis of an

internal data source, with which the NLB Group monitors the

loan portfolioquality.

Table 54a:

NLB NPL calculation

in EUR million

NLB

202120202019

Numerator

Total Non-Performing Loans130.4208.4169.5

Denominator

Total gross loans8,522.56,980.85,989.9

NPL per cent.1.5%3.0%2.8%

Table 54b:

NLB Group NPL calculation

in EUR million

NLB Group

202120202019201820172016

Numerator

Total Non-Performing Loans367.4474.7374.7622.3844.51,299.2

Denominator

Total gross loans15,541.813,686.69,793.59,017.29,130.49,443.7

NPL per cent.2.4%3.5%3.8%6.9%9.2%13.8%

Table 54c:

NLB Group’s banking subsidiaries NPL calculation

in EUR million

NLB Banka,

Skopje

NLB Banka,

Banja Luka

NLB Banka,

Sarajevo

NLB Banka,

Prishtina

NLB Banka,

Podgorica

NLB Banka,

Beograd

Komercijalna

Banka, Beograd

NLB Group’s

banking

subsidiaries

20212020

202120202021

20202021

20202021

202020212020

2021

2021

Numerator

Total Non-

Performing Loans

59.763.29.413.719.024.715.617.542.227.39.58.736.3322.1

Denominator

Total gross loans1,383.81,239.1734.7590.2621.0553.4802.0768.2602.0470.0618.1605.52,610.115,894.4

NPL per cent.4.3%5.1%1.3%2.3%3.1%4.5%1.9%2.3%7.0%5.8%1.5%1.4%1.4%2.0%

![]()

156

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

NPL coverage ratio 1

– The coverage of the gross non-

performing loans portfolio with loan loss allowances on the

entire loan portfolio - loan impairment in respect of non-

performing loans. It shows the level of credit provisions that the

entity has already absorbed into its profit and loss accounts

with respect to the total of impaired loans. The NPL coverage

ratio 1 is calculated on the basis of an internal data source, with

which the NLB Group monitors the quality of loan portfolio.

Table 55a:

NLB NPL coverage ratio 1 calculation

in EUR million

NLB

202120202019

Numerator

Loan loss allowances

entire loan portfolio

97.9158.4129.2

Denominator

Total Non-Performing Loans130.4208.4169.5

NPL coverage ratio 1 (NPLCR 1)75.1%76.0%76.2%

Table 55b:

NLB Group NPL coverage ratio 1 calculation

in EUR million

NLB Group

202120202019201820172016

Numerator

Loan loss allowances

entire loan portfolio

316.5388.4334.2479.6654.8988.7

Denominator

Total Non-Performing Loans367.4474.7374.7622.3844.51,299.2

NPL coverage ratio 1 (NPLCR 1)86.1%81.8%89.2%77.1%77.5%76.1%

Table 55c:

NLB Group's banking subsidiaries NPL coverage ratio 1 calculation

in EUR million

NLB Banka,

Skopje

NLB Banka,

Banja Luka

NLB Banka,

Sarajevo

NLB Banka,

Prishtina

NLB Banka,

Podgorica

NLB Banka,

Beograd

Komercijalna Banka,

Beograd

NLB Group’s banking

subsidiaries

2021

Numerator

Loan loss allowances

entire loan portfolio

60.517.720.338.022.88.923.1289.0

Denominator

Total Non-Performing Loans59.79.419.015.642.29.536.3322.1

NPL coverage ratio 1 (NPLCR 1)101.2%189.3%106.3%243.2%54.0%93.4%63.5%89.7%

![]()

157

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

NPL coverage ratio 2

– The coverage of the gross non-

performing loans portfolio with loan loss allowances on the

non-performing loans portfolio. The NPL coverage ratio 2 is

calculated on the basis of an internal data source, with which

the NLB Group monitors the loan portfolio quality.

Table 56a:

NLB and NLB Group NPL coverage ratio 2 calculation

in EUR million

NLBNLB Group

202120202019202120202019

Numerator

Loan loss allowances non-performing loan portfolio79.0120.796.2212.9272.1243.7

Denominator

Total Non-Performing Loans130.4208.4169.5367.4474.7374.7

NPL coverage ratio 2 (NPLCR 2)60.6%57.9%56.7%57.9%57.3%65.0%

Table 56b:

NLB Group’sbanking subsidiaries NPL coverage ratio 2 calculation

in EUR million

NLB Banka,

Skopje

NLB Banka,

Banja Luka

NLB Banka,

Sarajevo

NLB Banka,

Prishtina

NLB Banka,

Podgorica

NLB Banka,

Beograd

Komercijalna

Banka, Beograd

NLB Group’s

banking

subsidiaries

2021

Numerator

Loan loss allowances non-performing loan portfolio38.75.716.714.316.55.57.9184.2

Denominator

Total Non-Performing Loans59.79.419.015.642.29.536.3322.1

NPL coverage ratio 2 (NPLCR 2)64.7%61.0%87.6%91.6%39.1%57.6%21.7%57.2%

![]()

158

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Net NPL Ratio

– The share of net non-performing loans in

total net loans: non-performing loans after deduction of

loss allowances on the non-performing loans portfolio as

a percentage of total loans to clients after the deduction of

loan loss allowances; the ratio is in net terms.

The calculations

presented below are based on internal data sources.

Table 57:

NLB and NLB Group Net NPL Ratio calculation

in EUR million

NLBNLB Group

202120202019202120202019

Numerator

Net volume of non-performing loans51.487.873.3154.5202.7131.0

Denominator

Total Net Loans8,424.76,822.45,860.715,225.413,298.29,459.2

Net NPL ratio per cent. (%Net NPL)0.6%1.3%1.3%1.0%1.5%1.4%

Receivedcollaterals for NPLs/NPL

– The coverage of the

gross non-performing loans portfolio with collateral for non-

performing loans. The collateral market value is used for this

calculation. The calculations presented below are based on

internal data sources.

Table 58:

NLB and NLBGroup Received collaterals forNPLs/NPL calculation

in EUR million

NLBNLB Group

202120202019202120202019

Numerator

Gross volume of Non-Performing

Loans covered by collaterals

78.2137.2122.1226.6288.1249.7

Denominator

Total Non-Performing Loans130.4208.4169.5367.4474.7374.7

Received collaterals for NPLs / NPL60.0%65.8%72.0%61.7%60.7%66.6%

![]()

159

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Non-performing loans and advances(EBA def.)

– Non-

performing loans include loans and advances in accordance

with EBA Methodology that are classified as to D and E,

namely loans at least 90 days past due, or loans unlikely to be

repaid without recourse to collateral (before deduction of loan

loss allowances).

Gross NPL ratio

(EBA def.)

– The gross NPL ratio is the

ratio of the gross carrying amount of non-performing loans

and advances to the total gross carrying amount of loans

and advances, in accordance with the EBA methodology

(report Finrep18). For the purpose of this calculation, loans

and advances classified as held for sale, cash balances at

CBs, and other demand deposits are excluded from both the

denominator and the numerator. The calculations presented

below are based on internal data sources.

Table 59:

NLB and NLB Group Gross NPL ratio (EBA def.) calculation

in EUR million

NLBNLB Group

202120202019202120202019

Numerator

Gross volume of Non-Performing Loans and

advances without loans held for sale, cash

balances at CBs and other demand deposits

131.2199.1164.3375.1466.0372.9

Denominator

Gross volume of Loans and advances in Finrep18

without loans held for sale, cash balances

at CBs and other demand deposits

5,498.94,958.84,923.311,128.810,340.68,127.5

Gross NPL ratio per cent. (% NPL)2.4%4.0%3.3%3.4%4.5%4.6%

Gross NPL ratio (EBA def.) (BoS)

–

The gross NPL ratio is the

ratio of the gross carrying amount of non-performing loans

and advances to the total gross carrying amount of loans and

advances, in accordance with the EBA methodology (report

Finrep18). Cash balances at CBs and other demand deposits

are included in the calculation.The indicator for the banking

sector in the EU is published quarterly by the EBA in the Risk

dashboard.

The calculations presented below are based on

internal data sources.

Table 60:

NLB and NLB Group Gross NPL ratio (EBA def.) (BoS) calculation

in EUR million

NLBNLB Group

202120202019202120202019

Numerator

Gross volume of Non-Performing Loans and advances131.2199.1164.3375.1466.0372.9

Denominator

Gross volume of Loans and advances in Finrep188,615.37,028.26,050.915,668.813,795.39,888.1

Gross NPL ratio per cent. (% NPL)1.5%2.8%2.7%2.4%3.4%3.8%

![]()

160

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

NPL coverage ratio (EBA def.)

– The NPL coverage ratio is

the ratio of theamount ofaccumulatedimpairment, negative

changes in fair value due to credit risk to the non-performing

loans and advances, in accordance with the EBA methodology

(report Finrep18). Loans and advances classified as held for

sale, cash balances at CBs and other demand deposits are

excluded both from the denominator and from the numerator.

Table 61:

NLB and NLB Group NPL coverage ratio (EBA def.) calculation

in EUR million

NLBNLB Group

202120202019202120202019

Numerator

Volume of allowances and value adjustments for credit

losses on Non-Performing loans and advances

(i)

79.8110.191.2219.1265.3240.4

Denominator

Gross volume of Non-Performing loans and advances

(i)

131.2199.1164.3375.1466.0372.9

NPL coverage ratio per cent. (% CR)60.8%55.3%55.5%58.4%56.9%64.5%

NPL coverage ratio (EBA def.) (BoS)

–The NPL coverage

ratio is the ratio of the amount of accumulated impairment,

negative changes in fair value due to credit risk to the non-

performing loans and advances, in accordance with the EBA

methodology (report Finrep18). Cash balances at CBs and

other demand deposits are included in the calculation.

Table 62:

NLB and NLB Group NPL coverage ratio (EBA def.) (BoS) calculation

in EUR million

NLBNLB Group

202120202019202120202019

Numerator

Volume of allowances and value adjustments for credit

losses on Non-Performing loans and advances

79.8110.191.2219.1265.3240.4

Denominator

Gross volume of Non-Performing loans and advances131.2199.1164.3375.1466.0372.9

NPL coverage ratio per cent. (% CR)60.8%55.3%55.5%58.4%56.9%64.5%

(i)

Without loans and advances classified as held for sale, cash balances at CBs, and other demand deposits.

![]()

161

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Collateral received/NPL (EBA def.)

– The NPL collateral ratio

is the ratio of the collateral received for non-performing loans

and advances to the gross carrying amount of collateralized

non-performing loans and advances, in accordance with

the EBA methodology (report Finrep18). The calculation is

provided on single loan basis. The NPLs where the amount of

collateral received exceeds the net non-performing of each

loan exposure are the subject of calculation.

Table 63:

NLB and NLB Group NPL coverage ratio (EBA def.) calculation

in EUR million

NLBNLB Group

202120202019202120202019

Numerator

Volume of collateral received up to the carrying

amount of each loan or advance

12.238.612.936.761.323.9

Denominator

Gross volume of collateralized Non-

Performing loans and advances

19.488.838.262.5144.667.4

NPL coverage ratio per cent. (% CR)63.1%43.5%33.6%58.8%42.4%35.4%

Net stable funding ratio (NSFR)

– The net stable funding ratio

is a liquidity risk standard requiring financial institutions to

hold enough stable funding to cover the duration of their long-

term assets.

NSFR is defined as the amount of available stable funding

relative to the amount of required stable funding, and is

based on the current Basel Committee guidelines. This ratio

should be equal to at least 100% on an on-going basis.

‘Available stable funding’ is defined as the portion of capital

and liabilities expected to be reliable over the time horizon

considered by the NSFR, which extends to one year. The

amount of such stable funding required of a specific institution

is a function of the liquidity characteristics and residual

maturities of the various assets held by that institution, as

well as those of its off-balance-sheet (OBS) exposures. The

calculations presented below are based on internal data

sources.

Table 64:

NLB Group NSFR calculation

in EUR million

NLBNLB Group

31 Dec 202131 Dec 202031 Dec 201931 Dec 202131 Dec 202031 Dec 2019

Numerator

Amount of available stable funding10,815.89,455.78,251.618,446.716,514.611,957.9

Denominator

Amount of required stable funding6,309.55,833.75,193.99,960.89,966.87,495.5

NSFR171.4%162.1%158.9%185.2%165.7%159.5%

![]()

162

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

EVE (Economic Value of Equity) method

– EVE method is a

measure of sensitivity of changes in market interest rates on

the economic value of financial instruments. EVE represents

the present value of net future cash flows and provides a

comprehensive view of the possible long-term effects of

changing interest rates at least under the six prescribed

standardised interest rate shock scenarios or more if

necessary, according to the situation on financial markets.

Calculations take into account behavioural andautomatic

options, as well as the allocation of non-maturing deposits.

The assessment of the impact of a change in interest rates of

200 bps on the economic value of the banking book position:

Table 65:

NLB Group EVE calculation

in EUR thousand

NLB Group

31 Dec 202130 Sep 2021

30 Jun 2021

31 Mar 202131 Dec 202030 Sep 2020

30 Jun 2020

31 Mar 202031 Dec 201930 Sep 2019

30 Jun 2019

31 Mar 201931 Dec 2018

Numerator

Interest risk in banking book – EVE-126,651-135,133-134,173-140,567-128,370-98,185-59,547-68,129-88,355-102,319-77,841-105,256-102,397

Denominator

Equity (Tier I)1,972,4851,903,8001,879,3651,734,5451,765,0001,622,9451,616,9211,426,9361,451,1761,424,0201,425,2981,460,0781,458,318

EVE as % of Equity-6.4%-7.1%-7.1%-8.1%-7.3%-6.1%-3.7%-4.8%-6.1%-7.2%-5.5%-7.2%-7.0%

Operational business margin (OBM)

– Calculated as the ratio

between operational business net income annualized and

average assets.

Table 66:

NLB Group and NLBOBM calculation

in EUR million

NLB GroupNLB

202120202019202120202019

Numerator

Operational business net income

(i)

678.1490.3502.1274.3257.7268.6

Denominator

Average total assets

(ii)

20,659.015,086.213,311.711,876.010,336.39,215.3

OBM (cumulative)3.3%3.2%3.8%2.3%2.5%2.9%

(i)

Operational business net income is annualized, and calculated as operational business income in the period divided by the number of days in the period and multiplied by the

number of days in the year. Operational business income consists of net interest income (excluding interest expenses from subordinated securities), net fees and commissions

and net gains and losses from financial assets and liabilities held for trading that derive from foreign exchange trading.

(ii)

NLB internal information. Average total assets is calculated as a sum of balance as at the end of the previous year end (31 December) and monthly balances of the last day of

each month from January to month t divided by (t+1).

![]()

163

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Operational business margin (OBM) (quarterly)

– Calculated

as the ratio between operational business net income

annualized and average assets.

Table 67:

NLBGroup OBM (quarterly) calculation

(iii)

in EUR million

NLB Group

Q4 2021Q3 2021Q2 2021Q1 2021Q4 2020

Numerator

Operational business net income

(i)

718.0675.1676.3642.1499.8

Denominator

Average total assets

(ii)

21,414.521,232.120,357.019,749.015,378.5

OBM (quarterly)3.35%3.18%3.32%3.25%3.25%

(i)

Operational business net income (quarterly) is annualized, and calculated as operational business income in the period divided by the number of days in the quarter and

multiplied by the number of days in the year. Operational business income consists of net interest income (excluding interest expenses from subordinated securities), net fees and

commissions and net gains and losses from financial assets and liabilities held for trading that derive from foreign exchange trading.

(ii)

NLB internal information. Average total assets is calculated as a sum of balance as at the end of the previous year end (31 December) and monthly balances of the last day of

each month from January to month t divided by (t+1).

(iii)

Komercijalna Banka group included from 2021 on.

Return on equity before tax (ROE b.t.)

– Calculated as the ratio

between result before tax annualized and average total equity

(including non-controlling interests).

Table 68:

NLB Group and NLB ROE b.t. calculation

in EUR million

NLB GroupNLB

202120202019202120202019

Numerator

Result before tax

(i)

261.4277.9215.4211.5113.9177.7

Denominator

Average total equity

(ii)

2,222.81,808.11,700.71,507.21,384.61,328.7

ROE b.t.11.8%15.4%12.7%14.0%8.2%13.4%

(i)

The result before tax is annualized, and calculated as the result before tax in the period divided by the number of months for the reporting period and multiplied by 12.

(ii)

NLB internal information. Average total equity (including non-controlling interests) is calculated as the sum of the balance as at end of the previous year end (31 December) and

monthly balances of the last day of each month from January to month t divided by (t+1).

![]()

164

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Return on equity after tax (ROE a.t.)

–

Calculated as the ratio

between result after tax annualized and average equity.

Table 69a:

NLB Group and NLB ROE a.t. calculation

in EUR million

NLB GroupNLB

20212020201920182017202120202019

Numerator

Result after tax

(i)

236.4269.7193.6203.6225.1208.4114.0176.1

Denominator

Average equity

(ii)

2,069.91,751.21,658.01,729.91,566.71,507.21,384.61,328.7

ROE a.t.11.4%15.4%11.7%11.8%14.4%13.8%8.2%13.3%

(i)

The result after tax is annualized, and calculated as the result after tax in the period divided by the number of months for the reporting period and multiplied by 12.

(ii)

NLB internal information. Average equity is calculated as the sum of the balance as at the end of the previous year end (31 December) and monthly balances of the last day of

each month from January to month tdivided by (t+1).

Table 69b:

NLB Group (w/o Komercijalna Banka group) ROE a.t. calculation

in EUR million

NLB Group (w/o Komercijalna Banka group)

2020

Numerator

Result after tax

(i)

141.3

Denominator

Average equity

(ii)

1,741.1

ROE a.t.8.1%

(i)(ii)

Please refer to the notes under Table 69a.

Table 69c:

NLB Group’s banking subsidiaries ROE a.t.calculation

in EUR million

NLB Banka, SkopjeNLB Banka, Banja LukaNLB Banka, SarajevoNLB Banka, PrishtinaNLB Banka, PodgoricaNLB Banka, Beograd

Komercijalna

Banka, Beograd

2021202020212020202120202021202020212020202120202021

Numerator

Result after tax

(i)

39.019.218.210.110.05.924.413.310.11.44.32.634.8

Denominator

Average equity

(ii)

245.4219.4106.793.393.584.3108.992.176.568.277.474.2630.2

ROE a.t.15.9%8.8%17.0%10.8%10.7%7.0%22.4%14.5%13.1%2.0%5.5%3.5%5.5%

(i)(ii)

Please refer to the notes under Table 69a.

![]()

165

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Return on assets (ROA b.t.)

– Calculated as the ratio between

result before tax annualized and average total assets.

Table 70:

NLB Group and NLB ROA b.t. calculation

in EUR million

NLB GroupNLB

202120202019202120202019

Numerator

Result before tax

(i)

261.4277.9215.4211.5113.9177.7

Denominator

Average total assets

(ii)

20,659.015,086.213,311.711,876.010,336.39,215.3

ROA b.t.1.3%1.8%1.6%1.8%1.1%1.9%

(i)

The result before tax is annualized, and calculated as the result before tax in the period divided by the number of months for the reporting period and multiplied by 12.

(ii)

NLB internal information. Average total assets is calculated as the sum of the balance as at the end of the previous year end (31 December) and the monthly balances of the

last day of each month from January to month t divided by (t+1).

Return on assets (ROA a.t.)

– Calculated as the ratio between

result after tax annualized and average total assets.

Table 71a:

NLB Group and NLB ROA a.t. calculation

in EUR million

NLB GroupNLB

202120202019202120202019

Numerator

Result after tax

(i)

236.4269.7193.6208.4114.0176.1

Denominator

Average total assets

(ii)

20,659.015,086.213,311.711,876.010,336.39,215.3

ROA a.t.1.1%1.8%1.5%1.8%1.1%1.9%

(i)

The result after tax is annualized, and calculated as the result after tax in the period divided by the number of months for the reporting period and multiplied by 12.

(ii)

NLB internal information. Average total assets is calculated as the sum of balance as at the end of the previous yearend (31 December) and monthly balances of the last day of

each month from January to month t divided by (t+1).

Table 71b:

NLBGroup’s banking subsidiaries ROAa.t.calculation

in EUR million

NLB Banka,

Skopje

NLB Banka,

Banja Luka

NLB Banka,

Sarajevo

NLB Banka,

Prishtina

NLB Banka,

Podgorica

NLB Banka,

Beograd

Komercijalna

Banka, Beograd

2021202020212020202120202021202020212020202120202021

Numerator

Result after tax

(i)

39.019.218.210.110.05.924.413.310.11.44.32.634.8

Denominator

Average total assets

(ii)

1,658.61,507.2874.5784.9673.5639.3906.0824.9593.5541.0696.3662.84,029.4

ROA a.t.2.4%1.3%2.1%1.3%1.5%0.9%2.7%1.6%1.7%0.3%0.6%0.4%0.9%

(i)(ii)

Please refer to the notes under Table 71a.

![]()

166

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Total capital ratio (TCR)

– TCR is the own funds of the

institution expressed as a percentage of the total risk

exposure amount.

Table 72a:

NLBGroup and NLBTCR calculation

in EUR million

NLB GroupNLB

31 Dec 202131 Dec 202031 Dec 201931 Dec 202131 Dec 202031 Dec 2019

Numerator

Total capital (Own funds)2,252.52,065.51,495.81,647.31,631.61,182.2

Denominator

Total risk exposure Amount (Total RWA)12,667.412,421.09,185.56,708.56,028.85,225.1

Total capital ratio17.8%16.6%16.3%24.6%27.1%22.6%

Table 72b:

NLBGroup’s banking subsidiaries TCR calculation

in EUR million

NLB Banka,

Skopje

NLB Banka,

Banja Luka

NLB Banka,

Sarajevo

NLB Banka,

Prishtina

NLB Banka,

Podgorica

NLB Banka,

Beograd

Komercijalna

Banka, Beograd

31 Dec

2021

31 Dec

2020

31 Dec

2021

31 Dec

2020

31 Dec

2021

31 Dec

2020

31 Dec

2021

31 Dec

2020

31 Dec

2021

31 Dec

2020

31 Dec

2021

31 Dec

2020

31 Dec

2021

Numerator

Total capital243.6190.677.178.475.074.6112.3103.270.052.187.784.5555.8

Denominator

Total risk exposure Amount (Total RWA)1,354.41,212.5456.7452.3445.0416.4647.9579.7429.3321.5456.3443.11,946.7

Total capital ratio18.0%15.7%16.9%17.3%16.9%17.9%17.3%17.8%16.3%16.2%19.2%19.1%28.6%

![]()

167

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

NLB GroupChart

CompaniesCompaniesFinancial institutionsFinancial institutions

SloveniaSloveniaSloveniaSlovenia

Nova Ljubljanska banka d.d., Ljubljana

CORE MEMBERSNON-CORE MEMBERS

Banks

Foreign countries

Foreign countriesForeign countries

NLB Banka, Beograd

100%

100%

NLB InterFinanz, Zürich in

liquidation

100%100%

NLB InterFinanz, Beograd in

liquidation

100%

100%

NLB Leasing, Beograd in

liquidation

100%

100%

LHB AG, Frankfurt

100%

100%

REAM, Beograd

100%

100%

REAM, Podgorica

100%

100%

Tara Hotel, Budva

12.71%

100%

SPV 2, Beograd

100%

100%

NLB Srbija, Beograd

100%

100%

NLB Crna Gora, Podgorica

100%

100%

NLB Skladi, Ljubljana

100%

100%

Bankart, Ljubljana

(ii)

45.64%

45.64%

NLB Banka, Sarajevo

97.35%

97.35%

NLB Lease&Go, Ljubljana

100%

100%

NLB Cultural Heritage

Management Institute

100%

100%

NLB Banka, Podgorica

(iii)

75.90%

99.87%

NLB Banka, Prishtina

82.377%

82.377%

NLB Banka, Banja Luka

99.85%

99.85%

NLB Banka, Skopje

86.97%

86.97%

Komercijalna Banka,

Beograd

88.28%

88.28%

NLB Leasing Ljubljana-

in liquidation

(iv)

100%

100%

Prvi faktor, Ljubljana in

liquidation

50%

50%

PRO-REM, Ljubljana in

liquidation

100%

100%

S-REAM, Ljubljana

100%

100%

ARG-Nepremičnine, Horjul

75%

75%

KomBank Invest, Beograd

100%

100%

Optima Leasing, Zagreb in

liquidation

100%

100%

Prvi faktor, Beograd in

liquidation

(i)

90%

95%

Prvi faktor, Zagreb in

liquidation

100%

100%

OL Nekretnine, Zagreb in

liquidation

100%

100%

REAM, Zagreb

100%

100%

Subsidiary

% direct share

% indirect share at the

group level

Associate

% direct share

% indirect share at the

group level

Joint venture

% direct share

% indirect share at the

group level

Legend:

The chart shows voting rights shares.The Group includes entities according to the definition in the Financial Conglomerates Act (Article 2).

Notes:

(i)

90% direct ownership Prvi Faktor, Ljubljana in liquidation, 5% NLB, 5% SID banka d.d.

(ii)

Abanka merged into Nova KBM, which currently has a 29.22% share in Bankart. This is over the 25% threshhold set in the Founding

agreement - no shareholder other than NLB can have more than 25% capital share in Bankart.

(iii)

75.90% direct ownership NLB; 23.97% Komercijalna Banka, Beograd.

(iv)

100% direct ownership NLB Lease&Go d.o.o., Ljubljana

![]()

168

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Understanding of the tasks and responsibilities of Global Risk, Compliance and

Integrity and Internal Audit is taken into account in accordance to the definitions of

the (currently valid) Banking Act (ZBan-3).

(i)

Worker´s Council is independent organisational unit with no subordinate or

superior organisational units and it operates in accordance with ZSDU.

Organisational Structure of NLB

SUPERVISORY BOARD

MANAGEMENT BOARD

Internal Audit

Worker´s Council

(i)

Compliance and IntegrityStrategy and Business Development

Global Risk

Credit Risk - Corporate

Credit Risk - Retail

Evaluation and Control

Restructuring

Workout and Legal support

Group Real Estate ManagementSales Development and Management

ControllingCSA & Cross-border Financing

Financial Accounting and AdministrationLarge Corporates

Financial MarketsSmall and Mid Corporates

Trade Finance Services

Investment Banking and Custody

Private Banking

KC 24/7

Area Branch Ljubljana

Area Branch Northwest and Central Slovenia

Area Branch Northeast Slovenia

Area Branch Southeast Slovenia

Area Branch Southwest Slovenia

Micro Enterprises

Mobile Banking

IT Architecture

IT Delivery

Data Management

IT Shared Service Centre

NLB Group ITSecurity Governance

IT Infrastructure

Procurement

Payments Processing

Cash Processing

Financial Instruments Processing

Corporate Customer Delivery

Retail Banking Processing

Distribution Network

CRO

CFO

CMO

COO

Group SteeringLegal and Secretariat

Communication

Human Resources and Organization Development

![]()

We believe you deserve

every opportunity.

First, we liked your résumé.

Then, you fascinated us with your enthusiasm.

After that, we saw great potential in you.

Now, we will make sure you utilise it to the fullest.

We believe that a satisfied and efficient employee is one who successfully aligns their private and professional life,

while at the same time preserves the feeling that their potential is recognised and respected.With intensive investments

into the upgrading of the potential of our employees, we have raised a company of enthusiastic experts from across

the region who firmly believe in their work and mission. Just like Nino, Ljubica and Matej from our Ljubljana IT office.

![]()

170

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

FINANCIALREPORT

![]()

171

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Independent auditor’s report

............................

173

Statement of management’s responsibility

..............

177

Statement of comprehensive income

for the annual period ended 31 December

................

179

Statement of financial position as at 31 December

........

180

Statement of changes in equity

for the annual period ended 31 December

................

182

Statement of cash flows

for the annual period ended 31 December

................

184

Notes to the financial statements

.........................

186

1.General information

...............................

186

2.Summary of significant accounting policies

........

186

2.1.Statement of compliance

............................

186

2.2.Basis for presenting the financial statements . . . . . . . .

186

2.3.Comparative amounts

...............................

186

2.4. Consolidation

........................................

187

2.5.Business combinations, goodwill,

and bargain purchases

..............................

187

2.6.Investments in subsidiaries,

associates and joint ventures

........................

188

2.7.A combination of entities or

businesses under common control

..................

188

2.8.Foreign currency translation

........................

188

2.9.Interest income and expenses

.......................

188

2.10.Fee and commission income

........................

189

2.11.Dividend income

.....................................

189

2.12.Financial instruments

...............................

189

2.13.Allowances for financial assets

......................

192

2.14.Forborne loans

......................................

194

2.15.Repossessed assets

.................................

195

2.16. Offsetting

............................................

195

2.17.Sale and repurchase agreements

...................

195

2.18.Property and equipment

.............................

195

2.19.Intangible assets

.....................................

195

2.20.Investment properties

...............................

196

2.21.Non-current assets and disposal

groups classified as held for sale

....................

196

2.22.Accounting for leases

................................

196

2.23.Cash and cash equivalents

..........................

197

2.24.Borrowings, deposits, and issued

debt securities with characteristics of debt

..........

197

2.25.Other issued financial instruments

with characteristics of equity

........................

197

2.26. Provisions

...........................................

197

2.27.Contingent liabilities and commitments

..............

197

2.28. Taxes

................................................

197

2.29.Fiduciary activities

...................................

198

2.30.Employee benefits

...................................

198

2.31.Share capital

........................................

198

2.32.Segment reporting

..................................

198

2.33.Critical accounting estimates and

judgments in applying accounting policies

..........

199

2.34.Implementation of the new and revised

International Financial Reporting Standards

........

201

3.Changes in the composition oftheNLB Group

.....

203

4.Notes to the income statement

....................

204

4.1.Interest income and expenses

......................

204

4.2.Dividend income

....................................

205

4.3.Fee and commission income and expenses

.........

205

4.4.Gains less losses from financial assets

and liabilities not measured at fair value

through profit or loss

...............................

207

4.5.Gains less losses from financial assets

and liabilities held for trading

.......................

207

4.6.Gains less losses from non-trading

financial assets mandatorily at fair value

through profit or loss

...............................

208

4.7.Foreign exchange translation gains less losses

.....

208

4.8.Other net operating income

........................

209

4.9.Administrative expenses

.............................

210

4.10.Cash contributions to resolution funds

and deposit guarantee schemes

......................

211

4.11.Depreciation and amortisation

.......................

211

4.12.Gains less losses from modification

of financial assets

....................................

212

4.13. Provisions

...........................................

212

4.14.Impairment charge

..................................

213

4.15.Gains less losses from non-current

assets held for sale

..................................

213

4.16.Income tax

..........................................

214

4.17.Earnings per share

..................................

215

Contents

![]()

172

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

5.Notes to the statement of financial position

........

215

5.1.Cash, cash balances at central banks,

and other demand deposits at banks

................

215

5.2.Financial instruments held for trading

..............

216

5.3.Non-trading financial instruments

measured at fair value through profit or loss

........

217

5.4.Financial assets measured at fair value

throughother comprehensive income

...............

218

5.5.Derivatives for hedging purposes

...................

220

5.6.Financial assets measured at amortised cost

........

223

5.7.Non-current assets held for sale

....................

226

5.8.Property and equipment

.............................

226

5.9.Investment property

.................................

229

5.10.Intangible assets

....................................

230

5.11. Leases

...............................................

232

5.12.Investments in subsidiaries,

associates and joint ventures

........................

234

5.13.Other assets

.........................................

243

5.14.Movements in allowance

for the impairment of financial assets . . . . . . . . . . . . . . .

244

5.15.Financial liabilities,

measured at amortised cost

........................

255

5.16. Provisions

...........................................

258

5.17.Deferred income tax

................................

265

5.18.Income tax relating to components

of other comprehensive income

....................

269

5.19.Other liabilities

......................................

269

5.20.Share capital

.......................................

270

5.21.Accumulated other comprehensive

income and reserves

...............................

270

5.22.Capital adequacy ratios

.............................

271

5.23.Off-balance sheet liabilities

..........................

273

5.24.Funds managed on behalf of third parties

...........

275

6.Risk management

................................

276

6.1.Credit risk management

.............................

278

6.2.Market risk

..........................................

297

6.3.Liquidity risk

.......................................

304

6.4.Management of non-financial risks

..................

316

6.5.Fair value hierarchy of financial and

non-financial assets and liabilities

...................

317

6.6.Offsetting financial assets and financial liabilities

...

328

7.Analysis by segment for NLB Group

................

329

8.Related-party transactions

........................

333

9.Events after the reporting date

....................

341

![]()

173

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Independent auditor’s report

![]()

174

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

![]()

175

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

![]()

176

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

![]()

177

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Statement of management’s

responsibility

The Management Board hereby confirms its responsibility

for preparing the consolidated financial statements of NLB

Group and the financial statements of NLB for the year ending

on 31 December 2021, and for the accompanying accounting

policies and notes to the financial statements.

The Management Board is responsible for the preparation

and fair presentation of these financial statements in

accordance with the International Financial Reporting

Standards as adopted by the European Union, and with

the requirements of the Slovenian Companies Act and the

Banking Act so as to give a true and fair view of the financial

position of NLB Group and NLB as at 31 December 2021, and

their financial results and cash flows for the year then ended.

The Management Board also confirms that the appropriate

accounting policies were consistently applied, and that

the accounting estimates were prepared according to

the principles of prudence and good management. The

Management Board further confirms that the financial

statements of NLB Group and NLB, together with the

accompanying notes, have been prepared on a going-

concern basis for NLB Group and NLB, and in line with

valid legislation and the International Financial Reporting

Standards as adopted by the European Union.

The Management Board is also responsible for appropriate

accounting practices, the adoption of appropriate measures

for safeguarding assets, and the prevention and identification

of fraud and other irregularities or illegal acts.

Management Board of NLB

Archibald Kremser

CFO

Andreas Burkhardt

CRO

Blaž Brodnjak

CEO & CMO

![]()

178

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Income statement for the annual period ended 31 December

in EUR thousands

NLB GroupNLB

Notes2021202020212020

Interest income calculated using the effective interest method

467,500

347,636170,002167,611

Other interest and similar income10,3297,5529,1837,493

Interest and similar income4.1.477,829355,188179,185175,104

Interest expense

s

calculated using the effective interest method(53,171)(41,208)(25,142)(21,883)

Other interest and similar expenses(15,298)(14,407)(14,904)(14,334)

Interest and similar expenses4.1.(68,469)(55,615)(40,046)(36,217)

Net interest income409,360299,573139,139138,887

Dividend income4.2.22311179,6166,259

Fee and commission income4.3.332,589232,432155,217136,691

Fee and commission expenses4.3.(95,413)(62,152)(35,623)(32,234)

Net fee and commission income

237,176

170,280

119,594

104,457

Gains less losses from financial assets and liabilities not measured at fair value through profit or loss4.4.

167

17,689

24

16,970

Gains less losses from financial assets and liabilities held for trading4.5.

21,194

9,794

4,596

4,741

Gains less losses from non-trading financial assets mandatorily at fair value through profit or loss4.6.16,8386,59813,4926,815

Fair value adjustments in hedge accounting5.5.a)

167

720

167

720

Foreign exchange translation gains less losses4.7.345739700(1,108)

Net gains or losses on derecognition of investments in subsidiaries, associates and joint ventures5.12.b)(9,298)(471)--

Gains less losses on derecognition of non-financial assets2,6811,3005312

Other net operating income4.8.23,2217,549

13,747

5,794

Administrative expenses4.9.(368,851)(262,226)(166,079)(162,613)

Cash contributions to resolution funds and deposit guarantee schemes4.10.(35,140)

(16,674)

(9,535)(7,103)

Depreciation and amortisation4.11.(46,528)(31,715)(17,522)(17,848)

Gains less losses from modification of financial assets4.12.(263)(3,577)--

Provisions for credit losses4.13.8,504(482)8,028599

Provisions for other liabilities and charges4.13.(22,670)(8,077)(72)(7,645)

Impairment of financial assets4.14.27,331(61,799)18,067(9,633)

Impairment of non-financial assets4.14.(4,407)

(996)

7,547(685)

Negative goodwill5.12.c)-137,858--

Share of profit from investments in associates and joint ventures (accounted for using the equity method)5.12.d)1,108

874

--

Gains less losses from non-current assets held for sale4.15.

248

10,853

(94)

35,234

Profit before income tax261,406277,921211,468113,853

Income tax4.16.(13,538)(5,165)(3,047)99

Profit for the year247,868272,756208,421113,952

Attributable to owners of the parent236,404

269,707

208,421113,952

Attributable to non-controlling interests11,4643,049--

Earnings per share/diluted earnings per share (in EUR per share)4.17.11.813.510.45.7

The notes are an integral part of these financial statements.

![]()

179

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Statement of comprehensiveincome forthe annualperiodended31 December

The notes are an integral part of these financial statements.

in EUR thousands

NLB GroupNLB

Notes2021202020212020

Net profit for the year after tax247,868272,756208,421113,952

Other comprehensive income after tax(30,168)(2,147)(15,281)3,817

Items that will not be reclassified to income statement

Actuarial gains/(losses) on defined benefit pensions plans

5.16.c)

(1,377)

878

(115)700

Fair value changes of equity instruments measured at fair value through other comprehensive income

5.4.c)

3,0723,809(383)202

Share of other comprehensive income/(losses) of entities accounted for using the equity method(30)(41)--

Income tax relating to components of other comprehensive income

5.18.

(1)(534)

94

(171)

Items that have been or may be reclassified subsequently to income statement

Foreign currency translation611(703)--

Translation gains/(losses) taken to equity611(703)--

Debt instruments measured at fair value through other comprehensive income

(37,394)

6,555(17,359)3,810

Valuation gains/(losses) taken to equity5.4.c)(40,081)7,733(17,187)7,522

Transferred to income statement4.4., 4.14.2,687(1,178)(172)(3,712)

Share of other comprehensive income/(losses) of entities accounted for using the equity method-(11,026)--

Income tax relating to components of other comprehensive income

5.18.

4,951(1,085)2,482(724)

Total comprehensive income for the year after tax217,700270,609193,140

117,769

Attributable to owners of the parent

207,854

266,907193,140

117,769

Attributable to non-controlling interests9,8463,702--

![]()

180

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Statement of financial position as at 31 December

The notes are an integral part of these financial statements.

in EUR thousands

NLB GroupNLB

Notes31 Dec 202131 Dec 202031 Dec 202131 Dec 2020

Cash, cash balances at central banks, and other demand deposits at banks5.1.5,005,0523,961,8123,250,4372,261,533

Financial assets held for trading5.2.a)

7,678

84,8557,68218,831

Non-trading financial assets mandatorily at fair value through profit or loss5.3.a)21,16142,39312,36035,106

Financial assets measured at fair value through other comprehensive income5.4.3,461,8603,514,2901,585,7511,716,351

Financial assets measured at amortised cost

- debt securities5.6.a)1,717,6261,503,0871,436,4241,277,880

- loans and advances to banks5.6.b)140,683197,005199,287158,320

- loans and advances to customers5.6.c)10,587,1219,619,8605,145,1534,564,178

- other financial assets5.6.d)122,229113,13892,40454,503

Derivatives - hedge accounting5.5.b)568-568-

Fair value changes of the hedged items in portfolio hedge of interest rate risk5.5.c)7,08213,8447,08213,844

Investments in subsidiaries5.12.a)--781,540

749,060

Investments in associates and joint ventures5.12.d)11,5257,9884,4831,662

Tangible assets

Property and equipment5.8.247,014249,11786,12291,675

Investment property5.9.

47,624

54,8429,1818,300

Intangible assets5.10.

59,076

61,66829,45328,105

Current income tax assets

3,948

4,369

3,761

1,923

Deferred income tax assets5.17.38,97731,78931,90229,214

Other assets5.13.91,22197,14011,85311,664

Non-current assets held for sale5.7.7,0518,6584,0894,454

Total assets21,577,49619,565,85512,699,53211,026,603

Financial liabilities held for trading5.2.b)7,58515,4857,60215,500

Financial liabilities measured at fair value through profit or loss5.3.b)--352-

Financial liabilities measured at amortised cost

- deposits from banks and central banks5.15.a)71,82872,633109,32941,635

- borrowings from banks and central banks5.15.b)858,531158,225873,479143,464

- due to customers5.15.a)17,640,80916,397,1679,659,6058,850,755

- borrowings from other customers5.15.b)

74,051

91,56040613

- subordinated liabilities5.15.c)288,519288,321288,519288,321

- other financial liabilities5.15.d)206,878182,095102,527

88,969

Derivatives - hedge accounting5.5.b)35,37761,16135,37761,161

Provisions5.16.119,404125,05949,36363,790

Current income tax liabilities

5,878

1,002--

Deferred income tax liabilities5.17.3,0454,475--

Other liabilities5.19.49,46845,63221,03922,001

Total liabilities19,361,37317,442,81511,147,5989,575,609

Equity and reserves attributable to owners of the parent

Share capital5.20.200,000200,000200,000200,000

Share premium5.21.a)871,378871,378871,378

871,378

Accumulated other comprehensive income5.21.b)(10,552)21,127

8,768

24,102

Profit reserves5.21.a)13,52213,52213,52213,522

Retained earnings1,004,385

846,762

458,266341,992

2,078,7331,952,7891,551,934

1,450,994

Non-controlling interests137,390170,251--

Total equity2,216,1232,123,0401,551,9341,450,994

Total liabilities and equity21,577,49619,565,85512,699,53211,026,603

![]()

181

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

The Management Board has authorised for issue the financial statements and the accompanying notes.

Ljubljana, 11 April 2022

Archibald Kremser

CFO

Andreas Burkhardt

CRO

Blaž Brodnjak

CEO & CMO

![]()

182

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Statement of changes in equity for the annual period ended 31 December

in EUR thousands

Accumulated other comprehensive income

NLB Group

Share

capital

Share

premium

Fair value

reserve of

financial assets

measured at

FVOCI

Foreign

currency

translation

reserve

Other

Profit

reserves

Retained

earnings

Equity

attributable to

owners of the

parent

Equity

attributable to

non-controlling

interests

Total

equity

Notes5.20.5.21.a)5.21.b)5.21.b)5.21.b)5.21.a)

Balance as at 1 January 2021200,000

871,378

42,496(17,724)(3,645)13,522

846,762

1,952,789170,2512,123,040

- Net profit for the year------236,404236,40411,464

247,868

- Other comprehensive income--(28,005)540(1,085)--(28,550)(1,618)(30,168)

Total comprehensive income after tax--(28,005)540(1,085)-236,404

207,854

9,846217,700

Dividends paid------(92,200)(92,200)(7,710)(99,910)

Transactions with non-controlling

interests (note 3.)

--149---10,16810,317(34,997)(24,680)

Transfer of fair values reserve--

(3,274)

-(4)-3,278---

Other------(27)(27)-(27)

Balance as at 31 December 2021200,000

871,378

11,366(17,184)(4,734)13,5221,004,385

2,078,733

137,3902,216,123

in EUR thousands

Accumulated other comprehensive income

NLB Group

Share

capital

Share

premium

Fair value

reserve of

financial assets

measured at

FVOCI

Foreign

currency

translation

reserve

Other

Profit

reserves

Retained

earnings

Equity

attributable to

owners of the

parent

Equity

attributable to

non-controlling

interests

Total

equity

Notes5.20.5.21.a)5.21.b)5.21.b)5.21.b)5.21.a)

Balance as at 1 January 2020200,000871,37847,880(17,055)(4,332)13,522

574,489

1,685,88245,0151,730,897

- Net profit for the year------

269,707

269,7073,049272,756

- Other comprehensive income--(2,833)(669)702--(2,800)653(2,147)

Total comprehensive income after tax--(2,833)(669)702-269,707266,9073,702270,609

Acquisition of subsidiaries--------121,534121,534

Transfer of fair values reserve--(2,551)-(15)-2,566---

Balance as at 31 December 2020200,000

871,378

42,496(17,724)(3,645)13,522

846,762

1,952,789170,2512,123,040

![]()

183

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

The notes are an integral part of these financial statements.

in EUR thousands

Accumulated other comprehensive income

NLB

Share

capital

Share

premium

Fair value reserve

of financial assets

measured at FVOCI

Other

Profit

reserves

Retained

earnings

Total

equity

Notes5.20.5.21.a)5.21.b)5.21.b)5.21.a)5.20.

Balance as at 1 January 2021200,000871,378

27,694

(3,592)13,522341,992

1,450,994

- Net profit for the year-----208,421208,421

- Other comprehensive income--(15,177)(104)--(15,281)

Total comprehensive income after tax--(15,177)(104)-208,421193,140

Dividends paid-----(92,200)(92,200)

Transfer of fair values reserve--(53)--53-

Balance as at 31 December 2021200,000871,37812,464

(3,696)

13,522458,2661,551,934

in EUR thousands

Accumulated other comprehensive income

NLB

Share

capital

Share

premium

Fair value reserve

of financial assets

measured at FVOCI

Other

Profit

reserves

Retained

earnings

Total

equity

Notes5.20.5.21.a)5.21.b)5.21.b)5.21.a)5.20.

Balance as at 1 January 2020200,000871,37824,444(4,159)13,522228,0401,333,225

- Net profit for the year-----113,952113,952

- Other comprehensive income--3,250

567

--3,817

Total comprehensive income after tax--3,250

567

-113,952

117,769

Balance as at 31 December 2020200,000871,378

27,694

(3,592)13,522341,992

1,450,994

![]()

184

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Statement of cash flows for the annual period ended 31 December

in EUR thousands

NLB GroupNLB

Notes2021202020212020

CASH FLOWS FROM OPERATING ACTIVITIES

Interest received541,219372,903214,866207,188

Interest paid

(69,578)

(52,921)(43,343)(31,881)

Dividends received635

787

56,6066,261

Fee and commission receipts332,575232,607152,288

133,743

Fee and commission payments(92,102)(65,728)(33,927)(32,972)

Realised gains from financial assets and financial liabilities not at fair value through profit or loss

17117,993

24

17,274

Net gains/(losses) from financial assets and liabilities held for trading21,56310,9195,4045,634

Payments to employees and suppliers(382,529)(260,259)(170,986)(164,558)

Other receipts27,51613,64217,7238,627

Other payments(51,129)(20,629)(16,026)(9,490)

Income tax (paid)/received(8,617)(6,645)(1,603)3,779

Cash flows from operating activities before changes in operating assets and liabilities319,724

242,669

181,026143,605

(Increases)/decreases in operating assets(964,998)(366,831)(469,788)(105,859)

Net (increase)/decrease in trading assets68,9651,8382,4711,838

Net (increase)/decrease in non-trading financial assets

mandatorily at fair value through profit or loss

36,500(12,667)35,792(12,564)

Net (increase)/decrease in financial assets measured at fair

value through other comprehensive income

(57,015)(150,006)90,215(77,098)

Net (increase)/decrease in loans and receivables measured at amortised cost

(1,020,944)

(207,260)(598,138)(18,357)

Net (increase)/decrease in other assets7,4961,264(128)322

Increases/(decreases) in operating liabilities

2,108,374

1,338,7781,589,8611,043,991

Net increase/(decrease) in deposits and borrowings measured at amortised cost2,106,9851,338,5911,589,4151,044,255

Net increase/(decrease) in other liabilities1,389

187

446(264)

Net cash flows from operating activities1,463,1001,214,6161,301,0991,081,737

CASH FLOWS FROM INVESTING ACTIVITIES

Receipts from investing activities

495,174

478,251478,851402,729

Proceeds from sale of property, equipment, and investment property5,0775,341122,258

Proceeds from sale of subsidiaries, net of cash and cash equivalents5.12.b)(47,832)-15,310-

Proceeds from non-current assets held for sale

966

39,07879139,078

Proceeds from disposals of debt securities measured at amortised cost536,963433,832462,738361,393

Payments from investing activities(832,512)108,232

(697,976)

(602,939)

Purchase of property, equipment, and investment property(23,013)(27,626)(9,093)(15,089)

Purchase of intangible assets(12,704)(15,020)(6,889)(10,663)

Purchase of subsidiaries, net of cash acquired and increase in subsidiaries’ equity3., 5.12.c)(24,437)452,770(40,046)(397,729)

Increase in associates and joint ventures’ equity(2,900)(326)(2,900)(326)

Purchase of debt securities measured at amortised cost

(769,458)

(301,566)(639,048)(179,132)

Net cash flows from investing activities(337,338)586,483(219,125)(200,210)

CASH FLOWS FROM FINANCING ACTIVITIES

Proceeds from financing activities-119,222-119,222

Issuance of subordinated debt5.15.c)-119,222-119,222

Payments from financing activities(100,503)(45,000)(92,200)(45,000)

Dividends paid(100,503)-(92,200)-

Repayments of subordinated debt5.15.c)-(45,000)-(45,000)

Net cash flows from financing activities(100,503)

74,222

(92,200)

74,222

Effects of exchange rate changes on cash and cash equivalents14,640

(2,176)

3,219(2,080)

Net increase/(decrease) in cash and cash equivalents1,025,2591,875,321

989,774

955,749

Cash and cash equivalents at beginning of year4,136,4122,263,2672,261,7911,308,122

Cash and cash equivalents at end of year

5,176,311

4,136,4123,254,7842,261,791

The notes are an integral part of these financial statements.

![]()

185

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

in EUR thousands

NLB GroupNLB

Notes31 Dec 202131 Dec 202031 Dec 202131 Dec 2020

Cash and cash equivalents comprise:

Cash, cash balances at central banks, and other demand deposits at banks5.1.

5,005,946

3,962,686

3,250,7842,261,791

Loans and advances to banks with original maturity up to three months142,319146,2234,000-

Debt securities measured at fair value through other comprehensive income with original maturity up to three months28,04627,503--

Total

5,176,311

4,136,4123,254,7842,261,791

![]()

186

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Notes to the financial

statements

1.

General information

NovaLjubljanska banka d.d. Ljubljana (hereinafter: ‘NLB’

or ‘the Bank’) is a Slovenian joint-stock entity providing

universal banking services. NLB Group consists of NLB and

its subsidiaries located in nine countries, mainly in Slovenia

and the SEE market. Information on NLB Group’s structure

is disclosed in note 5.12. Information on other related party

relationships of NLB Group is provided in note 8.

NLB is incorporated and domiciled in Slovenia. The address

of its registered office is Trg Republike 2, 1000 Ljubljana. NLB’s

shares are listed on the Ljubljana Stock Exchange, and the

global depositary receipts (‘GDR’), representing ordinary

shares of NLB, are listed on the London Stock Exchange. Five

GDRs represent one share of NLB.

As at 31 December 2021 and as at 31 December 2020, the

largest shareholder of NLB with significant influence is the

Republic of Slovenia, owning 25.00% plus one share.

All amounts in the financial statements and in the notes to

the financial statements are expressed in thousands of euros

unless otherwise stated.

2.

Summary ofsignificant

accountingpolicies

The principal accounting policies adopted for the preparation

of the separate and consolidated financial statements are set

out below. The policies have been consistently applied to all

the years presented, except for changes in accounting policies

resulting from the application of new standards or changes to

standards.

2.1.

Statement of compliance

The principal accounting policies applied in the preparation

of the separate and consolidated financial statements were

prepared in accordance with the International Financial

Accounting Standards (hereinafter: ‘the IFRS’) as adopted

by the European Union (hereinafter: ‘EU’). Additional

requirements underthe nationallegislation are included

where appropriate.

The separate and consolidated financial statements are

comprised of the income statement and statement of

comprehensive income, the statement of financial position, the

statement of changes in equity, the statement of cash flows,

significant accounting policies, and the notes.

2.2.Basis for presenting the financial statements

The financial statements have been prepared on a going-

concern basis, under the historical cost convention as

modified by the revaluation of financial assets measured at

fair value through other comprehensive income, financial

assets, and financial liabilities at fair value through profit or

loss, including all derivative contracts, hedged items in fair

value hedgeaccountingrelationships,non-current assets

held for sale, and investment property.

The preparation of financial statements in accordance with

the IFRS requires the use of estimates and assumptions that

affect the reported amounts of assets and liabilities, the

disclosure of contingent assets and liabilities on the date

of the financial statements, and the reported amounts of

revenue and expenses during the reporting period. Although

these estimates are based on management’s best knowledge

of current events and activities, actual results may ultimately

differ from those estimates. Accountingestimates and

underlying assumptions are reviewed on an ongoing basis.

Revisions of accounting estimates are recognised in the

period in which the estimate is revised. Critical accounting

estimates and judgements in applying accounting policies are

disclosed in note 2.33.

This document contains both the separate financial

statements of NLB, and the consolidated financial statements

of NLB Group. The presented accounting policies apply

to both sets of financial statements, with the exception of

policies described in notes 2.4. and 2.5., which only apply to

the consolidated financial statements and policies described

in note 2.6., where differences in the accounting treatment for

investments in subsidiaries, and associated and joint ventures

between separate and consolidated financial statements are

described. Data relating to separate financial statements is

marked ‘NLB,’ while data relating to consolidated financial

statements is marked ‘NLB Group.’

2.3.

Comparative amounts

Except when a standard or an interpretation permits or

requires otherwise, all amounts are reported or disclosed

with comparative amounts. Where IAS 8 applies, comparative

figures have been adjusted to conform to the changes in

presentation in the current year.

Compared to the presentation of the financial statements for

the year ended 31 December 2020, the classification of certain

line items in the Statement of Financial Position changed due

to changes prescribed by the Bank of Slovenia. Additionally,

there was a change in the line item ‘Interest and similar

expenses’ in the Income statement, where two lines were

added with more detailed presentation of interest expenses.

Comparative amounts have been adjusted to reflect these

changes in the presentation.

in EUR thousands

31 Dec 2020NLB GroupNLB

Notes

Old

presentation

Current

presentation

Change

Old

presentation

Current

presentation

Change

Statement of financial position:

Other financial liabilites5.15.d)

Accrued salaries19,068-(19,068)9,807-(9,807)

Unused annual leave6,137-(6,137)2,497-(2,497)

Other liabilities5.19.

Accrued salaries-19,06819,068-9,8079,807

Unused annual leave-6,1376,137-2,4972,497

Income statement:

Interest expenses calculated using

the effective interest method

-(41,208)(41,208)-(21,883)(21,883)

Other interest and similar expenses

-(14,407)(14,407)-(14,334)(14,334)

Interest and similar expenses4.1.(55,615)(55,615)-(36,217)(36,217)-

![]()

187

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

‘Accrued salaries’ and ‘Unused annual leave’ are included

under the line item ‘Other liabilities’; before changing the

classification, these line items were included under the line

item ‘Other financial liabilities.’

‘Interest expenses calculated using the effective interest

method’ and ‘Other interest and similar expenses’ were not

disclosed separately before the change, they were shown

under the line item ‘Interest and similar expenses.’

2.4.

Consolidation

In the consolidated financial statements (NLB Group),

subsidiaries which are directly or indirectly controlled by NLB

have been fully consolidated. Subsidiaries are consolidated

from the date on which effective control is transferred to NLB

Group.

NLB controls an entity when all three elements of control are

met:

•it has power over the entity;

•it is exposed or has rights to variable returns from its

involvement with the entity; and

•it has the ability to use its power over the entity to affect the

amount of the entity’s returns.

NLB reassesses whether it controls an entity if facts and

circumstances indicate there are changes to one or more

of the three elements of control. If the loss of control of a

subsidiary occurs, the subsidiary is no longer consolidated

from the date that the control ceases.

Where necessary, the accounting policies of subsidiaries

have been amended to ensure consistency with the policies

adopted by NLB. The financial statements of consolidated

subsidiaries are prepared as at the parent entity’s reporting

date. Non-controlling interests are disclosed in the

consolidated statement of changes in equity. Non-controlling

interest is that part of the net results, and of the equity of

a subsidiary, attributable to interests which NLB does not

own, either directly or indirectly. NLB Group measures

non-controlling interest ona transaction-by-transaction

basis, either at fair value, or by the non-controlling interest’s

proportionate share of net assets of the acquiree.

Inter-company transactions, balances, and unrealised gains

on transactions between NLB Group entities are eliminated.

Unrealised losses are also eliminated unless the transaction

provides evidence of impairment of the asset transferred.

NLBGroup treats transactions withnon-controlling interests

as transactions with equity owners of NLB Group. For

purchases of subsidiaries from non-controlling interests, the

difference between any consideration paid and the relevant

share acquired of the carrying value of net assets of the

subsidiary is deducted from the equity. For sales to non-

controlling interests, the differences between any proceeds

received and the relevant share of non-controlling interests

are also recorded in the equity. All effects are presented in the

line item ‘Equity Attributable to Non-controlling Interest.’

2.5.Business combinations, goodwill,

and bargain purchases

NLB Group accounts for business combinations using the

acquisition method when the acquired set of activities and

assets meets the definition of a business and control is

transferred to the Group. In determining whether a particular

set of activities and assets is a business, the Group assesses

whether the set of assets and activities acquired includes, at a

minimum, an input and substantive process and whether the

acquired set has the ability to produce outputs. The acquired

process is considered substantive if it is critical to the ability to

continueproducing outputs; and theinputs acquiredinclude

an organised workforce with the necessary skills, knowledge,

or experience to perform that process or it significantly

contributes to theability to continue producing outputs and

is considered unique or scarce or cannot be replaced without

significant cost, effort, or delay in the ability to continue

producing outputs.

The consideration transferred is measured at the fair value

of the assets transferred, equity interest issued, liabilities

incurred or assumed, including the fair value of assets or

liabilities from contingent consideration arrangements and

fair value ofany pre-existing equity interest in subsidiary.

However, this excludes amounts related to the settlement

of pre-existing relationships which are recognised in profit

or loss. Acquisition-related costs such as advisory, legal,

valuation, and similar professional services are recognised

in profit or loss as well. Transaction costs incurred for issuing

equity instruments are deducted from the equity, and all

other transaction costs associated with the acquisition are

expensed.

Identifiable assets acquired and liabilities assumed in a

business combination are, with limited exceptions, measured

initially at their fairvalues at the acquisitiondate.

A contingent consideration classified as equity is not re-

measured and its subsequent settlement is accounted for

within equity. A contingent consideration classified as an asset

or liability that is a financial instrument and within the scope of

IFRS 9 Financial Instruments, is measured at fair value at each

reporting date and changes in fair value are recognised in the

statement of profit or loss in accordance with IFRS 9. Other

contingent considerations that are not within the scope of

IFRS 9 are measured at fair value at each reporting date and

changes in fair value are recognised in profit or loss.

For each business combination, NLB Group elects whether to

measure the non-controlling interests in the acquiree at fair

value or at the present ownership instruments’ proportionate

share in the recognised amounts of the acquiree’s identifiable

net assets at the date of acquisition. All other components

of non-controlling interests are measured at their

acquisition-date fair values, unless another measurement

basis is required by IFRSs.

Goodwill is measured as the excess of the aggregate of the

consideration transferred measured at fair value, the amount

of any non-controlling interest in the acquiree, and the fair

value of an interest in the acquiree held immediately before

the acquisition date over the net amounts of the identifiable

assets acquired, as well as the liabilities assumed. Any

negative amount, a gain on a bargain purchase (or ‘negative

goodwill’), is recognised in profit or loss after management

reassesses whether it has identified all the assets acquired

and all the liabilities and contingent liabilities assumed, and

reviews the appropriateness of their measurement.

Goodwill is tested annually for impairment. For the purpose

of impairment testing, goodwill arising from a business

combination is, from the acquisition date, allocated to the

Group’s cash-generating units (CGUs) or groups of CGUs that

are expected to benefit from the synergies of the combination.

Where goodwill has been allocated to a cash-generating unit

(CGU) and part of the operation within that unit is disposed

of, the goodwill associated with the disposed operation

is included in the carrying amount of the operation when

determining the gain or loss on disposal. Goodwill disposed

in these circumstances is measured based on the relative

values of the disposed operation and the portion of the cash-

generating unit retained.

The goodwill of associates and joint ventures is included in the

carrying value of investments.

![]()

188

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

In a business combination achieved in stages, NLB Group

remeasures its previously held equity interest in the acquiree

at its acquisition-date fair value and recognises the resulting

gain or loss, if any, in profit or loss.

2.6.

Investments in subsidiaries,

associates and joint ventures

In the separate financial statements (NLB), investments in

subsidiaries, associates and joint ventures are accounted

for with the cost method. Dividends from subsidiaries,

joint ventures, or associates are recognised in the income

statement when NLB’s right to receive the dividend has been

established.

In the consolidated financial statements, investments in

associates, are accounted for using the equity method of

accounting. These are generally undertakings in which NLB

Group holds between 20% and 50% of the voting rights, and

over which NLB Group exercises significant influence, but does

not have control.

Joint ventures are entities over whose activities NLB Group

has joint control, established by contractual agreement. In the

consolidated financial statements, investments in joint ventures

are accounted for using the equity method of accounting.

NLB Group’s share of its associates’ and joint ventures’ post-

acquisition profits or losses is recognised in the consolidated

income statement, and its share of other comprehensive

income is recognised in other comprehensive income. The

cumulative post-acquisition movements are adjusted against

the carrying amount of the investment. When NLB Group’s

share of losses in an associate and joint venture equals

or exceeds its interest in the associate and joint venture,

including any other unsecured receivables, NLB Group does

not recognise further losses unless it has incurred obligations

or made payments on behalf of the associate and joint

venture. NLB Group resumes recognising its share of those

profits only after its share of the profits equals the share of

losses not recognised (note 5.12.d).

NLB Group’s subsidiaries, associates and joint ventures are

presented in note 5.12.

2.7.A combination of entities or businesses

under common control

A merger of entities within NLB Group is a business

combination involvingentities under commoncontrol.

For such mergers, members of NLB Group apply merger

accounting principles, and use the carrying amounts of

merged entities as reported in the consolidated financial

statements. No goodwill is recognised on mergers of NLB

Groupentities.

Mergers of entities within NLB Group do not affect the

consolidated financial statements.

2.8.

Foreign currency translation

Functional and presentation currency

Items included in the financial statements of each of NLB

Group’s entities are measured using the currency of the

primary economic environment in which the entity operates

(i.e., the functional currency). The financial statements are

presented in euros, which is NLB Group’s presentation

currency.

Transactions and balances

Foreign currency transactions are translated into the

functional currency at the exchange rates prevailing at the

dates of the transactions. Foreign exchange gains and losses

resulting from the settlement of such transactions, and from

the translation of monetary assets and liabilities denominated

in foreign currencies, are recognised in the income statement,

except when deferred in other comprehensive income as

qualifying cash flow hedges.

Translation differences resulting from changes in the

amortised cost of monetary items denominated in foreign

currency and classified as financial assets measured at fair

value through other comprehensive income, are recognised in

the income statement.

Translation differences on non-monetary items, such as equity

instruments at fair value through profit or loss, are reported

as part of the fair value gain or loss in the income statement.

Translation differences on non-monetary items, such as equity

instruments classified as financial assets, measured at fair value

through other comprehensive income, are included together

with valuation reserves in the valuation (losses)/gains taken to

other comprehensive income and accumulated in the equity.

Gains and losses resulting from foreign currency purchases

and sales for trading purposes are included in the income

statement as gains less losses from financial assets and

liabilities held for trading.

NLB Group entities

The financial statements of all NLB Group entities that have a

functional currency different from the presentation currency

aretranslated into the presentationcurrency as follows:

•

assets and liabilities for each statement of financial position

presented are translated at the closing rate on the reporting

date;

•income and expenses for each income statement are

translated at average exchange rates; and

•components of equity are translated at the historical rate.

Goodwill and fair value adjustments arising from the acquisition

of a foreign entity are treated as assets and liabilities of the

foreign entity and translated at the closing rate.

In the consolidated financial statements, exchange differences

arising from the translation of the net investment in foreign

operations are recognised in other comprehensive income.

When control over a foreign operation is lost, the previously

recognised exchange differences on translations to a

different presentation currency are reclassified from other

comprehensive income to profit and loss for the year. On

the partial disposal of a subsidiary without loss of control,

the related portion of accumulated currency translation

differences is reclassified as a non-controlling interest within

the equity.

2.9.Interest income and expenses

Interest income and expenses for all financial instruments

measured at amortised cost, and financial assets measured

at fair value through other comprehensive income are

recognised in the income statement for all interest-bearing

instruments on an accrual basis using the effective interest

method. Interest income on all trading assets and financial

assets mandatorily required to be measured at fair value

through profit or loss is recognised using the contractual

interest rate. The effective interest method is used to calculate

the amortised cost of a financial asset or financial liability,

and to allocate the interest income or interest expenses over

the relevant period. The effective interest rate is the rate that

exactly discounts estimated future cash payments or receipts

over the expected life of the financial instrument, or a shorter

period (when appropriate) to the gross carrying amount of the

financial asset or to the amortised cost of a financial liability.

Interest income includes coupons earned on fixed-yield

investments and trading securities, and accrued discounts

and premiums on securities. The calculation of the effective

interest rate includes all fees and points paid or received by

parties to the contract and all transaction costs, but excludes

future credit risk losses.

Interest income is calculated by applying the effective interest

rate to the gross carrying amount of financial assets other

than credit-impaired assets.

![]()

189

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

When a financial asset becomes credit-impaired and is,

therefore, classified in Stage 3, interest income is calculated by

applying the effective interest rate to the net amortised cost of the

financial asset. If the financial asset cures and is no longer credit-

impaired, interest income is again calculated on a gross basis.

In the case of purchased or originated credit-impaired financial

assets (POCI), the credit-adjusted effective interest rate is

applied to the amortised cost of the financial asset from initial

recognition. The credit-adjusted effective interest rate is the

interest rate that, at initial recognition, discounts the estimated

future cash flows (including credit losses) to the amortised cost

of the purchased or originated credit-impaired financial asset. At

NLB Group level, most POCI exposures relate to initial recognition

of non-performing exposures in case of business combination.

2.10.Fee and commission income

Fees and commissions mainly include fees received from

credit cards and ATMs, customer transaction accounts,

payment services, investment funds, and commissions from

guarantees. Fee and commission income are recognised at

an amount that reflects the consideration to which the Group

expects to be entitled in exchange for providing the services.

The performance obligations, as well as the timing of their

satisfaction, areidentified, and determined,at the inception

of the contract. The Group’s revenue contracts do not include

multiple performance obligations.

When the Group provides a service to its customers,

consideration is invoiced and generally due immediately

upon satisfaction of a service provided at a point in time.

When the service is provided over time, the consideration is

invoiced and due in line with contractual provisions.

The Group has generally concluded that it is the principal in

its revenue arrangements because it typically controls the

services before transferring them to the customer.

Fees and commissions that are integral to the effective interest

rate of financial assets and liabilities are presented within

interest income or expenses.

2.11.Dividend income

Dividends are recognised in the income statement within the

line item ‘Dividend income’ when NLB Group’s right to receive

payment has been established and an inflow of economic

benefits is probable. In the consolidated financial statements,

dividends received from associates and joint ventures reduce

the carrying value of the investment.

2.12.Financial instruments

a)Classification and measurement

Financial instruments are initially measured at fair value plus

or minus, in the case of a financial instrument not measured

at fair value through profit or loss, transaction costs that are

directly attributable to the acquisition or issue of the financial

instrument. Subsequent measurement depends on the

classification of theinstrument.

Financial assets

All debt financial assets need to be assessed based on a

combination of the Group’s business model for managing

the assets and the instruments’ contractual cash flow

characteristics. Measurement categories of financial assets

are as follows:

•

Financial assets, measured at amortised costs (AC);

•Financial assets at fair value through other comprehensive

income(FVOCI);

•Financial assets held for trading (FVTPL); and

•Non-trading financial assets, mandatorily at fair value

through profit or loss (FVTPL).

Financial assets are measured at AC if they are held within a

business model for the purpose of collecting contractual cash

flows (‘held to collect’), and if cash flows are solely payments

of principal and interest on the principal amount outstanding.

After initial recognition, they are measured at the amortised

cost using the effective interest method and are subject to

impairment. Interest income calculated using the effective

interest method, foreign exchange gains and losses, and

impairment are recognised in profit or loss. Each of them is

presented as a separate line item in the income statement. Any

gain or loss on derecognition is recognised in profit or loss in

line item ‘Gains less losses from financial assets and liabilities

not classified at fair value through profit or loss.’

Debt financial instruments are measured at FVOCI if they are

held within a business model for the purpose of both collecting

contractual cash flows and selling (‘held to collect and sell’),

and if cash flows are solely payments of principal and interest

on the principal amount outstanding. FVOCI results in the debt

instruments being recognised at fair value in the statement

of financial position and at the AC in the income statement.

Interest income is calculated using the effective interest

method, foreign exchange gains and losses, and impairments

are recognised separately in the income statement. Other

net gains and losses are recognised in other comprehensive

income, until the instrument is derecognised. At derecognition

of the debt financial instrument, the cumulative gains and

losses previously recognised in other comprehensive income

are reclassified to the income statement under the line item

‘Gains less losses from financial assets and liabilities not

classified at fair value through profit or loss.’

Equity instruments that are not held for trading may be

irrevocably designated as FVOCI, with no subsequent

reclassification of gains or losses to the income statement.

Dividends are recognised as income in profit or loss unless

the dividend clearly represents a recovery of part of the cost

of the investment, in which case, such gains are recorded

in other comprehensive income. Other net gains and losses

are recognised in other comprehensive income and are

never reclassified to profit or loss. In NLB Group, the most

material equity instrument irrevocably designated as FVOCI

is investment in National Resolution Fund (note 5.4.a). NLB

Group decided to use this presentation alternative because

the fund was established based on the law and it has a highly

regulated investment strategy in order to ensure safety, low

risk, and the high liquidity of the fund.

All other financial assets are mandatorily measured at FVTPL,

including financial assets within other business models such

as financial assets managed at fair value or held for trading

and financial assets with contractual cash flows that are not

solely payments of principal and interest on the principal

amount outstanding. Net gains and losses, including any

interest or dividend income, are recognised in profit or loss.

IFRS 9 includes an option to designate financial assets

at fair value through profit or loss if doing so eliminates

or significantly reduces a measurement or recognition

inconsistency that would otherwise arise from measuring

assets or liabilities or recognising the gains or losses on them

on different bases.

Financialliabilities

Financial liabilities are subsequently measured at the

amortised cost or at fair value through profit or loss, when

they are held for trading, derivative instruments, or the fair

value designation is applied.

Upon initial recognition, financial liability may be irrevocably

designated as measured at fair value through profit or loss

if that eliminates or significantly reduces a measurement or

recognition inconsistency that would otherwise arise from

measuring assets or liabilities or recognising the gains or

![]()

190

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

losses on them on different bases, or if the liabilities are part of

a group of financial instruments which are managed and their

performance evaluated on a fair value basis in accordance

with a documented risk management or investment strategy.

Changes in the fair value of financial liabilities designated as

measured at fair value through profit or loss are recognised

in profit or loss, with the exception of movement in the fair

value due to changes of NLB Group’s own credit risk. Such

changes are presented in other comprehensive income with

no subsequent reclassification to theincome statement.

Other financial liabilities are subsequently measured at

amortised cost using the effective interest method. Interest

expenses and foreign exchange gains and losses are

recognised in profit or loss. Any gain or loss on derecognition

of financial liability is recognised in profit or loss. In the event

of derecognition of a financial liability measured at amortised

cost, the gains and losses are recognised in the line item

‘Gains less losses from financial assets and liabilities not

classified at fair value through profit or loss.’ Gains and losses

on disposals of financial liabilities designated as measured at

fair value through profit or loss are also presented separately

from those held for trading.

Assessment of NLB Group’s business model

NLB Group has determined its business model separately

for each reporting unit within NLB Group, and is based on

observable factors for different portfolios that best reflect how

the Group manages groups of financial assets to achieve its

business objective, such as:

•how the performance of the business model and the

financial assets held within that business model are

evaluated and reported to key management personnel;

•the risks that affect the performance of the business model

and, in particular, the way those risks are managed;

•how the managers of the business are compensated (e.g.,

whether the compensation is based on the fair value of the

assets or on collection of contractual cash flows); and

•the expected frequency, value, and timing of sales.

The business model assessment is based on reasonably

expected scenarios without taking worst-case and stress case

scenarios into consideration. In general, the business model

assessment of the Group can be summarised as follows:

•Loans and deposits given are included in a business model

‘held to collect’ since the primary objective of NLB Group for

the loan portfolio is to collect the contractual cash flows;

•Debt securities are divided into three business models:

•the first group of debt securities presents ‘held for trading’

category;

•debt securities in the second group are held under a

business model ‘held to collect and sale’ with the intention

of collecting the contractual cash flows and sale of

financial assets, and forms part of the Group’s liquidity

reserves;

•the third part of debt securities is held within the

business model for holding them with objective to collect

contractual cash flows.

With regard to debt securities within the ‘held to collect’

business model, the sales which are related to the increase of

the issuers’ credit risk, concentrations risk, sales made close

to the final maturity, or sales in order to meet liquidity needs in

a stress case scenario are permitted. Other sales, which are

not due to an increase in credit risk may still be consistent with

a held to collect business model if such sales are incidental to

the overall business model, and:

•are insignificant in value both individually and in aggregate,

even when such sales are frequent;

•are infrequent even when they are significant in value.

A review of instruments’ contractual cash flow

characteristics (the SPPI test – solely payment of principal

and interest on the principal amount outstanding)

The second step in the classification of the financial assets in

portfoliosbeing ‘held to collect’ and ‘held to collect and sell’

relates to the assessment of whether the contractual cash

flows are consistent with the SPPI test. The principal amount

reflects the fair value at initial recognition less any subsequent

changes, e.g., due to repayment. The interest must represent

only the consideration for the time value of money, credit risk,

other basic lending risks, and a profit margin consistent with

basic lending features. If the cash flows introduce more than

de minimis

exposure to risk or volatility that is not consistent

with basic lending features, the financial asset is mandatorily

measured at fair value through profit or loss.

NLB Group reviews the portfolio within ‘held to collect’ and

‘held to collect and sale’ for standardised products on a level

of a product and for non-standardised products on a single

exposure level. The Group has established a procedure for

SPPI identification as part of regular investment process with

defined responsibilities for primary and secondary controls.

Special emphasis is put on new and non-standardised

characteristics of loan agreements.

Accounting policy for modified financial assets

When contractual cash flows of a financial asset are modified,

NLB Group assesses if the terms and conditions have been

modified to the extent that, substantially, it becomes a new

financial asset. The following factors are, amongst others,

considered when making such assessment:

•reason for modification of cash flows (commercial or client’s

financial difficulties);

•change in currency of the loan;

•

introduction ofan equity feature;

•replacement of initially agreed debtor with a new debtor

that is not related party to initial debtor; and

•if the modification changes the result of the SPPI test.

If the modification results in derecognition of a financial asset,

the new financial asset is initially recognised at fair value, with

the difference recognised as a derecognition gain or loss,

to the extent that an impairment loss has not already been

recorded. If the modification does not result in cash flows that

are substantially different, the modification does not result

in derecognition. In such cases, NLB Group recalculates the

gross carrying amount of the financial asset and recognises

modification gain or loss in the income statement. The gross

carrying amount is recalculated as the present value of the

renegotiated or modified contractual cash flows that are

discounted at the financial asset’s original effective interest

rate (or credit-adjusted effective interest rate for purchased or

originated credit-impaired financial assets).

b) Reclassification

Financial assets can be reclassified when and only when NLB

Group’s business model for managing those assets changes.

The reclassification takes place from the start of the reporting

period following the change. Such changes are expected to

be very infrequent, and none occurred during the presented

periods. Financial liabilities shall not be reclassified.

c) Day one gains or losses

The best evidence of fair value at initial recognition is the

transaction price (i.e., the fair value of the consideration given

or received), unless the fair value of that instrument is evidenced

by a comparison with other observable current market

transactions in the same instrument (i.e., without modification

or repackaging), or based on a valuation technique whose

variables only include data from observable markets.

If the transaction price on a non-active market is different

than the fair value from other observable current market

transactions in the same instrument or is based on a valuation

![]()

191

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

technique whose variables onlyinclude data fromobservable

markets, the difference between the transaction price and fair

value is recognised immediately in the income statement (‘day

one gains or losses’).

In cases where the data used for valuation are not fully

observable in financial markets, day one gains or losses are

not recognised immediately in the income statement. The

timing of recognition of deferred day one gains or losses is

determined individually. It is either amortised over the life of

the transaction, deferred until the instrument’s fair value can

be determined using market observable inputs, or realised

throughsettlement.

d) Derecognition

A financial asset is derecognised when the contractual rights

to the cash flows from the financial asset expire, or when the

financial asset is transferred, and the transfer qualifies for

derecognition. A financial liability is derecognised only when

it is extinguished, i.e., when the obligation specified in the

contract is discharged, cancelled, or expires.

e)Write-offs

NLB Group writes off financial assets in their entirety or a

portion thereof when it has exhausted all practical recovery

efforts and has no reasonable expectations of recovery. Criteria

indicating that there is no reasonable expectation of recovery

include default period, quality of collateral, and different stages

of enforcement procedures. NLB Group may write off financial

assets that are still subject to enforcement activities, but this

does not affect its rights in the enforcement procedures. NLB

Group still seeks to recover all amounts it is legally entitled to in

full. A write-off reduces the gross carrying amount of a financial

asset and allowance for the impairment. Any subsequent

recoveries are credited to credit loss expenses. Write-offs and

recoveries are disclosed in note 5.14.a).

f) Fair value measurement principles

The fair value of financial instruments traded on active

markets is based on the price that would be received to sell

the assets or transfer liability (exit price) being measured at

the reporting date, excluding transaction costs. If there is no

active market, the fair value of the instruments is estimated

using discounted cash flow techniques or pricing models.

If discounted cash flow techniques are used, estimated future

cash flows are based on management’s best estimates; and

the discount rate is a market-based rate at the reporting

date for an instrument with similar terms and conditions. If

pricing models are used, inputs are based on market-based

measurements atthe reporting date.

g)Derivativefinancial instruments and hedge accounting

Derivative financial instruments – including forward

and futures contracts, swaps, and options – are initially

recognised in the statement of financial position at fair

value. Derivative financial instruments aresubsequentlyre-

measured at their fair value. Fair values are obtained from

quoted market prices, discounted cash flow models, or pricing

models, as appropriate. All derivatives are carried at their fair

value within assets when the derivative position is favourable

to NLB Group, and within liabilities when the derivative

position is unfavourable to NLB Group.

The method of recognising the resulting fair value gain or loss

depends on whether the derivative is designated as a hedging

instrument and, if so, the nature of the item being hedged. NLB

Group designates certain derivatives as either:

•hedges of the fair value of recognised assets or liabilities or

firm commitments (fair value hedge);

•hedges of highly probable future cash flows attributable to a

recognised asset or liability, or a highly probable forecasted

transaction (cash flow hedge); or

•hedges of a net investment in a foreign operation (net

investment hedge).

Hedge accounting is used when certain criteria are met.

NLB Group and NLB have exercised the option to continue

applying the existing IAS 39 hedge accounting requirements

in accordance with the policy choice permitted under IFRS 9.

However, disclosures that are required by the IFRS 9 related

amendments to IFRS 7 ‘Financial Instruments: Disclosures’ are

implemented.

At the inception of the transaction, NLB Group documents the

relationship between hedged items and hedging instruments,

as well as its risk management objective, valuation

methodology, and strategy for undertaking various hedge

transactions. NLB Group also documents its assessment, both

at the hedge inception and on an ongoing basis, of whether

the derivatives used in hedging transactions are highly

effective in offsetting changes in fair values or cash flows of

hedged items. The actual results of a hedge must always fall

within a range of 80–125%.

Fair value hedge

Changes in the fair value of derivatives that are designated

and qualify as fair value hedges are recognised in the income

statement together with any changes in the fair value of the

hedged asset or liability that are attributable to the hedged

risk. Effective changes in the fair value of hedging instruments

and related hedged items are reflected in ‘Fair Value

Adjustments in Hedge Accounting’ in the income statement.

Any ineffectiveness from derivatives is recorded in ‘Gains Less

Losses on Financial Assets and Liabilities Held for Trading.’

If a hedge no longer meets the hedge accounting criteria,

the adjustment to the carrying amount of the hedged item

for which the effective interest method is used is amortised

to profit or loss over the remaining period to maturity. The

adjustment to the carrying amount of a hedged equity

security is included in the income statement upon disposal of

the equity security.

Cash flow hedge

The effective portion of changes in the fair value of derivatives

that are designated and qualify as cash flow hedges is

recognised in other comprehensive income. The gain or loss

relating to the ineffective portion is immediately recognised in

the income statement.

Amounts accumulated in equity are recycled as a

reclassification from other comprehensive income to the

income statement in the periods when the hedged item affects

the profit or loss.

When a hedging instrument expires or is sold, or when a

hedge no longer meets hedge accounting criteria, any

cumulative gain or loss existing in other comprehensive

income and previously accumulated in equity at that time

remains in other comprehensive income and in equity, and

is recognised in profit or loss only when the forecasted

transaction is ultimately recognised in the income statement.

When a forecasted transaction is no longer expected to

occur, the cumulative gain or loss that was reported in other

comprehensive income is immediately transferred to the

income statement.

Hedge of a net investment in a foreign operation

Hedges of net investments in foreign operations are

accounted for in consolidated financial statements similar to

cash flow hedges. Any gain or loss on the hedging instrument

relating to the effective portion of the hedge is recognised

directly in equity. The gain or loss relating to the ineffective

portion is recognised immediately in the consolidated income

statement in ‘Gains Less Losses on Financial Assets and

Liabilities Held for Trading.’ Gains and losses accumulated in

![]()

192

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

other comprehensive income are included in the consolidated

income statement when the foreign operation is disposed of

as part of the gain or loss on the disposal.

2.13.Allowances for financial assets

a)Expected credit losses for collective allowances

IFRS 9 applies an expected loss model that provides an

unbiased and probability-weighted estimate of credit losses

by evaluating a range of possible outcomes that incorporates

forecasts of future economic conditions. The expected loss

model requires NLB Group to recognise not only credit losses

that have already occurred, but also losses that are expected

to occur in the future. An allowance for expected credit losses

(ECL) is required for all loans and other debt financial assets

not measured at FVTPL, together with loan commitments and

financial guarantee contracts.

In the general model, the allowance is based on the expected

credit losses associated with the probability of default in the

next 12 months unless there has been a significant increase

in credit risk since initial recognition, in which case, the

allowance is based on the probability of default over the life

of the financial asset (LECL). When determining whether the

risk of default increased significantly since initial recognition,

the Group considers reasonable and supportable information

that is relevant and available without undue cost or effort. This

includes both quantitative and qualitative information and

analysis, based on the Group’s historical data, experience,

expert credit assessment, and incorporation of forward-looking

information. In 2021, the NLB Group made improvements to the

SICR (significant increase of credit risk) identification concept

by including additional qualitative indicators as well as by

development of numeric LPD (lifetime probability of default)

concept for part of the portfolio where this was feasible

Classification into stages

NLB Group prepared a methodology for ECL defining the

criteria for classification into stages, transition criteria

between stages, models for risk indicators calculation,

forward-looking scenarios, and the validation of models. The

Group classifies financial instruments into Stage 1, Stage 2, and

Stage 3, based on the applied ECL allowance methodology as

described below:

•Stage 1 – performing portfolio: no significant increase of

credit risk since initial recognition, NLB Group recognises an

allowance based on 12-month period;

•Stage 2 – underperforming portfolio: significant increase

in credit risk (SICR) since initial recognition, NLB Group

recognises an allowance for lifetime period; and

•Stage 3 – impaired portfolio: NLB Group recognises lifetime

allowances for these defaulted financial assets.

The Bank has aligned its definition of credit impaired assets

under IFRS 9 to the new European Banking Authority (EBA)

definition of non-performing loans (NPLs) as at 31 December

2020. The Bank uses a unified definition of past due and

default exposures; defaulted clients are rated D, DF, or E

based on the internal rating system and contains the clients

with material delays over 90 days, as well as the clients that

were assessed as unlikely to pay. All facilities of retail clients

obtain a unified credit rating.

A significant increase in credit risk is assumed:

•when a credit rating significantly deteriorates at the

reporting date in comparison to the credit rating at initial

recognition (which is accompanied with the increase of

Probability of default (PD)indicator),

•when threefold increase of LPD since initial recognition is

detected,

•when a financial asset has material delays over 30 days

(days past due are also included in the credit rating

assessment),

•if NLB Group grants the forbearance to the borrower,

•if the facility is placed on the watch list or intensive care list,

•if a retail client obtained COVID-19 moratoria and is placed

on the watch list.

As COVID-19 moratoria granted to the bank clients in the past

years have mostly expired, these exposures no longer need

specific treatment, and so SICR identification is carried out in

the same manner as for any other exposures.

The methodology of credit rating for banks and sovereign

classification depends on the existence or non-existence of a

rating from international credit rating agencies Fitch, Moody’s,

or S&P. Ratings are set on a basis of the average international

credit rating. If there are no international credit ratings, the

classification is based on the internal methodology of NLB

Group.

The classification into stages is based on the facility level,

nevertheless occurring delays on one facility may trigger the

Stage deterioration of other facilities of the same client. When

the SICR criteria no longer exist, the facility may be transferred

to a more favourable stage subject to the prescribed cure

periodof threemonths.

The ECL for Stage 1 financial assets is calculated based on

12-month PDs or shorter period PDs, if the remaining maturity

of the financial asset is shorter than 1 year. The 12-month

PD already includes the macroeconomic impact effect.

Allowances in Stage 1 are designed to reflect expected credit

losses that had been incurred in the performing portfolio but

have not been identified.

The ECL for Stage 2 financial assets is calculated based on

lifetime PDs (LPD) because their credit risk has increased

significantly since their initial recognition. This calculation is

also based on a forward-looking assessment that considers

a number of economic scenarios in order to recognise the

probability of losses associated with the predicted macro-

economic forecasts.

For financial instruments in Stage 3, the same treatment

is applied as for those considered to be credit impaired.

Exposures below the materiality threshold obtain collective

allowances using a PD of 100%. Financial instruments will be

transferred out of Stage 3 if they no longer meet the criteria

of being credit-impaired after a probation period. Special

treatment applies for purchased or originated credit-impaired

financial instruments (POCI), where only the cumulative

changes in lifetime expected losses since the initial recognition

are recognised as a loss allowance.

The calculation of collective allowances is performed by

multiplying the EAD (exposure at default) at the end of each

month with an appropriate PD and LGD (loss-given default).

The obtained result for each month is discounted to the

present time using the original effective interest rate of the

facility. For Stage 1 exposures, the ECL only takes a 12-month

period into account, while for Stage 2 or 3 all potential losses

until the maturity date are included. Risk parameters are

calculated separately for each of the three possible scenarios.

The final ECL for each facility is calculated as a weighted

average ECL for each scenario.

The EADrepresents theanticipated outstandingamount

owed by the obligor, which is determined as the sum of

on-balance exposure and expected future drawings of the

off-balance exposure. The drawings are assessed by applying

the CCF (credit conversion factor) based on the Bank’s historic

experience with similar types of facilities.

![]()

193

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

The PD is the estimation of likelihood of default over a given

time horizon. The estimation is performed separately for each

uniquesegment (corporate clientsby size, institutions, central

government) or by product group (mortgage, consumer

loans and other retail products). Through the cycle, the PD is

supplemented with the forward-looking aspect using three

possible scenarios.

The LGD parameter reflects the expected loss the facility

will incur in case of the event of default. The LGD value is

assessed based on the Bank’s historic data on repayments

from different types of collateral (hair-cuts are calculated

for homogenic groups of collateral), as well as other types of

repayments such as regular/partial repayments, repayments

from legal proceedings, the sale of receivables, and others.

Through the cycle, the LGD is supplemented with the forward-

looking aspect to reflect the expected changes in the

macroeconomic parameters using three possible scenarios.

Risk parameter calculations are based on the data from

each subsidiary,while the calculations and modelling are

performed centrally. In the case where the data samples are

not sufficiently large, hurdle rates are applied based on the

regulatory or other benchmarks.

Expected Life

When measuring ECL, the Bank must consider the maximum

contractual period over which the Bank is exposed to credit

risk. For certain revolving credit facilities that do not have

a fixed maturity, the expected life is estimated based on

the period over which the Bank is exposed to credit risk

and where the credit losses would not be mitigated by

management actions.

Forward-looking information

In 2021, the Group reviewed IFRS 9 provisioning by testing a set

of relevant macroeconomic scenarios to adequately reflect the

current circumstances and the related impacts in the future.

NLB Group established and developed multiple scenarios

(i.e., baseline, mild, and severe) on the level of ECL calculation.

The baseline scenario presents our forecast macroeconomic

view for all countries present in the NLB Group. This scenario

is constructed to culminate various outlooks into a unified

projection of macroeconomic and financial variables for the

NLB Group. This approach is in line with the concept that the

NLB Group has a consolidated view of the future of economic

development in Southeast Europe (SEE). The IFRS 9 baseline

scenario relies on the NLB monthly Economic Outlook created

in April 2021.

The macroeconomic rationale behind the alternative scenarios is

related to a range of plausible effects of the COVID-19 pandemic

on economic development during the next three years (the

so-called ‘post-COVID-19 period’). The basis for the alternative

scenarios is related to the ECB’s view of economic development

after the coronavirus outbreak in early 2020. Based on the

ECB illustration of a mild and severe scenario resolution of the

pandemic crisis through the lens of the possible expected impact

on economic activity in the euro area, the Group developed both

alternative scenarios. In general, the mild scenario envisions

a resolution of the health crisis by the end of 2021 and a long-

term reviving process of the economy, while a severe scenario

assumes a more protracted crisis and permanent losses

in economic potential.These scenarios are included in the

calculation of expected credit losses under IFRS 9. Apart from

this important innovation, we had to keep track of the latest

economic developments and changing official projections.

This latest set of IFRS 9 scenarios for macroeconomic

variables is applied in the modelling process for the

probability of default (PD) and loss given default (LGD)

estimates. Nevertheless, our focus in macroeconomic

scenarios is on the trajectory of real GDP and the

unemployment rate over the projection horizon from 2021 to

2023. Both variables are included in the modelling process of

PD and LGD,respectively.

Macroeconomic scenarios for explanatory variables,

developed for each country in the NLB Group (in %):

Mild scenarioBaseline scenarioSevere scenario

Slovenia202120222023202120222023202120222023

Real GDP7.24.43.74.543.52.32.14.2

Unemployment rate

4.8

4.43.9

5

54.5

5.25.7

5.2

Mild scenarioBaseline scenarioSevere scenario

Bosnia and Herzegovina202120222023202120222023202120222023

Real GDP4.83.83.133.531.51.93.6

Unemployment rate16.714.713.917.516.51618.318.918.3

Mild scenarioBaseline scenarioSevere scenario

Montenegro202120222023202120222023202120222023

Real GDP10.45.53.76.553.53.32.74.2

Unemployment rate15.714.213.516.51615.517.318.417.7

Mild scenarioBaseline scenarioSevere scenario

North Macedonia202120222023202120222023202120222023

Real GDP6.44.43.7443.522.14.2

Unemployment rate16.214.713.91716.51617.818.918.3

Mild scenarioBaseline scenarioSevere scenario

Serbia202120222023202120222023202120222023

Real GDP84.94.254.542.52.44.8

Unemployment rate9.187.49.598.59.910.39.7

Mild scenarioBaseline scenarioSevere scenario

Kosovo202120222023202120222023202120222023

Real GDP7.24.94.24.54.542.32.44.8

Unemployment rate24.322.221.325.52524.526.728.728

![]()

194

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

NLB Group formed three probable scenarios with an

associated probability of occurrence for forward-looking

assessment of risk provisioning in the context of IFRS 9. The

scenarios are weighted 20-60-20, where both alternative ones

(i.e., mild and severe) receive a weight of 20%. The assigned

weight for the baseline scenario is 60%.

Recalculation is performed annually of all risk parameters.

IFRS 9 macroeconomic scenarios incorporate the forward-

looking and probability-weighted aspects of ECL impairment

calculation. Both features may change when material changes

in the future development of the economy are recognised and

not embedded in previous forecasts. Then all the parameters

are recalculated according to new weight and projections.

The favourable macroeconomic environment has the most

significant impact on expected credit losses in 2021. This

change in macroeconomic scenarios affects forward-looking

values of risk parameters during the post-COVID-19 period.

Risk parameter overlaysand mark-ups

NLB Group implemented overlays and mark-ups on forward-

looking PD and LGD, respectively. PD overlay measures are

implemented to address prediction errors from the back-

testing exercise in particular segments and rating categories.

In addition, mark-ups on the LGD risk parameter are applied

by NLB Group members due to the particularities of the local

market.

Effects of changedrisk parameters

Effects of changed risk parameters on the amount of expected

credit losses are disclosed in notes 5.14. and 5.16.b).

b)Individual assessment of allowances for impaired

financial assets

NLB Group assesses impairments of financial assets

separately for all individually significant assets classified in

Stage 3. The materiality threshold is set at EUR 0.5 million

exposure for legal entities and EUR 0.1 million for private

persons on the level of NLB, while the Group members apply

lower thresholds applicable to their portfolio size. All other

financial assets obtain collective allowances.

The amount of loss is measured as the difference between the

asset’s carrying amount and the present value of estimated

future cash flows, which are discounted to the estimation

date. The scenario of expected cash flows can be based on

the ‘going concern’ assumption, where the cash flow from

operations is considered along with the sale of collateral

that is not crucial for future business. In the case of the ‘gone

concern’ principle, the repayments are based on expected

cash flows from the sale of collateral. The expected payment

from the collateral is calculated from the appraised market

value of the collateral, the haircut used as defined in the

Haircut Methodology, and discounted. Off-balance sheet

liabilities are also assessed individually and, where necessary,

related allowances arerecognised as liabilities.

The carrying amount of financial assets measured at

amortised cost is reduced through an allowance account

and the loss is recognised in the income statement line item

‘Impairment of financial assets.’If the amount of allowances

for ECL decreases subsequently due to an event occurring

after the impairment was recognised (e.g., repayment in the

collection process exceeds the assessed expected payment

from collateral), the reversal of the loss is recognised as a

reduction in the allowance account, and the gain is recognised

in the same income statement item. For off-balance

exposures, the amount of ECL is recognised in the statement

of financial position in the line item ‘Provisions’ and in the

income statement in the line item ‘Provisions for credit losses.’

The ECLs for debt instruments measured at fair value through

other comprehensive income do not reduce the carrying

amount of these financial assets in the statement of financial

position, which remains at fair value. Instead, an amount equal

to the allowance that would arise if the assets were measured

at amortised cost is recognised in other comprehensive

income as an accumulated impairment amount, with a

corresponding charge to profit or loss. The accumulated loss

recognised in other comprehensive income is recycled to

the profit or loss upon derecognition of the assets, or when

the amount of allowances for ECL decreases due to an event

occurring after the impairment was recognised.

2.14.

Forborne loans

A forborne loan (or restructured financial asset) arises as

a result of a debtor’s inability to repay a debt under the

originally agreed terms, either by modifying the terms of the

original contract (via an annex) or by signing a new contract

under which the contracting parties agree the partial or

total repayment of the original debt. Loans with deferral of

payment approved in line with the national legislation on

intervention measures in response to SARS-CoV-2 (COVID-19)

pandemic until 30 September 2020 are not forborne loans.

Loans with deferrals of payment under COVID-19 measures

approved after 30 September 2020 are subject of assignment

of forbearance status, except in cases, where detailed review

and analysis sufficiently justify that the client is not in financial

difficulties. If to receivables due from the client the status of

restructuring is introduced, the debtor must be classified in

the rating group C or lower.

The definitions of forborne loans closely follow definitions that

were developed by the European Banking Authority (EBA).

These definitions aim to achieve comprehensive coverage

of exposures to which forbearance measures have been

extended.

The accounting treatment of forborne loans depends

on the type of restructuring. When NLB Group embarks

on a forborne loan via the modified terms of repayment

proceeding from extending the deadline for the repayment

of the principal and/or interest, and/or a forbearance of the

repayment of the principal, and/or interest or a reduction

in the interest rate, and/or other expenses, it adjusts the

carrying amount of the forborne loan on the basis of the

discounted value of the estimated future cash flows under

the modified terms, and recognises the resulting effect in

profit or loss. In the event of the reduction of a claim against

the debtor via the reduction in the amount of the claims as a

result of a contractually agreed debt waiver and ownership

restructuring or debt to equity swap, NLB Group derecognises

the claim in the part relating to the write-down or the

contractually agreed upon debt waiver. The new estimate of

the future cash flows for the residual claim, not yet written

down, is based on an updated estimate of the probability of

loss. NLB Group considers the debtor’s modified position, the

economic expectations, and the collateral of the forborne

loan. When NLB Group is embarking on the forborne loan

by taking possession of other assets (i.e., property, plant and

equipment, securities, and other financial assets), including

investments in the equity of debtors obtained via debt-

to-equity swaps, it recognises the acquired assets in the

statement of financial position at fair value, recognising the

difference between the fair value of the asset and the carrying

amount of the eliminated claim in profit or loss.

Forborne exposures may be identified in both the performing

and non-performing parts of the portfolio. Where the

forborne loan is classified in the non-performing part of

the portfolio, it can be reclassified to the performing part if

exposure is no longer considered as impaired or defaulted, if

determined amounts were repaid, if one year has passed from

the latest of the events defined (introduction of forbearance,

![]()

195

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

classification in the non-performing part, repayment of

the last overdue amount, end of the grace period) and

after the introduction of forbearance there have been no

overdue amounts or doubts concerning the repayment of

the entire exposure, under the terms and conditions after the

forbearance. The absence of doubt is confirmed by analysis of

the financial situation of the debtor.

The forborne status is withdrawn when:

•at least a 2-year probation period has passed since the

latest of:

•the moment of extending the restructuring measures or

•the forborne exposure was deemed performing;

•regular payments of the principal or interest were made, in

a substantial total amount, during at least half the probation

period;

•no exposure, in the probation period, is more than 30 days

in default of more than EUR 100;

•

the client fulfils determined financial indicators.

In the case of a deferral of payment approved due to the

COVID-19 crisis, the probation period is extended for the

period of deferral.

2.15.

Repossessed assets

In certain circumstances, assets are repossessed following the

foreclosure on loans that are in default. Repossessed assets are

initially recognised in the financial statements at their fair value

and classified in the appropriate category according to their

purpose and are sold as soon as it is feasible in order to reduce

exposure (note 6.1.l). After initial recognition, repossessed

assets are measured and accounted for in accordance

with the policies applicable to the relevant asset categories.

Repossessed assets mainly represent items of real estate that

NLB Group classifies within investment properties measured in

accordance with an IAS 40 Investment property (note 2.20.), and

other assets measured in accordance with IAS 2 Inventories.

Real estate obtained as collateral from the foreclosure of

loans and receivables, classified as other assets are initially

recognised at fair value less costs to sell (realisable value),

wherein only the direct costs of sales can be considered. At

subsequent measurement, the realisable value is verified

at least annually. Valuations of the fair value of real estate

are performed by certified real estate appraisers. The real

estate is impaired when the carrying value exceeds the

realisable value. The effect of impairment is recognised as the

impairment of other assets and the reversal of impairment as

income from the reversal of the impairment of other assets.

2.16.

Offsetting

Financial assets and liabilities are offset, and the net amount

reported in the statement of financial position when there is

a legally enforceable right to offset the recognised amounts,

and there is an intention to settle on a net basis, or to realise

the asset and settle the liability simultaneously.

2.17.

Sale and repurchase agreements

Securities sold under sale and repurchase agreements

(repos) are retained in the financial statements, and the

counterparty liability is recognised in financial liabilities

measured at an amortised cost. Securities sold subject to sale

and repurchase agreements are reclassified in the financial

statements as pledged assets when the transferee has the

right by contract or custom to sell or re-pledge the collateral.

Securities purchased under agreements to resell (reverse

repos) are presented as loans to other banks or customers, as

appropriate.

In financial statements, the difference between the sale and

repurchase price is treated as interest and accrued over

the life of the repo agreements using the effective interest

method.

2.18.

Property and equipment

All items of property and equipment are initially recognised

at cost. They are subsequently measured at cost less any

accumulated depreciation and any accumulated impairment

loss.

Each year, NLB Group assesses whether there are indications

that property and equipment may be impaired. If any such

indication exists, the recoverable amounts are estimated. The

recoverable amount is the higher of the fair value less costs

to sell and value in use. If the recoverable amount exceeds

the carrying value, the assets are not impaired. If the carrying

amount exceeds the recoverable amount, the difference is

recognised as an impairment loss in the income statement.

Items of a largely independent property and equipment

which do not generate cash flows are included in the cash-

generating unit and later tested for possible impairment.

Depreciation is calculated on a straight-line basis over

the assets’ estimated useful lives. The following annual

depreciation rateswere applied:

NLB Group and NLBin %

Buildings2-5

Leasehold improvements5-25

Computers14.3-50

Furniture and equipment10-33.3

Motor vehicles12.5-25

Depreciation does not begin until the assets are available for use.

The assets’ residual values and useful lives are reviewed and

adjusted if appropriate on each reporting date. Gains and

losses on the disposal of items of property and equipment

are determined as the difference between the sale proceeds

and their carrying amount and are recognised in the income

statement.

Maintenance and repairs are charged to the income

statement during the financial period in which they are

incurred. Subsequent costs that increase future economic

benefits are recognised in the carrying amount of an asset,

and the replaced part, if any, is derecognised.

2.19.Intangible assets

Intangible assets include software licenses, goodwill (note

2.5.), and identifiable intangible assets acquired in a business

combination. Intangible assets other than goodwill, have a

finite useful life and are in the statement of financial position

stated at cost, less accumulated amortisation and impairment

losses. Amortisation is calculated on a straight-line basis at

rates designed to write-down the cost of an intangible asset

over its estimated useful life. The core banking system is

amortised over a period of 10 years, and other software over a

period of three to five years. Amortisation does not begin until

the assets are available for use.

The identifiable intangible assets acquired in a business

combination and recognised separately from goodwill, are

recorded at fair value on the acquisition date if the intangible

asset is separable or arises from contractual or other legal

rights. After initial recognition, intangible assets acquired in a

![]()

196

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

business combination are measured in accordance with IAS

38 Intangible Assets. Additionally identified intangible assets

acquired in a business combination in December 2020 (note

5.12.c) relate to core deposits and trade name. Their useful

life is assessed to be 5 years. Amortisation of a trade name

is calculated on a straight-line basis, while for core deposits

accelerated amortisation is applied, since it better reflects the

pattern of asset’s consumption.

2.20.

Investment properties

Investment properties include properties held to earn rentals,

or to increase the value of a long-term investment, rather than

to be used by NLB Group. Investment properties are carried

at fair value determined by a certified appraiser. Fair value is

based on current market prices. Any gain or loss arising from a

change in the fair value is recognised in the income statement.

2.21.Non-current assets and disposal

groups classified as held for sale

Non-current assets and disposal groups are classified as held

for sale if their carrying amount will be recovered through

a sale transaction rather than through continuinguse. This

condition is deemed to be met only when the sale is highly

probable, and the asset is available for immediate sale in its

present condition. Management must be committed to the

sale, which should be expected to qualify for recognition as a

completed sale within one year from the date of classification.

Non-current assets and disposal groups classified as held

for sale are measured at the lower of the assets’ previous

carrying amount and fair value less costs to sell.

In the case of business combinations, NLB Group measures

an acquired non-current asset (or disposal group) that

is classified as held for sale at the acquisition date in

accordance with IFRS 5 Non-current Assets Held for Sale and

Discontinued Operations at fair value less costs to sell.

During subsequent measurement, certain assets and liabilities

of a disposal group that are outside the scope of IFRS 5

measurement requirements are measured in accordance

with the applicable standards (e.g., deferred tax assets,

assets arising from employee benefits, financial instruments,

investment property measured at fair value, and contractual

rights under insurance contracts). Tangible and intangible

assets are not depreciated. The effects of sale and valuation

are included in the income statement as a gain or loss from

non-current assets held for sale.

Liabilities directly associated with disposal groups are

reclassified and presented separately in the statement of

financial position.

2.22.Accounting for leases

A lease is a contract, or part of a contract, which creates

enforceable rights and obligations and conveys the right

to control the use of an identified asset for a period of

time in exchange for consideration. Thus, IFRS 16 requires

determination whether a contract is, or contains, a lease.

NLB Group as a lessee

NLB Group recognises a liability to make lease payments and

an asset representing the right to use the underlying asset

(i.e., the right-of-use asset) during the lease term for all leases,

except for short-term leases and leases of low-value. Short-

term leases are defined as those which at the commencement

date have a lease term of 12 months or less without the option

to purchase the underlying asset. Leases of underlying assets

with a value, when new, lower or equal to EUR 5 thousand

are defined as low value leases, and are thus recognised as

expenses on a straight-line basis over the lease term.

Right-of-use assets

At the commencement date, NLB Group measures the

right-of-use asset at cost, reduced by any accumulated

depreciation and impairment losses, and adjusted for any

remeasurement of lease liabilities. The cost of right-of-use

assets consists of the amount of lease liabilities recognised,

initial direct costs incurred, an estimate of costs to be incurred

by the lessee in dismantling, and removing the underlying

asset to the condition required by the terms and conditions

of the lease and lease payments made at or before the

commencement date less any lease incentives received. After

the commencement date, NLB Group measures the right-of-

use asset using a cost model and recognises depreciation

of the right-of-use assets, on a straight-line basis over the

lease term, and (separately) interest on the lease liabilities.

In the statement of financial position, right-of-use assets are

presented in the line item ‘Property and equipment.’

Lease liabilities

At the commencement date, NLB Group measures the lease

liability at the present value of the lease payments that are

not paid at that date. The lease payments consist of fixed

payments, variable lease payments that depend on an

index or a rate, amounts expected to be paid under residual

value guarantees, the exercise price of a purchase option if

there exists a reasonable certainty for it to be exercised, and

payments of penalties for terminating the lease, if the lease

term reflects exercising the option to terminate. Subsequently

(after the commencement date), NLB Group measures the

lease liability by:

•increasing the carrying amount to reflect interest on the

lease liability;

•reducing the carrying amount to reflect the lease payments

made;

•remeasuring the carrying amount to reflect any

reassessment or lease modifications.

In the statement of financial position, lease liabilities are

presented in line item ‘Other financial liabilities.’

NLB Group as a lessor

Payments under operating leases are recognised as income

on a straight-line basis over the period of the lease. Assets

leased under operating leases are presented in the statement

of financial position as investment property or as property

and equipment.

NLB Group classifies a lease as a finance lease when the

risks and rewards incidental to ownership of a leased asset

lie with the lessee. When assets are leased under a finance

lease, the present value of the lease payments is recognised

as a receivable. Income from finance lease transactions is

amortised over the lifetime of the lease using the effective

interest method. Finance lease receivables are recognised at

an amount equal to the net investment in the lease, including

the unguaranteed residual value.

Sale-and-leaseback transactions

NLB Group also enters into sale-and-leaseback transactions

(in which NLB Group is primarily a lessor) under which the

leased assets are purchased from, and then leased back to

the lessee. These contracts are classified as finance leases or

operating leases, depending on the contractual terms of the

leaseback agreement.

Leases recognised in a business combination

In all leases acquired in a business combination, the acquiree

is the lessee. For such leases, NLB Group applies the IFRS 16

initial measurement provisions (with exceptions for leases with

remaining term of 12 months or less and low value leases) and

recognises the acquired lease liability as if the lease contract

![]()

197

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

was a new lease at the acquisition date. The right-of-use asset

is measured at an amount equal to the recognised liability.

There are no favourable or unfavourable terms of the leases

relative to market terms, which would require the adjustment

of the right-of-use assets.

2.23.Cash and cash equivalents

For the purpose of the statement of cash flows, cash and

cash equivalents comprise cash and balances with central

banks and other demand deposits at banks, debt securities

held for trading, loans to banks, and debt securities not held

for trading with an original maturity of up to three months.

Cash and cash equivalents are disclosed under the cash flow

statement.

2.24. Borrowings, deposits, and issued debt

securities with characteristics of debt

Loans and deposits received and issued debt securities are

initially recognised at fair value. Borrowings are subsequently

measured at the amortised cost. The difference between the

value at initial recognition and the final value is recognised

in the income statement as interest expenses, applying the

effective interest rate.

Repurchased own debt is disclosed as a reduction of

liabilities in the statement of financial position. The difference

between the book value and the price at which own debt was

repurchased is disclosed in the income statement.

2.25. Other issued financial instruments

with characteristics of equity

Upon initial recognition, other issued financial instruments

are classified in part or in full as equity instruments if the

contractual characteristics of the instruments are such

that NLB Group must classify them as equity instruments in

accordance with IAS 32 Financial Instruments: Presentation.

An issued financial instrument is only considered an equity

instrument if that instrument does not represent a contractual

obligation for payment.

Issued financial instruments with characteristics of equity are

recognised in equity in the statement of financial position.

Transaction costs incurred for issuing such instruments are

deducted from equity reserves. The corresponding interest is

recognised directly in profit reserves.

The carrying value of an issued financial instrument with

characteristics of equity is presented in the statement of

changes in equity in the line item ‘Other Equity Instruments.’

2.26.

Provisions

Provisions are recognised when NLB Group has a present

legal or constructive obligation as a result of past events,

and it is probable that an outflow of resources embodying

economic benefits will be required to settle the obligation,

and a reliable estimate of the amount of the obligation can

be made. They are recognised in the amount that is the best

estimate of the expenditure required to settle the present

obligation at the end of the reporting period. When the effect

of the time value of money is material, NLB Group determines

the level of provisions by discounting the expected cash flows

at a pre-tax rate reflecting the current rates specific to the

liability.

2.27.Contingent liabilities and commitments

Financial and non-financial guarantees

Financial guarantees are contracts that require the issuer to

make specific payments to reimburse the holder for a loss it

incurs because a specific debtor fails to make payments when

due, in accordance with the terms of debt instruments. Such

financial guarantees are given to banks, financial institutions,

and other bodies on behalf of the customer to secure loans,

overdrafts, and other banking facilities.

The issued guarantees covering non-financial obligations of

the clients represent the obligation of the Bank (guarantor) to

pay if the client fails to perform certain works in accordance

with the terms of the commercial contract.

Financial and non-financial guarantees are initially

recognised at fair value, which is usually evidenced by the fees

received. The fees are amortised to the income statement over

the contract term using the straight-line method. NLB Group’s

liabilities under guarantees are subsequently measured at the

greater of:

•the initial measurement, less amortisation calculated to

recognise fee income over the period of guarantee; or

•ECL provisions as set out in note 2.13.

Documentary letters of credit

Documentary (and standby) letters of credit constitute a

written and irrevocable commitment of the issuing (opening)

bank on behalf of the issuer (importer) to pay the beneficiary

(exporter) the value set out in the documents by a defined

deadline:

•if the letter of credit is payable on sight; and

•if the letter of credit is payable for deferred payment, the

bank will pay according to the contractual agreement when

and if the beneficiary (exporter) presents the bank with

documents that are in line with the conditions and deadlines

set out in the letter of credit.

A commitment may also take the form of a letter of credit

confirmation, which is usually done at the request or

authorisation of the issuing (opening) bank and constitutes a

firm commitment by the confirming bank, in addition to that of

the issuing bank, which independently assumes a commitment

to the beneficiary under certain conditions.

Other contingent liabilities and commitments

Other contingent liabilitiesand commitmentsrepresent

undrawn loan commitments to extend credit, uncovered

letters of credit, and other commitments.

The nominal contractual values of guarantees, letters of

credit, and undrawn loan commitments where the loan

agreed to be provided is on market terms, are not recognised

in the statement of financial position.

Contingent liabilities recognised in a business combination

A contingent liability recognised in a business combination is

initially measured at its fair value. After initial recognition, it is

measured at the higher of:

•the amount that would be recognised in accordance with

IAS 37 Provisions, Contingent Liabilities and Contingent

Assets; or

•the amount initially recognised less, if appropriate, the

cumulative amount of income recognised in accordance

with the principles of IFRS 15 Revenue from Contracts with

Customers. This requirement does not apply to contracts

accounted for in accordance with IFRS 9.

2.28.

Taxes

Income tax expenses comprises current and deferred income tax.

Current corporate income tax in NLB Group is calculated on

taxable profits at the applicable tax rate in the respective

jurisdiction. The corporate income tax rate for 2021 in Slovenia

was 19% (2020: 19%).

Current and deferred taxes are recognised in profit or loss,

except to the extent that they relate to a business combination

or taxes related to effects recognised directly in equity

(deferred tax related to the fair value re-measurement

of financial assets measured at fair value through other

comprehensive income, cash flow hedges, and actuarial gains

and losses on defined benefit pension plans is charged or

credited directly to other comprehensive income).

![]()

198

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Deferred income tax is calculated using the balance sheet

liability method for temporary differences arising between the

tax bases of assets and liabilities, and their carrying amounts

for financial reporting purposes.

Deferred tax assets are recognised if it is probable that future

taxable profit will be available in the foreseeable future

against which the temporary differences can be utilised.

Deferred tax assets and liabilities are measured at tax rates

enacted or substantively enacted at the end of the reporting

period that are expected to apply to the period when the asset

is realised, or the liability is settled. At each reporting date,

NLB Group reviews the carrying amount of deferred tax assets

and assesses future taxable profits against which temporary

taxable differences can be utilised.

Deferred tax assets for temporary differences arising from

impairments of investments in subsidiaries, associates and

joint ventures are recognised only to the extent that it is

probable that:

•the temporary differences will be reversed in the

foreseeable future; and

•taxable profit will be available.

Slovenian tax law does not set deadlines by which uncovered

tax losses must be utilised.

In the case of business combination deferred tax balances are

recognised if related to temporary differences and carry-

forwards of an acquiree that exist at the acquisition date or

if they arise as a result of the acquisition. Income taxes are

measured in accordance with IAS 12 Income Taxes.

A tax on financial services is a tax on fees, paid for prescribed

financial services rendered (financial services, exempt from

value added tax (with the exception of securities transactions)

and the services of insurance brokers and agents), paid in

Slovenia. The tax rate is 8.5% (2020: 8.5%) and the tax is paid

monthly. Given that the tax on financial services is classified

as a sales tax, it reduces accrued revenues in the financial

statements.

2.29.

Fiduciary activities

NLB Group provides asset management services to its clients.

Assets held in a fiduciary capacity are not reported in NLB

Group’s financial statements as they do not represent assets

of NLB Group. Fee and commission income and expenses

relating to fiduciary activities are generally recognised in the

income statement when the service has been provided (see

also note 2.10.). Fee and commission income charged for this

type of service is broken down by items in note 4.3.b). Further

details on transactions managed on behalf of third parties are

disclosed in note 5.24.

Based on the requirements of Slovenian legislation, NLB

Group has, in note 5.24., additionally disclosed the assets and

liabilities on accounts used to manage financial assets from

fiduciary activities, i.e., information related to the receipt,

processing, and execution of orders and related custody

activities.

2.30.

Employee benefits

Employee benefits include:

•short-term employee benefits (such as salaries,

compensations, annual holiday allowance, separation

allowance,and non-monetary benefits);

•

reimbursement of commuting costs, meal allowance,

compensation for use of own resources);

•

retirement indemnity bonuses (post-employment benefits);

•other employment benefits (jubilee long-service benefits,

voluntary supplementary pension insurance);

•

variableremuneration.

Short-term employee benefits are recognised in the period to

which they relate and included in the income statement line

item ‘Administrative expenses.’ Among others they include the

payment of contributions for pension and disability insurance,

which according to local legislation (for employer) amount to

8.85% of the gross salaries.

According to legislation, employees retire after they fulfil

certain conditions according to Pension and Disability

Insurance Act (ZPIZ), they are entitled to a lump-sum

severance payment. Employees are also entitled to a long-

service bonus for every 10 years of service in NLB.

These obligations are measured at the present value of future

cash outflows considering future salary increases and other

conditions, and then apportioned to past and future employee

service based on the benefit plan’s terms and conditions.

Service costs are included in the income statement in the

line item ‘Administrative expenses’ as defined benefit costs,

while interest expenses on the defined benefit liability are

recognised in the line item ‘Interest and similar expenses.’

These interest expenses represent the change during the

period in the defined benefit liability that arises from the

passage of time. For post-employment benefits, actuarial

gains and losses from the effect of changes in actuarial

assumptions and experience adjustments (differences

between the realised and expected payments) arerecognised

in other comprehensive income under the line item ‘Actuarial

Gains/(Losses) on Defined Benefit Pensions Plans,’ and will

not be recycled to the income statement. Actuarial gains

and losses that relate to other employment benefits are

recognised in the income statement as defined benefit costs.

In the statement of financial position, liabilities for short-

term employee benefits are included in the line item ‘Other

liabilities,’ while liabilities for post-employment benefits and

other employment benefits (jubilee long-service benefits) are

included in the line item ‘Provisions.’

In the case of a business combination employee benefits

are recognised and measured in accordance with IAS 19

Employee Benefits, i.e., not at fair value.

2.31.Share capital

Dividends on ordinary shares

Dividends on ordinary shares are recognised in equity in the

period in which they are approved by NLB’s shareholders.

Treasury shares

If NLB or another member of NLB Group purchases NLB’s

shares, the consideration paid is deducted from the total

shareholders’ equity as treasury shares. If such shares are

subsequently sold, anyconsideration received is included in

equity. If NLB’s shares are purchased by NLB itself or other

NLB Group entities, NLB creates reserves for treasury shares

in equity.

Share issue costs

Costs directly attributable to the issue of new shares are

recognised in equity as a reduction in the share premium

account.

2.32.

Segment reporting

Operating segments are reported in a manner consistent with

internal reporting to the Management Board, which is the

executive body that makes decisions regarding the allocation

of resources and assesses the performance of a specific

segment.

Transactions between organisational units (OUs) are

managed under normal operating conditions. Interest income

among individual OUs in the parent bank (NLB) is allocated

using a fund transfer pricing method and shown within the

![]()

199

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

net interest income of each OU. Net non-interest income is

allocated to the OU that actually provides the service that

generates income. Direct costs are attributed to the segment

that is directly related to the provided service and indirect

costs (costs which service centres provide for profit centres)

are attributed to the segment for which the service is provided,

whereas overhead costs are allocated according to general

keys. External net income is the net income of NLB Group

from the consolidated income statement. Income tax is not

allocated between segments. Analysis by segment for NLB

Group is presented in note 7.a).

In accordance with IFRS 8, NLB Group has the following

reportable segments: Retail Banking in Slovenia, Corporate

and Investment Banking in Slovenia, Strategic Foreign

Markets, Financial Markets in Slovenia, Non-core members,

and OtherActivities.

2.33.Critical accounting estimates and

judgments in applying accounting policies

NLB Group’s financial statements are influenced by

accounting policies, assumptions, estimates, and

management’s judgment. NLB Group makes estimates and

assumptions that affect the reported amounts of assets and

liabilities within the next financial year. All estimates and

assumptions required in conformity with the IFRS are best

estimates undertaken in accordance with the applicable

standard. Estimates and judgments are evaluated on a

continuing basis, and are based on past experience and other

factors, including expectations with regard to future events.

a) Allowances for expected credit losses on loans and

advances

NLB Group monitors and checks the quality of the loan

portfolio at the individual and portfolio levels to continuously

estimate the necessary allowances for ECL. NLB Group

creates individual allowances for individually significant

financial assets attributed to Stage 3. Such an assignment is

based on information regarding the fulfilment of contractual

obligations or other financial difficulties of the debtor, and

other important facts. Individual assessments are based on

the expected discounted cash flows from operations and/or

the assessed expected payment from collateral.

Allowances are assessed collectively for financial assets

assigned to Stage 1 or 2, or for financial assets in Stage 3

with exposure below the materiality threshold. The ECL in

this group of assets are estimated based on expected value

of risk parameters combining the historic movements with

the future macroeconomic predictions for three separate

scenarios. Themodels used to estimate future risk parameters

are validated and back-tested on a regular basis to make loss

estimations as realistic as possible.

NLB Group performs regular stress-testing as part of the

ICAAP process normative approach, where the 3-year budget

is tested for adverse circumstances. The selected stress

scenario predicts adverse economic circumstances as a result

of the prolonged COVID-19 pandemic.

In terms of credit risk, the scenario has an unfavourable impact

on default rates (transfer of assets from performing to default)

and loss rates (expected losses after occurrence of default).

Furthermore, a transfer of assets within the performing sub-

portfolio to rating classes with worse default probabilities is

envisaged. Based on the existing exposures (static balance

sheet assumption), additional allowances for expected credit

losses are assessed on existing default exposures and new

default flows, as well as on the remaining performing portfolio.

The results of the stress scenario for NLB Group shows an

increase of credit risk impairments in the first year of stress

by EUR 139.6 million (2020: EUR 134.7 million), and an increase

in the coverage of the credit portfolio by impairments by 0.98

percentage points (2020: 0.90 percentage points).

b)Fair value of financial instruments

The fair values of financial investments traded on the active

market are based on current bid prices (financial assets) or

offer prices (financial liabilities).

The fair values of financial instruments that are not traded on

the active market are determined by using valuation models.

These include a comparison with recent transaction prices,

the use of a discounted cash flow model, valuation based on

comparable entities, and other frequently used valuation models.

These valuation models at their best estimate reflect current

market conditions at the measurement date, which may not be

representative of market conditions either before or after the

measurement date. Management reviewed all applied models

as at the reporting date to ensure they appropriately reflect

current market conditions, including the relative liquidity of the

market and the applied credit spread. Changes in assumptions

regarding these factors could affect the reported fair values

of financial instruments held for trading, and financial assets

measured at fair value through other comprehensive income.

In year 2020, the volatility of prices on various markets

increased as a result of the spread of COVID-19. Therefore,

NLB Group decided to sell some securities with increased

credit spreads as part of its strategy to manage the credit

risk. Most of these securities were classified as measured at

fair value through other comprehensive income (EUR 250,297

thousand at NLB Group and EUR 222,586 thousand at NLB),

while EUR 120,131 thousand of sold securities were measured

at amortised cost. The total realised gains due to sales of

securities amount to EUR 17,815 thousand at NLB Group and

EUR 17,096 thousand at NLB (note 4.4.).

Due to increased frequency and values of sales of securities

measured at amortised cost, NLB Group reassessed whether

there has been a change in its business model for managing

financial assets. Sales were made due to an increase in the

assets’ credit risk, and are therefore consistent with a held to

collect business model because the credit quality of financial

assets is relevant to NLB Group’s ability to collect contractual

cash flows. Credit risk management activities that are aimed

at minimising potential credit losses due to credit deterioration

are integral to such a model.

Furthermore, the sales were made as a response to COVID-19

situation and the increased volume of sales is not expected to

persist. It is expected, that future sales volumes will be lower in

frequency and value. So, no change in our business model has

been made.

The fair values of derivative financial instruments are

determined on the basis of market data (mark-to-market), in

accordance with NLB Group’s methodology for the valuation

of financial instruments. The market exchange rates, interest

rates, yield, and volatility curves used in valuations are based

on the market snapshot principle. Market data are saved daily

at 4 p.m., and later used for the calculation of the fair values

(market value, NPV) of financial instruments. NLB Group

applies market yield curves for valuation, and fair values are

additionally adjusted for credit risk of the counterparty.

The fair value hierarchy of financial instruments is disclosed in

note 6.5.

c)Impairment of investments in subsidiaries, associates and

joint ventures

The process of identifying and assessing the impairment of

investments in subsidiaries, associates and joint ventures is

inherently uncertain, as the forecasting of cash flows requires

![]()

200

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

the significant use of estimates, which themselves are sensitive

to the assumptions used. The review of impairment represents

management’s best estimate of the facts and assumptions

suchas:

•Future cash flows from individual investments present the

estimated cash flow for periods for which adopted business

plans are available. For core members, estimated cash

flows are based on a five-year business plan. For non-core

members, estimated cash flows are based on a period in

line with the strategy of divestment. The business plans of

individual entities are based on an assessment of future

economic conditions that will impact an individual member’s

business and the quality of the credit portfolio;

•The growth rate in cash flows for the period following the

adopted business plan is between 2.6 and 3.7%;

•

The target capital adequacy ratio of an individual bank is

between 14 and 17%;

•The discount rate derived from the capital asset pricing

model that is used to discount future cash flows is based

A sensitivity analysis of significant actuarial assumptions for post-employment benefit:

NLB GroupNLB

2021202020212020

Actuarial assumptions

Discount factor0.5% - 4.3%0.3% - 4.0%0.6%0.3%

Wage growth based on inflation, promotions,

and wage growth based on past years of service

1.8% - 4.8%1.0% - 4.0%2.5% - 3.0%2.6% - 3.0%

Other assumptions

Number of employees eligible for benefits7,0147,9962,4442,572

NLB GroupNLB

31 Dec 2021Discount rate

Future salary

increases

Discount rate

Future salary

increases

+0.5 b.p.-0.5 b.p.+0.5 b.p.-0.5 b.p.+0.5 b.p.-0.5 b.p.+0.5 b.p.-0.5 b.p.

Impact on provisions for employee benefits

- post-employment benefits (in %)

(5.3)5.75.5(5.1)(5.1)5.55.5(5.2)

NLB GroupNLB

31 Dec 2020Discount rate

Future salary

increases

Discount rate

Future salary

increases

+0.5 b.p.

-0.5 b.p.+0.5 b.p.-0.5 b.p.+0.5 b.p.-0.5 b.p.+0.5 b.p.-0.5 b.p.

Impact on provisions for employee benefits

- post-employment benefits (in %)

(4.9)3.85.3(4.8)(5.2)3.45.6(5.3)

on the cost of equity allocated to an individual investment.

The discount rate reflects the impact of a range of financial

and economic variables, including the risk-free rate and

risk premium. The value of variables used is subject to

fluctuationsoutside management’s control. Thepre-tax

discount rate is between 9.66 and 15.88% (31 December

2020: between 9.66 and 15.88%).

For strategic NLB Group members in 2021 and 2020, there

were no indications of impairment for equity investments.

In 2021, NLB impaired equity investments in non-core

members in the amount of EUR 458 thousand (2020: EUR 582

thousand).

d) Employee benefits

Liabilities for certain employee benefits are calculated by an

independent actuary. The main assumptions included in the

actuarial calculation are as follows:

The minimum discount rate is considered to be 0%.

Individual analysis is done by changing one assumption for

+/-0.5 percentage points, while all other assumptions stay

the same.

![]()

201

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

free rate. The Phase 2 amendments include a practical

expedient to require contractual changes, or changes to

cash flows that are directly required by the reform, to be

treated as changes to a floating interest rate equivalent

to a movement in a market rate of interest. The practical

expedient is also required for entities applying IFRS 4

–

Insurance Contracts

that are using the exemption from

IFRS 9

–

Financial Instruments

(and therefore, apply IAS

39

– Financial Instruments: Recognition andMeasurement

)

and for IFRS 16

–Leases

, to lease modifications required by

the IBOR reform. The amendments permit changes required

by the IBOR reform to be made to hedge designations and

hedge documentation under both IFRS 9 and IAS 39 without

the hedging relationship being discontinued. Under IFRS

7

– Financial instrument: Disclosures

amendments an entity

will be required to disclose information about new risks

arising from the reform and how it manages the transition

to alternative benchmark rates. The Phase 2 amendments

apply only to changes required by the interest rate

benchmark reform to financial instruments and hedging

relationships. Additional information about interest rate

benchmark reform is provided in note 5.5.d).

in EUR thousands

NLB GroupNLB

2021202020212020

Actuarial gains and losses due to changed financial assumptions251606292473

Actuarial gains and losses due to changes in demographic assumptions(1,211)134151200

Actuarial gains and losses due to experience(417)138(558)27

Total actuarial gains and losses for the year(1,377)

878

(115)700

NLB GroupNLB

2021202020212020

Post-employment benefit9.4 - 19.010.5 - 18.711.011.1

e)Taxes

NLB Group operates in countries governed by different

laws. The deferred tax assets recognised as at 31 December

2021 are based on profit forecasts and take the expected

manner of recovery of the assets into account. Changes

in assumptions regarding the likely manner of recovering

assets or changes in profit forecasts can lead to the

recognition of currently unrecognised deferred tax assets

or derecognition of previously created deferred tax assets.

If NLB profit projections used for estimation of the amount

of deferred tax assets which are expected to be reversed in

foreseeable future (i.e., within 5 years) would change by 10%,

the estimated amount of deferred tax assets would change by

approximately EUR 3.2 million (notes 4.16. and 5.17.).

2.34.Implementation of the new and revised

International Financial Reporting Standards

During the current year, NLB Group adopted all new

and revised standards and interpretations issued by the

International Accounting Standards Board (hereinafter:

‘the IASB’) and the International Financial Reporting

Interpretations Committee (hereinafter: ‘the IFRIC’), and

that are endorsed by the EU that are effective for annual

accounting periods beginning on 1 January 2021.

Accounting standards and amendments to existing

standards effective for annual periods beginning on

1January 2021 that were endorsed by the EU and adopted by

NLB Group

•IFRS 4 (amendment) –

Insurance Contracts

– deferral of

IFRS 9

is effective for annual periods beginning on or after

1 January 2021. Currently IFRS 4 requires insurance entities

to apply IFRS 9

– Financial Instruments

from 1 January

2021, and amendments allow them to defer the application

of IFRS 9 until the annual period beginning on or after

1January 2023. The amendment will not impact NLB Group’s

consolidated financial statements. There is no impact on

NLB Group’s and NLB’s financial statements.

•IFRS 9 (amendment), IAS 39 (amendment), IFRS 7

(amendment), IFRS 4 (amendment) and IFRS 16 (amendment)

–

Interest Rate Benchmark Reform – Phase 2

are effective

for annual periods beginning on or after 1 January 2021 with

earlier application permitted. Unlike Phase 1, which focused

on issues of the impact of the reform on financial reporting

in the period before the replacement of the existing interest

rate benchmark with a risk-free interest rate, Phase 2

focuses on issues that affect financial reporting when an

existing interest rate benchmark is replaced with a risk-

The weighted average duration of liabilities in years

The breakdown of actuarial gains and losses for post-employment benefit by causes

![]()

202

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Accounting standards and amendments to existing

standards that were endorsed by the EU, but not adopted

early by NLB Group

New and revised accounting standards and interpretations

endorsed by the EU that are not mandatory for annual

accounting periods beginning on 1 January 2021, were

not adopted early by NLB Group. These standards and

amendments are not expected to have a material impact

on the consolidated financial statements of NLB Group

in the future reporting periods and on foreseeable future

transactions. NLB Group plans to adopt the accounting

standards and amendments listed below for reporting periods

commencing on or after the effective date.

•IFRS 3 (amendment) –

Business Combinations – Reference

to the Conceptual Framework

is effective for annual periods

beginning on or after 1 January 2022. The amendments

update a reference in IFRS 3 to the Conceptual Framework

forFinancialReporting withoutchanging theaccounting

requirements for business combinations. Furthermore, the

amendments add an exception to the recognition principle

for liabilities and contingent liabilities within the scope of IAS

37 Provisions, Contingent Liabilities and Contingent Assets

or IFRIC 21 Levies. The amendments also clarify existing

guidance forcontingentassets.

•

IAS 16 (amendment) –

Property, Plant and Equipment:

Proceeds before Intended Use

is effective for annual periods

beginning on or after 1 January 2022. The amendment prohibits

the deduction from the cost of an item of property, plant and

equipment of any proceeds from the sale of produced items

while the asset is being prepared for its intended use. The

proceeds from selling such items, and the cost of producing

those items, are recognised in profit or loss. It also clarifies that

an entity is ‘testing whether the asset is functioning properly’

when it assesses the technical and physical performance of

the asset. The financial performance of the asset is not relevant

to this assessment. The amendment further requires separate

disclosure of the amounts of proceeds and costs relating

toitems produced that are not an output of the entity’s ordinary

activities. It is also necessary to disclose theline item in the

statement of comprehensive income where the proceeds are

included. NLB Group and NLB do not expect an impact on their

financial statements.

•IAS 37 (amendments) –

Provisions, Contingent Liabilities and

Contingent Assets: Onerous Contracts – Cost of Fulfilling

a Contract

is effective for annual periods beginning on or

after 1 January 2022. The amendments modify the standard

regarding costs a company should include as the cost of

fulfilling a contract when assessing whether a contract is

onerous. The amendments specify that the ‘cost of fulfilling’

a contract comprises the ‘costs that relate directly to the

contract.’ The costs that relate directly to a contract can

either be incremental costs of fulfilling that contract or

an allocation of other costs that relate directly to fulfilling

contracts. NLB Group and NLB do not expect an impact on

their financial statements.

•Annual Improvements to IFRS Standards 2018-2020

(amendments) are effective for annual periods beginning on

or after 1 January 2022. The amendments to IFRS 9 clarify

which fees and costs should be included in the ‘10 per cent’

test for derecognition of a financial liability. The amendment

to IFRS 16

– Leases

removes from the example the illustration

of the reimbursement of leasehold improvements by the

lessor in order to resolve any potential confusion regarding

the treatment of lease incentives.The amendments to IFRS

1

– First-time Adoption of International Financial Reporting

Standards

permits a subsidiary that becomes a first-time

adopter of IFRS Standards later than its parent to measure

cumulative translation differences at amounts included in

the consolidated financial statements of the parent, based

on the parent’s date of transition to IFRS Standards.The

amendments to IAS 41 –

Agriculture

remove the requirement

to exclude cash flows for taxation when measuring fair value

under IAS 41. This amendment is intended to align with the

requirement in the standard to discount cash flows on a post-

tax basis. This will ensure consistency with the requirements

in IFRS 13

–

Fair ValueMeasurement

. NLB Group and NLB do

not expect an impact on their financial statements.

•IFRS 17 (new standard including amendments) –

Insurance

Contracts

is effective for annual periods beginning on or after

1 January 2023. The new standard provides a comprehensive

principle-based framework for the measurement and

presentation of all insurance contracts. The new standard will

replace IFRS 4 Insurance Contracts and requires insurance

contracts to be measured using current fulfilment cash

flows, and for revenue to be recognised – as the service is

provided over the coverage period.The additionally issued

amendments to IFRS 17 simplify some requirements and

explanation of financial performance, and provide additional

transition reliefs to reduce the complexity of applying

standard for the first time. NLB Group and NLB do not expect

an impact on their financial statements.

•IFRS 16 (amendment) –

Covid-19-Related Rent Concessions

beyond 30 June 2021

is effective for annual periods

beginning on or after 1 April 2021. The amendment extended

the availability of the practical expedient by one year so

that it applies to rent concessions for which any reduction

in lease payments affects only payments originally due on

or before 30 June 2022, provided the other conditions for

applying the practical expedient are met. There is no impact

on NLB Group’s and NLB’s financial statements.

Accounting standards and amendments to existing

standards, but not endorsed by the EU

•IAS 1 (amendment and deferral of effective date) –

Presentation of Financial Statements: Classification

of Liabilities as Current or Non-current

is effective for

annual periods beginning on or after 1 January 2023. The

amendments clarify that liabilities are classified as either

current or non-current, depending on the rights that exist at

the end of the reporting period. Classification is unaffected

by the expectations of the entity or events after the reporting

date. The amendment also clarifies what IAS 1 means when it

refers to the ‘settlement’ of a liability. NLB Group and NLB do

not expect an impact on their financial statements.

•IAS 1 (amendment) –

Presentationof Financial Statements

and IFRS Practice Statement 2 – Disclosure of Accounting

policies

is effective for annual periods beginning on or after

1 January 2023. The amendments to IAS 1 require companies

to disclose their material accounting policy information

ratherthan theirsignificantaccounting policies. The

amendments to IFRS Practice Statement 2 provide guidance

on how to apply the concept of materiality to accounting

policy disclosures. NLB Group and NLB do not expect an

impact on their financial statements.

•IAS 8 (amendment) –

Accounting policies, Changes in

Accounting Estimates and Errors: Definition of Accounting

Estimates

is effective for annual periods beginning on

or after 1 January 2023. The amendments clarify how

companies should distinguish changes in accounting

policies from changes in accounting estimates. That

distinction is important because changes in accounting

estimates are applied prospectively only tofuture

transactions and other future events, but changes

in accounting policies are generally also applied

retrospectively to past transactions and other past events.

NLB Group and NLB do not expect an impact on their

financial statements.

![]()

203

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

•IAS 12 (amendment) -

Income Taxes: Deferred Tax related

to Assets and Liabilities arising from a Single Transaction

is

effective for annual periods beginning on or after 1 January

2023. IAS 12specifies how a company accounts for income

tax, including deferred tax, which represents tax payable

or recoverable in the future. In specified circumstances,

companies are exempt from recognising deferred tax when

they recognise assets or liabilities for the first time. The

amendments clarify that the exemption does not apply and

that companies are required to recognise deferred tax on

such transactions. NLB Group and NLB do not expect an

impact on their financial statements.

•IFRS 17 (amendment) –

Insurance contracts: Initial

Application of IFRS 17 and IFRS 9 – Comparative

Information

is effective for annual periods beginning on or

after 1 January 2023. The amendment is a transition option

relating to comparativeinformationabout financial assets

presented on initial application of IFRS 17. The amendment

is aimed at helping entities to avoid temporary accounting

mismatches between financial assets and insurance

contract liabilities, and therefore improve the usefulness of

comparative information for users of financial statements.

NLB Group and NLB do not expect an impact on their

financial statements.

3.Changes in the composition

oftheNLB Group

Changes in 2021

Capital changes:

•In April 2021, NLB increased the share of voting rights in

the takeover bid for the remaining shares of Komercijalna

banka a.d. Beograd from 83.23% to 87.999% and also

acquired 15.328% of preference shares. This increased

NLB’s share in total shareholding of the bank from 81.42% to

86.42%. The increase in capital investment was recognised

in the amount of EUR 23,098 thousand.

•In May 2021, NLB increased the share of voting rights in the

public offering of ordinary shares of Komercijalna banka

a.d. Beograd from 87.999% to 88.28%. This increased NLB’s

share in total shareholding of the bank from 86.42% to

86.70%. The increase in capital investment was recognised

in the amount of EUR 1,337 thousand.

•In May 2021, NLB acquired the remaining shares of minority

shareholders of NLB Banka a.d., Beograd and increased

its ownership from 99.997% to 100%. The increase in

capital investment was recognised in the amount of EUR 2

thousand.

•An increase in equity reserves in the form of a cash

contribution in the amount of EUR 300 thousand in REAM

d.o.o., Beograd to ensure regular business operations.

•In October 2021, NLB increased its business share in Bankart

d.o.o., Ljubljana from 40.08% to 45.64%.

•In November 2021, Komercijalna banka a.d. Podgorica

merged with NLB Banka a.d. Podgorica. After this merger,

Komercijalna banka a.d. Beograd has 23.97% shareholding

of NLB Banka a.d. Podgorica, while NLB d.d. has 75.90%.

•In December 2021, an increase in share capital in the form of

a cash contribution in the amount of EUR 15,309 thousand in

NLB Lease&Go, leasing, d.o.o., Ljubljana for the purpose of

achieving NLB Group’s leasing strategy.

•In December 2021, NLB increased its ownership in settlement

agreement in relation to the put and call option of shares

of NLB Banka sh.a., Prishtina from 81.21% to 82.38%. The

increase in capital investment was recognised in the amount

of EUR 223 thousand.

Other changes:

•In April 2021 company BH-RE d.o.o., Sarajevo – u likvidaciji

was liquidated. In accordance with a court order, company

was removed from the court register.

•In September 2021, NLB sold its 0.002% ownership interest in

Komercijalna banka a.d. Banja Luka to Komercijalna banka

a.d.Beograd.

•In November 2021, Prvi Faktor d.o.o., Sarajevo - u likvidaciji

was liquidated. In accordance with a court order, the

company was removed from the court register.

•In December 2021, Komercijalna banka a.d. Beograd sold its

subsidiary Komercijalna banka a.d. Banja Luka.

•In December 2021, NLB sold its subsidiary NLB Leasing

d.o.o., Ljubljana – v likvidaciji to NLB Lease&Go, leasing,

d.o.o., Ljubljana.

Changes in 2020

Capital changes:

•In December 2020, NLB acquired an 83.23% ordinary

shareholding in Komercijalna banka a.d. Beograd, which

represents 81.42% of total shareholding in the bank.

•In December 2020, NLB acquired 1 ordinary share of

Komercijalna banka a.d. Banja Luka which represents a

0.002% share of their capital.

•In December 2020, NLB acquired additional shares

of Bankart d.o.o., Ljubljana and thereby increased its

ownership from 39.44% to 40.08%.

•An increase in share capital in the form of a debt-to-equity

conversion in the amount of EUR 1,800 thousand in NLB

Leasing Podgorica d.o.o. – u likvidaciji.

Other changes:

•In April 2020, NLB established the non-financial cultural

heritage institute named ‘NLB Zavod za upravljanje kulturne

dediščine, Ljubljana.’

•In May 2020, NLB established financial company named

‘NLB Lease&Go, leasing, d.o.o., Ljubljana.’

•In May 2020, all the suspensive conditions under the joint

NLB and KBC Insurance NV sale agreement signed in

December 2019 were met, therefore the sale of NLB’s 50%

stake in the share capital of NLB Vita d.d., Ljubljana was

completed (note 4.15.).

•In December 2020, BH-RE d.o.o., Sarajevo – beginning of

the liquidationprocedure entered in thecourt register.

•In December 2020, NLB sold its subsidiaries NLB Leasing

d.o.o., Sarajevo - u likvidaciji and NLB Leasing Podgorica

d.o.o., Podgorica - u likvidaciji.

![]()

204

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

4.Notes to the income statement

4.1.Interest income and expenses

Analysis by type of assets and liabilities

in EUR thousands

NLB GroupNLB

2021202020212020

Interest and similar income

Interest income calculated using the effective interest method

467,500347,636170,002167,611

Loans and advances to customers at amortised cost412,449312,695144,081140,203

Securities measured at amortised cost14,04916,16510,15012,736

Financial assets measured at fair value through other comprehensive income40,34718,18011,73310,704

Loans and advances to banks measured at amortised cost4163833,9373,882

Deposits with banks and central banks23921310186

Other interest and similar income

10,3297,5529,1837,493

Financial assets held for trading4,7575,4084,4555,408

Negative interest (note 5.15.b)3,98033,9815

Non-trading financial assets mandatorily at fair value through profit or loss

780

1,800

744

1,739

Other8123413341

Total477,829355,188179,185175,104

Interest and similar expenses

Interest expenses calculated using the effective interest method

53,17141,20825,14221,883

Due to customers25,57520,5413,0673,835

Borrowings from banks and central banks1,7978801,647

774

Borrowings from other customers1,205

941

--

Subordinated liabilities10,54810,04010,54810,040

Deposits from banks and central banks865

78

627

Lease liabilities (note 5.11.a)470

294

2939

Other interest and similar expenses

15,29814,40714,90414,334

Derivatives - hedge accounting10,2799,43910,2799,439

Negative interest12,7118,4349,8457,168

Financial liabilities held for trading4,2224,7894,2224,789

Interest expenses on defined employee benefits (note 2.30., 5.16.c)2021004830

Other59579355

76

Total68,46955,61540,04636,217

Net interest income409,360299,573139,139138,887

The item ‘Negative interest’ classified under the line item

‘Other interest and similar income’ mainly includes the interest

from targeted longer-term refinancing operations in the

amount of EUR 3,979 thousand for NLB Group and NLB (note

5.15.b).

The item ‘Negative interest’ classified under the line item

‘Other interest and similar expenses’ includes the interest from

deposits with banks and central banks in the amount of EUR

11,692 thousand for NLB Group (2020: EUR 7,178 thousand), and

EUR 8,826 thousand for NLB (2020: EUR 5,912 thousand). It also

includes interest from deposits with financial organisations

in the amount of EUR 336 thousand for NLB Group and NLB

(2020: EUR 411 thousand) and interest from securities with

a negative yield due to the purchase with a premium in the

amount of EUR 683 thousand for NLB Group and NLB (2020:

EUR 845 thousand).

Other interest income in year 2021 for NLB Group in the

amount of EUR 809 thousand relates to interests in relation to

a refund of VAT from the Slovenian Tax Authority, while EUR

341 thousand in year 2020 for NLB Group and NLB relates to

arefund of corporate income tax from the Italian Tax Authority

(note 4.16.).

![]()

205

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

4.2.Dividend income

4.3.Fee and commission income and expenses

a) Fee and commission income and expenses relating to activities of NLB Group and NLB

in EUR thousands

NLB GroupNLB

2021202020212020

Fee and commission income

Fee and commission income relating to financial

instruments not at fair value through profit or loss

Credit cards and ATMs93,64463,94038,38935,634

Customer transaction accounts90,21266,31157,14749,566

Other fee and commission income

Payments77,24850,32522,75121,109

Investment funds27,09519,2868,6945,931

Guarantees13,91811,7817,8317,282

Agency of insurance products8,6426,3387,0105,241

Other services10,4454,6394,4843,434

Total321,204222,620146,306128,197

Fee and commission expenses

Fee and commission expenses relating to financial

instruments not at fair value through profit or loss

Credit cards and ATMs67,86046,47327,95225,581

Other fee and commission expenses

Payments11,5676,134917909

Insurance for holders of personal accounts and gold cards3,6501,0341,015

760

Investment banking3,4682,272664

524

Guarantees1,026

778

957712

Other services4,5352,528808817

Total92,10659,21932,31329,303

Net fee and commission income related to banking activities229,098163,401113,99398,894

in EUR thousands

NLB GroupNLB

2021202020212020

Financial assets measured at fair value through

other comprehensive income

18483--

- related to investments held at the end of reporting period18483--

Investments in subsidiaries--79,1365,561

Investments in associates and joint ventures--441

670

Non-trading financial assets mandatorily at

fair value through profit or loss

39283928

Total22311179,6166,259

![]()

206

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

b)Fee and commission income and expenses relating to fiduciary activities

in EUR thousands

NLB GroupNLB

2021202020212020

Fee and commission income related to fiduciary activities

Receipt, processing, and execution of orders1,9421,5831,6551,435

Management of financial instruments portfolio2,1181,237--

Initial or subsequent underwriting and/or placing of financial

instruments without a firm commitment basis

264327264327

Custody and similar services5,2904,8425,2474,909

Management of clients’ account of non-materialised securities1,5951,7971,5951,797

Safe-keeping of clients’ financial instruments26---

Advice to companies on capital structure, business

strategy, and related matters and advice, and services

relating to mergers and acquisitions of companies

1502615026

Total11,3859,8128,9118,494

Fee and commission expenses related to fiduciary activities

Fee and commission related to Central Securities

Clearing Corporation and similar organisations

3,1882,8763,1912,874

Fee and commission related to stock exchange and similar organisations1195711957

Total3,3072,9333,3102,931

Net fee income related to fiduciary activities8,0786,8795,6015,563

Total fee and commission income332,589232,432155,217136,691

Total fee and commission expenses95,41362,15235,62332,234

Total a) and b)237,176170,280119,594104,457

![]()

207

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

4.4.Gains less losses from financial assets and liabilities not measured at fair value through profit or loss

During 2020, NLB Group and NLB sold securities measured at

amortised cost in the amount of EUR 120,131 thousand due to

increased credit risk caused by COVID-19 (note 2.33.b).

4.5.Gains less losses from financial assets and liabilities held for trading

in EUR thousands

NLB GroupNLB

2021202020212020

Debt instruments measured at fair value through other comprehensive income

- gains

1715,244

24

4,525

- losses

(4)(178)-(178)

Debt instruments measured at amortised cost

- gains

-12,749-12,749

Financial liabilities measured at amortised cost

- losses

-(126)-(126)

Total

167

17,689

24

16,970

Interest income from financial assets held for trading is

included in the income statement line item ‘Interest and similar

income’ and interest expenses from financial liabilities held for

trading in line item ‘Interest and similar expenses’ (note 4.1.).

in EUR thousands

NLB GroupNLB

2021202020212020

Foreign exchange trading

- gains

28,16031,62810,79923,022

- losses

(7,114)(21,139)(5,795)(18,623)

Debt instruments

- gains

776

797460797

- losses

(616)(392)(571)(392)

Derivatives

- currency

(199)(170)(484)

867

- interest rate

749

(909)

749

(909)

- securities

(562)(21)(562)(21)

Total21,1949,7944,5964,741

![]()

208

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

4.6.Gains less losses from non-trading financial assets mandatorily at fair value through profit or loss

Material exposure that was restructured in 2014, and classified

as non-performing, was repaid in April 2021. This resulted in

positive valuation effect in the amount of EUR 14,837 thousand

at NLB Group level and EUR 13,033 thousand at the NLB level.

in EUR thousands

NLB GroupNLB

2021202020212020

Equity securities

- gains

2,2084,0031,1573,043

- losses

(1,049)(2,656)(855)(1,587)

Debt securities

- gains

514--

- losses

(63)(49)--

Loans and advances to customers

- gains

15,7375,28613,1905,359

Total16,8386,59813,4926,815

in EUR thousands

NLB GroupNLB

2021202020212020

Financial assets and liabilities not measured as

at fair value through profit or loss

359836714(1,011)

Financial assets measured at fair value through profit or loss37(131)37(131)

Other(51)34(51)34

Total345739700(1,108)

Interest income from non-trading financial assets mandatorily

at fair value through profit or loss is included in the income

statement line item ‘Interest and similar income’ (note 4.1.).

4.7.Foreign exchange translation gains less losses

![]()

209

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

4.8.Other net operating income

in EUR thousands

NLB GroupNLB

2021202020212020

Other operating income

Income from non-banking services6,5286,3905,8845,595

- cash transportation

3,2412,9943,2502,994

- operating leases of movable property

1,0741,003471470

- IT services

4264381,098891

- other

1,7871,9551,0651,240

Rental income from investment property3,5582,572

567

471

Revaluation of investment property to fair value (note 5.9.)4,4471,006411884

Sale of investment property

778

234-164

Other operating income14,3352,72810,6331,508

Total29,64612,93017,4958,622

Other operating expenses

Expenses related to issued service guarantees4531,3284531,328

Revaluation of investment property to fair value (note 5.9.)858136105

87

Other operating expenses5,1143,9173,1901,413

Total6,4255,3813,7482,828

Other net operating income23,2217,54913,7475,794

Other operating income in year 2021 includes settlement of

legal dispute in the amount of EUR 8,978 thousand in the NLB

Group and EUR 8,559 thousand in NLB.

Other operating expenses mainly include expenses associated

with donations, penalties and damages, and licences.

![]()

210

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

4.9.Administrative expenses

in EUR thousands

NLB GroupNLB

2021202020212020

Employee costs

Gross salaries, compensations, and other short-term benefits205,821145,87894,43390,063

Defined contribution scheme15,06510,2976,8916,689

Social security contributions10,3638,2365,7155,546

Defined benefit expenses (note 5.16.c)73545(59)304

Post-employment benefits

126423(27)239

Other employee benefits

(53)122(32)65

Total231,322164,956106,980102,602

Other general and administrative expenses

Material5,8064,5291,5212,117

Services40,19328,13617,89618,484

Intellectual services

16,50410,1765,4686,194

Costs of supervision

4,6283,9262,4932,257

Costs of other services

19,06114,0349,93510,033

Tax expenses7,5842,6889321,002

Membership fees and similar823852

307

337

Business travel502399129136

Marketing11,4078,1315,6415,086

Buildings and equipment27,08520,99611,67611,952

Electricity

5,9604,0452,3572,277

Rents and leases

1,9281,916283390

Maintainance costs

7,4506,5004,3474,714

Costs of security

6,0153,5991,8211,791

Insurance for tangible assets

851930166

167

Other costs related to buildings and equipment

4,8814,0062,7022,613

Technology30,59921,97915,10714,655

Maintainance of software and hardware

12,94910,1846,0537,164

Licences

9,8957,9616,3325,054

Data assets and subscription costs

2,5181,9981,6551,383

Other technology costs

5,2371,8361,0671,054

Communications11,3778,2594,7705,509

Postal services

4,8594,0272,9353,581

Telecommunication and internet

4,1312,152

669

724

Other communication costs

2,3872,0801,1661,204

Other general and administrative costs2,1531,3011,120733

Total137,52997,27059,09960,011

Total administrative expenses368,851262,226166,079162,613

Number of employees8,1858,7922,5102,591

Costs of other services include costs for cash transport and

insurance, archiving services, personal insurance costs,

legal costs and fees, and session fees to the members of the

Supervisory Board.

![]()

211

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Additionally, to the services included in the table above, the

statutory auditor in 2021 performed also some services related

to the expected issuance of subordinated instrument in the

amount of EUR 325 thousand (2020: EUR 75 thousand).

in EUR thousands

NLB GroupNLB

2021202020212020

External audit services

Audit of annual report

679

542232211

Other audit services1615511955

Other non-audit services34423442

Total

874

639385308

4.10. Cash contributions to resolution funds and deposit guarantee schemes

in EUR thousands

NLB GroupNLB

2021202020212020

Cash contributions to deposit guarantee schemes33,14815,0227,5435,451

Cash contributions to resolution funds1,9921,6521,9921,652

Total35,14016,6749,5357,103

4.11.

Depreciation and amortisation

in EUR thousands

NLB GroupNLB

2021202020212020

Amortisation of intangible assets (note 5.10.)16,21110,1126,0226,908

Depreciation of property and equipment:

- own property and equipment (note 5.8.b)21,60717,06210,61010,092

- right-of-use assets (note 5.11.a)8,7104,541890848

Total46,52831,71517,52217,848

In the presented years, NLB Group and NLB paid the following expenses related to the services of the statutory auditor:

![]()

212

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

4.12.Gains less losses from modification of financial assets

4.13.

Provisions

in EUR thousands

20212020

NLB Group

12-month

expected

credit

losses

Lifetime

ECL not

credit -

impaired

Lifetime

ECL credit-

impaired

Total

12-month

expected

credit

losses

Lifetime

ECL not

credit -

impaired

Lifetime

ECL credit-

impaired

Total

Financial assets modified

during the period

Amortised cost before modification15,5695,2594,43525,263416,34127,7988,756452,895

Net modification gains/(losses)(48)(12)(203)(263)(3,094)(357)(126)(3,577)

in EUR thousands

NLB Group31 Dec 202131 Dec 2020

Financial assets modified since initial recognition

Gross carrying amount of financial assets for which loss allowance

has changed to 12-month measurement during the period

162

1,690

in EUR thousands

NLB GroupNLB

2021202020212020

Guarantees and commitments (note 5.16.b)(8,504)482(8,028)(599)

Restructuring provisions (note 5.16.d)14,7973,500-3,500

Provisions for legal risks (note 5.16.e)7,8734,696724,230

Other provisions (note 5.16.f)-(119)-(85)

Total14,1668,559(7,956)7,046

![]()

213

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

4.14.Impairment charge

In 2021, NLB impaired equity investments in non-core

subsidiaries and an associate in total amount of EUR

458 thousand (2020: EUR 582 thousand). The release of

impairments in amount of EUR 7,901 thousand relates to sale

of non-core subsidiary (note 3.). In 2020, NLB did not release

any impairments of equity investments.

Impairments of investments in subsidiaries and associates are

included in the segment ‘Non-core members.’

In 2020, impairment of financial assets includes EUR 13,447

thousand of 12-month expected credit losses for Stage 1

financial assets, acquired through a business combination

(note 5.12.c). Of that, EUR 10,434 thousand relates to financial

assets measured at amortised cost, EUR 2,932 thousand

to financial assets measured at fair value through other

comprehensive income, and EUR 81 thousand to cash

balances at central banks and other demand deposits at

banks.

in EUR thousands

NLB GroupNLB

2021202020212020

Impairment of financial assets

Cash balances at central banks, and other demand deposits at banks11734489

124

Loans and advances to banks measured at amortised cost (note 5.14.a)57472714

Loans and advances to individuals measured at amortised cost (note 5.14.a)13,41429,0076,83013,219

Loans and advances to other customers measured at amortised cost (note 5.14.a)(44,639)25,972(24,840)(4,611)

Debt securities measured at fair value through other comprehensive income (note 5.14.b)2,8543,888(148)635

Debt securities measured at amortised cost (note 5.14.b)(383)547(17)

224

Other financial assets measured at amortised cost (note 5.14.a)1,2491,994(8)28

Total impairment of financial assets(27,331)61,799(18,067)9,633

Impairment of investments in subsidiaries, associates and joint ventures

Investments in subsidiaries--(7,522)552

Investments in associates and joint ventures--7930

Total--(7,443)582

Impairment of other assets

Property and equipment (note 5.8.)216204--

Intangible assets (note 5.10.)936---

Other assets3,255792(104)103

Total4,407

996

(104)103

Total impairment of non-financial assets4,407

996

(7,547)685

Total impairment(22,924)62,795(25,614)10,318

in EUR thousands

NLB GroupNLB

2021202020212020

Gains less losses on derecognition of subsidiaries, associates and joint ventures-11,006-35,454

Gains less losses from property and equipment

248

(153)(94)(220)

Total

248

10,853(94)35,234

4.15.

Gains less losses from non-current assets held for sale

In May 2020, all the suspensive conditions under the joint NLB

and KBC Insurance NV sale agreement signed in December

2019 were met, therefore, the sale of NLB’s 50% stake in the

share capital of NLB Vita was completed. The effect of sale is

included in the segment ‘Retail Banking in Slovenia.’

![]()

214

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

4.16.Income tax

Income tax differs from the amount of tax determined by applying the Slovenian statutory tax rate as follows:

Each member of NLB Group (disclosed in note 5.12.a) is taxable

as required by local tax legislation. Income tax rates within

NLB Group range from 9–32%.

A tax rate of 19% was applied in Slovenia in 2021 (2020: 19%).

For the year 2021, NLB realised tax loss due to the utilisation of

previously tax non-deductible expenses for impairments in the

subsidiary, which was divested in 2021. The effects of the sale

of the subsidiary are included into the effect of unrecognised

deferred tax assets on impairments of subsidiaries and

associates, and the effects of new tax loss are included into

effect of unrecognised deferred tax assets on tax losses.

Non-taxable income of NLB relates mostly to dividends.

Non-taxable dividend income in 2021 amounts to EUR 75,635

thousand (2020: EUR 5,947 thousand).

in EUR thousands

NLB GroupNLB

2021202020212020

Current income tax16,96111,9723,1594,010

Income tax related to previous period-(3,569)-(3,569)

Deferred income tax (note 5.17.)(3,423)(3,238)(112)(540)

Total13,5385,1653,047(99)

in EUR thousands

NLB GroupNLB

2021202020212020

Profit before tax261,406277,921211,468113,853

Tax calculated at prescribed rate of 19%49,66752,80540,17921,632

Income not assessable for tax purposes(12,685)(26,300)(14,900)(4,359)

Expenses not deductible for tax purposes6,5103,8381,1601,662

Effect of unrecognised deferred tax assets on

impairments of subsidiaries and associates

(32,036)(9,016)(36,446)(8,652)

Tax reliefs(463)(1,902)-(1,649)

Effect of unrecognised deferred tax assets on tax losses10,675(4,351)9,886(4,985)

Effects of different tax rates in other countries(11,345)(6,273)--

Withholding tax suffered in other countries for which

no tax credit was available in Slovenia

3,1561143,156114

Adjustment to tax in respect of prior periods50(3,457)3(3,569)

Other9(293)9(293)

Total13,5385,1653,047(99)

Non-taxable income of NLB Group for 2020 mostly relates

to the gain from a bargain purchase (negative goodwill) of

Komercijalna banka Beograd.

In 2020, NLB received EUR 3,569 thousand corporate income

tax refund and EUR 341 thousand interest from the Italian Tax

Authority. The refund is related to the closing of Trieste Branch

(officially closed in 2017) and is the consequence of tax non-

deductible impairments of financial assets, recognised by the

Trieste Branch in the year 2013. The refund procedure started

in 2016 and was successfully concluded in 2020.

NLB recognised deferred tax assets accrued on the basis of

temporary differences in an amount that, given future profit

estimates, is expected to be reversed in the foreseeable future (i.e.,

within five years). Due to some uncertainties regarding external

factors (regulatory environment, market situation, etc.), a lower

range of expected outcomes was considered for the purposes of

deferred tax assets calculation.The estimated amount of deferred

tax assets, expected to be reversed in foreseeable future, was not

changed in 2021 and stays the same as in 2020.

NLB did not recognise deferred tax assets arising from tax

losses and tax reliefs. NLB recognised deferred tax assets on all

temporary differences, except for impairments of non-strategic

capital investments and valuation of financial instruments where

deferred tax assets are recognised in the amount that, taking into

account other recognised deferred tax assets reaches the total

amount of deferred tax assets, for which a reversal is expected

within five years. The deferred tax assets with respect to which

simultaneously deferred tax liabilities are recognised are excluded

from this calculation (e.g., deferred tax assets for temporary non-

deductible expenses for impairment of debt securities measured

at fair value through other comprehensive income and deferred

tax assets related to fair value hedge accounting).

NLB Group members did not recognise deferred tax assets for tax

losses if there is uncertainty about whether the tax losses can be

utilised, because it is not probable that future taxable profits will be

available against which the deferred tax assets can be utilised.

The tax authorities may audit operations of NLB Group entities.

In general, tax inspection, which may result in the emergence

of additional tax liability, default interest, and penalties, may

be initiated at any time within four to six years from the date of

tax statement or from the year in which tax should have been

assessed. NLB is not aware of any circumstances that could

give rise to a potential material tax liability in this respect.

In 2018, the Financial Administration of the Republic of

Slovenia (FURS) granted NLB special tax status for a period

of three years. This status was extended in March 2021 for

another three years. The purpose of the status is to establish

cooperation between FURS and the taxpayers, with the aim of

encouraging voluntary compliance and reduce administrative

burdens on financial supervision. FURS cooperates with NLB

and responds quickly to resolve NLB’s tax compliance issues,

which reduces NLB’s tax risks and uncertain tax positions.

The effective tax rate of NLB Group relating to operations in

2021, calculated as a ratio of the tax expenses and profit before

tax is 5.2% (2020: 1.9%). NLB Group profit before tax for the

year 2020 includes non-taxable gain from a bargain purchase

(negative goodwill) of EUR 137,858 thousand. Without this one-

off event, the effective tax rate of NLB Group in 2020 would be

3.7%. The effective tax rate for NLB is 1.4% (2020: -0.1%).

![]()

215

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

4.17.Earnings per share

Earnings per share are calculated by dividing the net profit by

the weighted average number of ordinary shares in issue, less

treasury shares.

5.Notes to the statement of financial position

5.1.Cash, cash balances at central banks, and other demand deposits at banks

NLB GroupNLB

2021202020212020

Net profit attributable to the owners of the parent (in EUR thousands)236,404269,707208,421113,952

Weighted average number of ordinary shares (in thousands)20,00020,00020,00020,000

Basic earnings per share (in EUR per share)11.813.510.45.7

Diluted earnings per share (in EUR per share)11.813.510.45.7

Slovenian banks are required to maintain a compulsory

reserve with the Bank of Slovenia relative to the volume and

structure of their customer deposits. Other banks in NLB

in EUR thousands

NLB GroupNLB

31 Dec 202131 Dec 202031 Dec 202131 Dec 2020

Balances and obligatory reserves with central banks4,133,1043,149,7752,982,5761,998,297

Cash509,596507,970178,045192,405

Demand deposits at banks363,246304,94190,16371,089

5,005,9463,962,6863,250,7842,261,791

Allowance for impairment(894)(874)(347)(258)

Total5,005,0523,961,8123,250,4372,261,533

Group maintain a compulsory reserve in accordance with

local legislation. NLB and other banks in NLB Group fulfil their

compulsory reserve deposit requirements.

Diluted earnings per share are the same as basic earnings per

share for NLB Group and NLB, since subordinated loans and

issued debt securities have no future conversion options, and

consequently there are no dilutivepotentialordinary shares.

![]()

216

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

5.2.Financial instruments held for trading

a)Financial assets held for trading

The notional amounts of derivative financial instruments are disclosed in note 5.23.b).

in EUR thousands

NLB GroupNLB

31 Dec 202131 Dec 202031 Dec 202131 Dec 2020

Derivatives. excluding hedging instruments

Swap contracts6,66513,5976,67513,932

- currency swaps

438400448735

- interest rate swaps

6,22713,1976,22713,197

Options54

786

54

786

- interest rate options

53-53-

- securities options

1

786

1

786

Forward contracts9591,6669531,663

- currency forward

9591,6669531,663

Total derivatives7,67816,0497,68216,381

Securities

Bonds-68,806-2,450

- Republic of Serbia-

66,356--

- other non-EU members-

2,450-2,450

Total securities-68,806-2,450

Total7,67884,8557,68218,831

- quoted securities-68,806-2,450

of these debt instruments-

68,806-2,450

in EUR thousands

NLB GroupNLB

31 Dec 202131 Dec 202031 Dec 202131 Dec 2020

Derivatives. excluding hedging instruments

Swap contracts6,60913,9326,62613,947

- currency swaps

716777733792

- interest rate swaps

5,89313,1555,89313,155

Options53-53-

- interest rate options

53-53-

Forward contracts9231,5539231,553

- currency forward

9231,5539231,553

Total7,58515,4857,60215,500

b)Financial liabilities held fortrading

The notional amounts of derivative financial instruments are disclosed in note 5.23.b).

![]()

217

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

in EUR thousands

NLB GroupNLB

31 Dec 202131 Dec 202031 Dec 202131 Dec 2020

Assets

Shares4,4724,1714,4724,171

Investment funds12,42810,989--

Bonds4,2612,157--

Loans and advances to companies-25,0767,88830,935

Total21,16142,39312,36035,106

- quoted securities4,2612,157--

of these debt instruments

4,2612,157--

- unquoted securities16,90015,1604,4724,171

of these equity instruments

16,90015,1604,4724,171

5.3.Non-trading financial instruments measured at fair value through profit or loss

a)Financial assets mandatorily at fair value through profit orloss

b)Financial liabilities measured at fair value through profit or loss

in EUR thousands

NLB GroupNLB

31 Dec 202131 Dec 202031 Dec 202131 Dec 2020

Liabilities

Loans and advances to companies--352-

![]()

218

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

5.4.Financial assets measured at fair value through other comprehensive income

a)Analysis bytype of financial assets measured at fair value through other comprehensive income

in EUR thousands

NLB GroupNLB

31 Dec 202131 Dec 202031 Dec 202131 Dec 2020

Bonds3,251,8263,260,9401,526,2371,598,760

- governments

2,477,2852,527,240766,688879,856

- Republic of Slovenia

314,929417,238270,423334,819

- other EU members

462,459384,474331,676370,484

- Republic of Serbia

1,196,7241,258,7755,021-

- other non-EU members

503,173466,753159,568174,553

- banks

739,935716,459724,943701,663

- other issuers

34,60617,24134,60617,241

Shares22,10922,925219273

National Resolution Fund44,49044,87444,49044,874

Treasury bills105,866135,10214,80572,444

- Republic of Slovenia

6,47557,531-45,007

- other EU members

69,83624,01514,8057,011

- Republic of Serbia

-8,483--

- other non-EU members

29,55545,073-20,426

Commercial bills37,56950,449--

Total3,461,8603,514,2901,585,7511,716,351

of these debt securities

3,395,2613,446,4911,541,0421,671,204

of these equity securities

66,59967,79944,70945,147

Allowance for impairment (note 5.14.b)(12,016)(9,482)(3,001)(3,141)

- quoted securities3,205,2773,307,1031,541,0421,671,204

of these debt instruments

3,204,7453,306,4001,541,0421,671,204

of these equity instruments

532703--

- unquoted securities256,583207,18744,70945,147

of these debt instruments

190,516140,091--

of these equity instruments

66,06767,09644,70945,147

The credit quality analysis for financial assets and contingent

liabilities is disclosed in note 6.1.j) and movements in allowance

for the impairment of debt securities in note 5.14.b).

![]()

219

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

b)Movements of financial assets measured at fair value through other comprehensiveincome

in EUR thousands

NLB GroupNLB

2021202020212020

Debt securitiesEquity securitiesDebt securitiesEquity securitiesDebt securitiesEquity securitiesDebt securitiesEquity securities

Balance as at 1 January3,446,49167,7992,091,80549,6231,671,20445,1471,611,71144,946

Effects of translation of foreign operations to presentation currency1,19431(406)

94

----

Acquisition of subsidiaries (note 5.12.c)--1,267,28117,614----

Additions1,455,823-1,856,445-219,733-1,045,700-

Derecognition(1,468,240)(4,297)(1,790,053)(3,341)(338,929)(55)(999,844)-

Net interest income40,310-17,370-11,696-9,894-

Exchange differences on monetary assets8,367-(10,895)-8,452-(11,007)-

Changes in fair values(52,085)3,06614,9443,809(31,114)(383)14,750201

Disposal of subsidiary (note 5.12.b)(36,599)-------

Balance as at 31 December3,395,26166,5993,446,49167,7991,541,04244,7091,671,20445,147

As at 31 December 2021 and as at 31 December 2020, NLB

Group and NLB do not have any equity instruments measured

at fair value through other comprehensive income obtained

by taking possession of collateral in the statement of financial

position (note 6.1.l).

By selling equity securities measured at fair value through

other comprehensive income in 2021, NLB Group realised a

net gain in the amount of EUR 3,362 thousand, and NLB a net

gain in the amount of EUR 53 thousand (2020: NLB Group and

NLB did not realise any gain or loss by selling equity securities

measured at fair value through other comprehensive income).

Realised gain in year 2021 was transferred to retained

earnings (note 5.4.c).

Equity investment obtained by taking possession of collateral

in amount of EUR 3,289 thousand was during year 2020

converted back to the line item ‘Financial assets measured

at amortised cost’ because the conditions of the bankruptcy

proceedings were not met. At the time of conversion, NLB

Group transferred EUR 1,002 thousand from accumulated

other comprehensive income into retained earnings

(note5.4.c).

![]()

220

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

c)Accumulated other comprehensive income related to financial assets measured at fair value through other comprehensive income

5.5.Derivatives for hedging purposes

NLB Group entities measure exposure to interest rate risk

using repricing gap analysis and by calculating the sensitivity

of the statement of financial position and off-balance-sheet

items in terms of the economic value of equity. The portfolio

duration is used as a measure of risk in the management of

securities in the banking book.

NLB Group entities use various derivatives such as interest

rate swaps (IRS) and currency interest rate swaps (CIRS) to

close open positions in an individual maturity bucket. Micro

and macro fair value hedges are used for that purpose, i.e.,

the swapping of a fixed interest rate on a hedged item for

a variable interest rate. Micro cash flow hedges are also

occasionally used, i.e. the swapping of a variable interest rate

on a hedged item for a fixed interest rate. All cash flow hedges

are made on liability items, while fair value hedges are used

on asset items.

Hedge accounting principles (fair value and cash flow hedging)

were applied in the hedging of interest rate risk using interest

rate swaps. These hedge relationships are designated in such

a way that the characteristics of the hedging instrument and

those of the hedged item match (i.e., the principal terms match),

while the dollar-offset method is used to regularly measure

hedge effectiveness retrospectively. Prospective testing of

hedge effectiveness is carried out regularly for macro hedges

where the characteristics of both items in the hedge relationship

do not fully match by comparing the change in the fair value of

both items to the shift in the yield curve.

in EUR thousands

NLB GroupNLB

2021202020212020

Debt securitiesEquity securitiesDebt securitiesEquity securitiesDebt securitiesEquity securitiesDebt securitiesEquity securities

Balance as at 1 January39,9243,72645,4802,83627,24245224,156288

Effects of translation of foreign operations to presentation currency(7)61632----

Disposal of subisidiaries (note 5.12.b)

- valuation and impairment(1,916)-------

- deferred income tax (note 5.17.)193-------

Net gains/(losses) from changes in fair value(38,158)3,0667,7173,809(17,187)(383)7,522202

Gains/losses transferred to net profit on disposal (note 4.4.)(167)-(5,066)-(24)-(4,347)-

Impairment (note 4.14.)2,854-3,888-(148)-635-

Transfer of gains/losses to retained earnings (5.4.b)-(3,362)-(1,002)-(53)--

Deferred income tax (note 5.17.)4,758(179)(1,085)(401)2,48283(724)(38)

Share of other comprehensive income of associates and joint ventures--(11,026)(1,548)----

Balance as at 31 December7,4813,25739,9243,72612,3659927,242452

Hedge accounting principles were not applied in economic

hedges using CIRS. Thus, the effects of valuation are disclosed

in the income statement in the line item ‘Gains less losses from

financial assets and liabilities held for trading.’

Sources of hedge ineffectiveness may arise, but are not limited

to the discount rates used for valuation of derivatives at fair

value, and notional and timing differences, as well differences

in the amortisation plan between hedged items and the

hedging instrument. Hedge effectiveness is assessed monthly,

by comparing changes in the fair value of the hedged item

that are attributable to a hedged risk with changes in the fair

value of the hedging instrument.

![]()

221

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

a) Fair value adjustment in hedge accounting recognised in profit or loss

In both years presented, all fair value hedges were effective,

with actual results of the hedge ratio within a range of 80–125%,

therefore, no discontinuation of the hedge accounting was required.

As at 31 December 2021 and 2020, NLB Group and NLB had

no relationships designated for cash flow hedge accounting

or for hedge of a net investment in a foreign operation.

in EUR thousands

NLB Group and NLB20212020

Fair value hedge

167

720

Net effects from hedging instruments26,406(12,348)

- interest rate swap for micro hedge19,547(7,537)

- interest rate swap for macro hedge6,859(4,811)

Net effects from hedged items(26,239)13,068

- loans measured at amortised cost - micro hedge(105)(128)

- bonds measured at amortised cost - micro hedge(5,443)1,116

- bonds measured at fair value through OCI - micro hedge(13,929)7,227

- loans measured at amortised cost- macro hedge(6,762)4,853

in EUR thousands

NLB Group and NLBNotional amountFair value

AssetLiability

Fair value hedge

31 Dec 2021572,45556835,377

31 Dec 2020573,753-61,161

in EUR thousands

20212020

NLB Group and NLB

Carrying amount of

hedged items

Accumulated amount

of FV adjustments on

the hedged item

Carrying amount of

hedged items

Accumulated amount

of FV adjustments on

the hedged item

Micro fair value hedges479,57423,783498,39743,571

Fixed rate corporate loans measured at AC1,662602,667165

Fixed rate bonds measured at AC117,3688,426117,83914,182

Fixed rate bonds measured at FVOCI360,54415,297377,89129,224

Macro fair value hedges145,6387,082154,05013,844

Fixed rate retail loans145,6387,082154,05013,844

NLB Group applied a hedge of a net investment in a foreign

operation in years 2011 and 2012, and at that time recognised

a EUR 754 thousand gain on the hedging instrument in other

comprehensive income (note 5.21.b). This gain will be included

in the consolidated income statement when the foreign

operation is disposed of as a part of the gain or loss on the

disposal.

c) Accumulated fair value adjustments arising from the

corresponding continuing hedge relationships

The table below presents accumulated fair value adjustments

arising from the corresponding continuing hedge

relationships, irrespective of whether there has been a change

in the hedge designation during the year. The accumulated

fair value adjustment is presented in the same line of

statement of financial position as a hedged item, except for

macro fair value hedges. In such relationships, hedged items

are presented in the line item ‘Financial assets measured at

amortised cost,’ while the accumulated fair value adjustment

is presented in a separate line item ‘Fair value changes of the

hedged items in portfolio hedge of interest rate risk.’

b)Notional amounts of interest rate swaps

![]()

222

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

d) IBOR reform

NLB Group closely monitors the development of Benchmark

Interest Rate Reform and is actively preparing for the changes

imposed by the regulation. In 2018, NLB formed a special

working group which deals with the preparation for the

discontinuation of some important reference interest rates

and reports on this to NLB Group ALCO.

NLB Group no longer offers new products that would be

tied to reference rates in termination. The exception are

products related to EURIBOR, which is not scheduled for

discontinuation. Therefore,NLB Group’s attentionwas focused

on the modification of new contractual relationships with

customers in which EURIBOR occurs and the amendment of

existing contractual relationships with customers in which

other benchmarks in termination appear.

EURIBOR (likely) discontinuation

Due to timely transition to the new hybrid EURIBOR methodology

which meet the BMR requirements, EURIBOR can continue to be

used in new and legacy contracts for the foreseeable future.

EU supervised entities are bound to include robust fallback

clausesinto contractual documentationwith the clients. In

November 2019, the Euro risk-free rates (RFR) Working Group

published high level recommendations for fallback provisions

for products referencing EURIBOR. The inclusion of robust

fallback language is a requirement in contracts subject to the

EU Benchmark Regulation. The Bank already incorporated

the generic fallback clause into all new EURIBOR (both retail

and corporate) contracts.

In May 2021, the Euro RFR Working Group produced its

recommendations on EURIBOR fallback trigger events

and €STR-based EURIBOR fallback rates. Our mid-term

activities are expected to undertake on the implementation

of more precise fallback provisioning, based on these

recommendations. NLB identified potential €STR-based

fallbacks for EURIBOR, in line with the current market

consensus on those fallbacks and intends to proceed

with the activities for inclusion on EURIBOR fallbacks into

all new EURIBOR-based contracts. In the next step, the

Bank is expected to include fallback provisions also in

legacy contracts. The exact timing depends on regulatory

development and best market practice.

NLB as a supervised entity, is required to comply with the

Benchmark regulation and, as a user of benchmarks, must

produce and maintain a robust written plan setting out

the actions NLB would take in the event that a benchmark

materially changes or ceases to be provided. NLB has

prepared a plan, which sets out an inexhaustive/summary

action list, and will continue to closely follow market standards

to identify alternative benchmarks that could be referenced in

substitute of existing benchmarks.

LIBOR (imminent) discontinuation.

Since many LIBOR settings ceased to exist at the beginning

of 2022, the Bank accelerated the process of winding-down

the exposures in a most efficient way. Incremental LIBOR

transactions were not allowed unconditionally.

NLB Group activities for implementation of LIBOR transition

were as follows:

•

reviewof outstanding LIBOR referencing loans,

•identification of alternative reference rate to be used for

loan portfolio,

•analysis of how the alternative reference rate will be

calculated and how to calculate any economic difference

between LIBORs and the selected alternative reference

rates,

•consideration of IT system accommodation with alternative

reference rates,

•documentation of the transition of the loans.

In February 2021; the European Commission adopted an

amendment to the existing EU BMR and in October 2021;

the European Commission published the Implementing

Regulation on the designation of a statutory replacement for

certain settings of CHF LIBOR and for EONIA.

CHF LIBOR transition to SARON Compound Rate was

successfully implemented in due time.

The table below indicates the nominal amount and weighted

average maturity of derivatives in hedging relationships that

will be affected by the IBOR reform, analysed on an interest

rate basis. The derivative hedging instruments provide a close

approximation to the extent of the risk exposure NLB Group

manages through hedging relationships.

NLB Group and NLB20212020

Nominal amount

(in EUR thousands)

Weighted average

maturity (years)

Nominal amount

(in EUR thousands)

Weighted average

maturity (years)

Interest rate swaps

EURIBOR (3 months)186,4724.23186,4715.18

EURIBOR (6 months)371,8667.00374,2547.83

USD LIBOR (6 months)14,1170.9813,0281.99

As can be seen from the table, the majority of long-term

derivatives in hedging relationships are exposed to

EURIBOR, therefore, the uncertainty arising from interest rate

benchmark reform derives mainly from derivativeswith longer

maturities, when a change of EURIBOR could be expected.

As at 31 December 2021, derivatives with remaining maturity

of five or more years amount to EUR 272,730 thousand

(31December 2020: EUR 310,730 thousand).

![]()

223

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

5.6.Financial assets measured at amortised cost

Analysis by type

The credit quality analysis for financial assets and contingent liabilities is disclosed in note 6.1.j).

a) Debt securities

in EUR thousands

NLB GroupNLB

31 Dec 202131 Dec 202031 Dec 202131 Dec 2020

Debt securities1,717,6261,503,0871,436,4241,277,880

Loans and advances to banks140,683197,005199,287158,320

Loans and advances to customers10,587,1219,619,8605,145,1534,564,178

Other financial assets122,229113,13892,40454,503

Total12,567,65911,433,0906,873,2686,054,881

in EUR thousands

NLB GroupNLB

31 Dec 202131 Dec 202031 Dec 202131 Dec 2020

Governments1,317,2481,173,7181,041,787953,881

Companies79,85286,94672,63279,732

Banks295,653220,988295,653220,988

Financial organisations28,17825,12028,17825,120

1,720,9311,506,7721,438,2501,279,721

Allowance for impairment (note 5.14.b)(3,305)(3,685)(1,826)(1,841)

Total1,717,6261,503,0871,436,4241,277,880

in EUR thousands

NLB GroupNLB

31 Dec 202131 Dec 202031 Dec 202131 Dec 2020

Loans10,2009,809117,49095,070

Time deposits130,602128,07481,90063,405

Reverse sale and repurchase agreements-59,263--

Purchased receivables79-79-

140,881197,146199,469158,475

Allowance for impairment (note 5.14.a)(198)(141)(182)(155)

Total140,683197,005199,287158,320

b) Loans and advances to banks

![]()

224

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

c) Loans and advances to customers

Analysis of loans and advances to customers by sector

in EUR thousands

NLB GroupNLB

31 Dec 202131 Dec 202031 Dec 202131 Dec 2020

Loans10,310,3009,490,7345,006,8714,501,991

Overdrafts352,018322,622174,063152,487

Finance lease receivables (note 5.11.b)108,71549,517--

Credit card business129,330125,72559,30552,156

Called guarantees2,7313,5421,333916

10,903,0949,992,1405,241,5724,707,550

Allowance for impairment (note 5.14.a)(315,973)(372,280)(96,419)(143,372)

Total10,587,1219,619,8605,145,1534,564,178

in EUR thousands

NLB GroupNLB

31 Dec 202131 Dec 202031 Dec 202131 Dec 2020

Governments281,010368,400143,864170,742

Financial organisations141,709158,871226,144177,198

Companies4,645,1124,159,4962,118,2101,838,468

Individuals5,519,2904,933,0932,656,9352,377,770

Total10,587,1219,619,8605,145,1534,564,178

![]()

225

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

d) Other financial assets

Analysis by type of other financial assets

Receivables in the course of settlement are temporary

balances which will be transferred to the appropriate item in

the days following their occurrence.

in EUR thousands

NLB GroupNLB

31 Dec 202131 Dec 202031 Dec 202131 Dec 2020

Receivables in the course of settlement and other temporary accounts40,43632,48423,94515,906

Credit card receivables22,67020,26015,27011,383

Debtors8,2276,3161,3111,307

Fees and commissions7,3036,5633,0412,871

Receivables to brokerage firms and others for the

sale of securities and custody services

613611610610

Accrued income1,7151,3271,6901,296

Dividends--20,493-

Prepayments1,526447--

Other financial assets45,96550,68327,19722,460

128,455118,69193,55755,833

Allowance for impairment (note 5.14.a)(6,226)(5,553)(1,153)(1,330)

Total122,229113,13892,40454,503

Other financial assets include receivables to pension funds

for early retirement payments, receivables from insurance

companies, claims in enforcement procedures, claims from

refunds, claims for subsidies from related transactions, paid

duties, andcourt fees.

Analysis of other financial assets by sector

in EUR thousands

NLB GroupNLB

31 Dec 202131 Dec 202031 Dec 202131 Dec 2020

Banks33,32535,43134,1318,069

Government43,43241,57623,76922,537

Financial organisations15,97914,48812,8187,257

Companies5,9943,912647580

Individuals23,49917,73121,03916,060

Total122,229113,13892,40454,503

![]()

226

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

e)Movement of callednon-financial guarantees

5.7.

Non-current assets held for sale

The line item ‘Non-current assets held for sale’ includes

business premises and assets received as collateral that are

in the process of being sold. As at 31 December 2021, the value

of assets received by taking possession of collateral and

included in non-current assets held for sale by NLB Group

amounted to EUR 699 thousand(31 December 2020: EUR 699

thousand). As at 31 December 2021 and as at 31 December

2020, NLB did not have any non-current assets obtained by

taking possession of collateral and included in non-current

assets held for sale (note 6.1.l).

in EUR thousands

NLB GroupNLB

2021202020212020

Balance as at 1 January1,8381,859440365

Effects of translation of foreign operations to presentation currency(1)(2)--

Called guarantees1,5412,3761,2072,261

Paid guarantees(1,904)(1,932)(470)(1,723)

Write-offs(757)(463)(757)(463)

Balance as at 31 December7171,838420440

Analysis of movements of non-current assets held for sale

in EUR thousands

NLB GroupNLB

2021202020212020

Balance as at 1 January8,65843,1914,4545,532

Effects of translation of foreign operations to presentation currency3(3)--

Acquisition of subsidiaries (note 5.12.c)-1,969--

Additions9789--

Transfer from/(to) property and equipment (note 5.8.)6052,7795182,626

Transfer from/(to) other assets20---

Transfer from/(to) investment property (note 5.9.)(22)(17)--

Disposals(1,952)(39,089)(547)(3,484)

Valuation(358)(261)(336)(220)

Balance as at 31 December7,0518,6584,0894,454

In May 2020, all the suspensive conditions under the joint NLB

and KBC Insurance NV sale agreement signed in December

2019 were met, therefore, the sale of NLB’s 50% stake in the

share capital of NLB Vita was completed. The effect of sale

in year 2020 is included in the segment ‘Retail Banking in

Slovenia.’

5.8.

Property and equipment

a) Analysis by type

in EUR thousands

NLB GroupNLB

31 Dec 202131 Dec 202031 Dec 202131 Dec 2020

Own property and equipment223,593223,59882,90588,495

Right-of-use assets (note 5.11.)23,42125,5193,2173,180

Total247,014249,11786,12291,675

![]()

227

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

in EUR thousands

NLB GroupNLB

Land &

Buildings

ComputersOther equipmentTotal

Land &

Buildings

ComputersOther equipmentTotal

for own use

in operating

lease

for own use

in operating

lease

Cost

Balance as at 1 January 2021345,76981,72998,8384,309530,645197,04349,58049,3553,514299,492

Effects of translation of foreign operations

to presentation currency

62

1730-109-----

Additions3,9877,2964,8711,94818,1023,3211,5131,51096,353

Disposals(1,385)(8,710)(8,393)(648)(19,136)-(7,194)(4,722)(4)(11,920)

Impairment (note 4.14.)(126)---(126)-----

Transfer to/from investment property (note 5.9.)4,377---4,377(2,423)---(2,423)

Transfer to/from non-current assets

held for sale (note 5.7.)

(5,707)---(5,707)(2,089)---(2,089)

Disposal of subsidiary (note 5.12.b)(119)(201)(617)-(937)-----

Balance as at 31 December 2021346,85880,13194,7295,609527,327195,85243,89946,1433,519289,413

Depreciation and impairment

Balance as at 1 January 2021173,40453,82276,8972,924307,047135,34332,90539,9442,805210,997

Effects of translation of foreign operations

to presentation currency

71026-43-----

Disposals(684)(8,634)(7,577)(152)(17,047)-(7,194)(4,248)(3)(11,445)

Depreciation (note 4.11.)7,1248,7335,19655421,6073,8254,3762,08632310,610

Impairment (note 4.14.)90---90-----

Transfer to/from investment property (note 5.9.)(2,676)---(2,676)(2,083)---(2,083)

Transfer to/from non-current assets

held for sale (note 5.7.)

(5,102)---(5,102)(1,571)---(1,571)

Disposal of subsidiary (note 5.12.b)(3)(98)(127)-(228)-----

Balance as at 31 December 2021172,16053,83374,4153,326303,734135,51430,08737,7823,125206,508

Net carrying value

Balance as at 31 December 2021174,69826,29820,3142,283223,59360,33813,8128,361

394

82,905

Balance as at 1 January 2021172,36527,90721,9411,385223,59861,70016,6759,41170988,495

b)Movement of own property and equipment

![]()

228

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

As at 31 December 2021, the value of assets received by

taking possession of collateral and included in property and

equipment by NLB Group amounted to EUR 13,559 thousand

(31 December 2020: EUR 13,268 thousand), and in NLB to EUR 7

thousand (31 December 2020: EUR 7 thousand) (note 6.1.l).

in EUR thousands

NLB GroupNLB

Land &

Buildings

ComputersOther equipmentTotal

Land &

Buildings

ComputersOther equipmentTotal

for own use

in operating

lease

for own use

in operating

lease

Cost

Balance as at 1 January 2020313,16870,74495,6736,186485,771198,31344,63551,6285,441300,017

Effects of translation of foreign operations

to presentation currency

(101)(20)(40)-(161)-----

Acquisition of subsidiaries (note 5.12.c)40,1731,7733,249-45,195

Additions5,88810,2546,9451,25524,3425,2995,3783,35610414,137

Disposals(5,843)(961)(6,955)(3,132)(16,891)(13)(433)(5,629)(2,031)(8,106)

Impairment (note 4.14.)(43)---(43)-----

Transfer to/from investment property (note 5.9.)(756)---(756)-----

Transfer to/from non-current assets held for sale (note 5.7.)(6,717)---(6,717)(6,556)---(6,556)

Disposal of subsidiary (note 3.)-(61)(34)-(95)-----

Balance as at 31 December 2020345,76981,72998,8384,309530,645197,04349,58049,3553,514299,492

Depreciation and impairment

Balance as at 1 January 2020173,76348,80879,5154,625306,711135,32829,44043,7624,367212,897

Effects of translation of foreign operations

to presentation currency

(25)(17)(40)-(82)-----

Disposals(2,427)(948)(6,651)(2,349)(12,375)-(431)(5,600)(2,031)(8,062)

Depreciation (note 4.11.)6,2716,0404,10364817,0623,9453,8961,782

469

10,092

Impairment (note 4.14.)161---161-----

Transfer to/from investment property (note 5.9.)(401)---(401)-----

Transfer to/from non-current assets held for sale (note 5.7.)(3,938)---(3,938)(3,930)---(3,930)

Disposal of subsidiary (note 3.)-(61)(30)-(91)-----

Balance as at 31 December 2020173,40453,82276,8972,924307,047135,34332,90539,9442,805210,997

Net carrying value

Balance as at 31 December 2020172,36527,90721,9411,385223,59861,70016,6759,41170988,495

Balance as at 1 January 2020139,40521,93616,1581,561179,06062,98515,1957,8661,07487,120

![]()

229

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

5.9.

Investment property

in EUR thousands

NLB GroupNLB

2021202020212020

Balance as at 1 January54,84252,3168,3009,303

Effects of translation of foreign operations to presentation currency19(24)--

Acquisition of subsidiaries (note 5.12.c)-19,643--

Additions-717--

Disposals(4,075)(2,493)-(2,031)

Transfer from/(to) property and equipment (note 5.8.)(7,053)355340-

Transfer from/(to) non-current assets held for sale (note 5.7.)2217--

Transfer from/(to) other assets1,397(16,559)137231

Net valuation to fair value (note 4.8.)3,589

870

306797

Disposals of subisidiaries (note 5.12.b)(1,215)---

Other98-98-

Balance as at 31 December47,62454,8429,1818,300

in EUR thousands

NLB GroupNLB

2021202020212020

Leased to others1,1031,157291383

Not leased to others231

242

183

194

Total1,3341,399

474

577

As at 31 December 2021, the value of assets received by

taking possession of collateral and included in investment

property by NLB Group amounted to EUR 36,009 thousand (31

December 2020: EUR 36,130 thousand), and in NLB amounted

to EUR 4,176 thousand (31 December 2020: EUR 4,079

thousand) (note 6.1.l).

Operatingexpensesarising from investment properties:

![]()

230

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

5.10. Intangible assets

in EUR thousands

NLB GroupNLB

Software

licenses

Other

intangible

assets

GoodwillTotal

Software

licenses

Cost

Balance as at 1 January 2021246,68713,20032,336292,223201,614

Effects of translation of foreign operations to presentation currency1311-

24

-

Additions14,866--14,8667,370

Write-offs(15,527)--(15,527)(7,956)

Disposal of subsidiary (note 5.12.b)(432)--(432)-

Balance as at 31 December 2021245,60713,21132,336291,154201,028

Amortisation and impairment

Balance as at 1 January 2021201,748-28,807230,555173,509

Effects of translation of foreign operations to presentation currency87-15-

Amortisation (note 4.11.)11,9444,267-16,2116,022

Impairments (note 4.14.)936--936-

Write-offs(15,435)--(15,435)(7,956)

Disposal of subsidiary (note 5.12.b)(204)--(204)-

Balance as at 31 December 2021198,9974,27428,807232,078171,575

Net carrying value

Balance as at 31 December 202146,6108,9373,52959,07629,453

Balance as at 1 January 202144,93913,2003,52961,66828,105

![]()

231

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Other intangibleassets represent additionallyidentified

intangible assets in a business combination, namely core

deposits and trade name (note 5.12.c).

in EUR thousands

NLB GroupNLB

Software

licenses

Other

intangible

assets

GoodwillTotal

Software

licenses

Cost

Balance as at 1 January 2020228,692-32,336261,028192,581

Effects of translation of foreign operations to presentation currency(34)--(34)-

Acquisition of subsidiaries (note 5,12.c)4,92113,200-18,121-

Additions14,150--14,1509,033

Write-offs(844)--(844)-

Disposal of subsidiary (note 3.)(198)--(198)-

Balance as at 31 December 2020246,68713,20032,336292,223201,614

Amortisation and impairment

Balance as at 1 January 2020192,679-28,807221,486166,601

Effects of translation of foreign operations to presentation currency(22)--(22)-

Amortisation (note 4,11.)10,112--10,1126,908

Write-offs(826)--(826)-

Disposal of subsidiary (note 3.)(195)--(195)-

Balance as at 31 December 2020201,748-28,807230,555173,509

Net carrying value

Balance as at 31 December 202044,93913,2003,52961,66828,105

Balance as at 1 January 202036,013-3,52939,54225,980

![]()

232

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

5.11.

Leases

a) NLB Group as a lessee

In the statement of financial position, right-of-use assets are

included in the line item ‘Property and equipment’ and lease

liabilities are included in the line item ‘Other financial liabilities.’

Additions to the right-of-use assets during 2021 in NLB Group

amounted to EUR 10,172 thousand (2020: EUR 4,736 thousand)

and in NLB EUR 1,245 thousand (2020: EUR 1,808 thousand).

Due to the acquisition of subsidiaries in 2020, the right-of-use

assets in NLB Group increased by EUR 9,576 thousand.

The income statement shows the following amounts relating

to leases:

in EUR thousands

NLB GroupNLB

31 Dec 202131 Dec 202031 Dec 202131 Dec 2020

Right-of-use assets

Land and buildings19,54522,7582,2442,240

Vehicles390959

960

912

Furniture and equipment3,4861,8021328

Total23,42125,5193,2173,180

Lease liabilities24,32426,3593,2563,212

in EUR thousands

NLB GroupNLB

2021202020212020

Depreciation of right-of-use assets (note 4.11.)

Land and buildings7,1593,299465441

Vehicles444571410391

Furniture and equipment1,107

671

1516

Total8,7104,541890848

in EUR thousands

NLB GroupNLB

2021202020212020

Interest expenses on lease liabilities (note 4.1.)(470)(294)(29)(39)

Expenses relating to short-term leases (included in administrative expenses)(606)(719)(179)(266)

Expenses relating to leases of low-value assets that are not shown

above as short-term leases (included in administrative expenses)

(1,050)(771)(157)(151)

Income from sub-leasing right-of-use assets

(included in other operating income)

10892--

The total cash outflow for leases in 2021 in NLB Group was EUR

9,397 thousand (2020: EUR 4,865 thousand) and in NLB EUR

933 thousand (2020: EUR 897 thousand).

![]()

233

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

NLB Group leases various offices, branches, vehicles, and

other equipment used in its business. Rental contracts for

offices and branches generally have lease terms between

5 to 20 years, while some contracts are made for indefinite

periods. Contracts for indefinite periods are included in

measurement of the liability in accordance with planning

projections. Normally, a lease term of 5 years is assumed, with

the exemption of business premises on strategic locations

where management assesses a different (longer) lease term.

Vehicles and other equipment generally have lease terms

between 1 to 5 years. There are several lease contracts that

include extension and termination options. These options are

negotiated by management to align with the Group’s business

needs. Lease payments to be made under reasonably certain

extension options are included in measurement of the liability.

Lease terms are negotiated on an individual basis and

contain a range of different terms and conditions. The

lease agreements do not impose any covenants other than

the security interests in the leased assets that are held by

the lessor. Leased assets may not be used as security for

borrowing purposes.

NLB Group also has certain leases of other equipment with

lease term of 12 months or less, and equipment with low value.

For these leases, NLB Group applies the short-term lease

and lease of low-value assets recognition exemptions. Lease

payments on short-term leases and leases of low-value assets

are recognised as an expenses on a straight-line basis over

the lease term.

For calculation of the net present value of the future lease

payments, NLB Group applies the internal transfer price for

retail deposits as a discount rate.

NLB Group and NLB do not have expenses relating to variable

payments and gains or losses arising from sale and leaseback

transactions.

A maturity analysis of lease liabilities is disclosed in note 6.3.f).

b) NLB Group as a lessor

Finance and operating leases of motor vehicles and operating

leases of business premises and POS terminals represent the

majority of agreements in which NLB Group acts as a lessor.

Most of the lease agreements entered into by NLB Group

as lessor contracts are finance lease agreements. Most

of the finance lease agreements are concluded for a non-

cancellable period of between 48 and 60 months. By paying

the last instalment at the end of the contract, the leasing

object becomes the lessee’s property. The financial leasing

receivables are secured by the object of financing. NLB Group

does not have finance lease contracts with variable payments

not included in the measurement of the net investment in the

lease.

The investment properties are leased to lessee under

operating leases with rentals payable monthly. There are no

variable lease payments that depend on an index or rate. The

investment properties generally have lease terms between 2

to 10 years. Some contracts are made for indefinite period.

As at 31 December 2021, the allowance for unrecoverable

finance lease receivables included in the allowance for

loan impairment amounted to EUR 436 thousand (as at 31

December 2020 EUR 884 thousand).

Finance leases

Loans and advances to customers in NLB Group include

finance lease receivables.

The following table sets out a maturity analysis of lease

receivables, showing the undiscounted lease payments to be

received after the reporting date.

in EUR thousands

NLB Group20212020

Less than one year36,46523,287

One to two years25,72311,506

Two to three years21,2767,734

Three to four years16,4355,159

Four to five years10,3753,243

More than five years8,6042,719

Total undiscounted lease receivable118,87853,648

Unearned finance income(10,163)(4,131)

Net investment in the lease108,71549,517

During 2021, NLB Group recognised interest income on lease

receivables in the amount of EUR 3,452 thousand (2020: EUR

1,957 thousand).

![]()

234

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Operating lease

A maturity analysis of lease payments, showing the undiscounted lease payments to be received after the reporting date:

NLB Group realised rental income arising from: investment

properties in the amount of EUR 3,558 thousand (2020: EUR

2,572 thousand); and movable property in the amount of EUR

1,074 thousand (2020: EUR 1,003 thousand).

in EUR thousands

NLB GroupNLB

2021202020212020

Less than one year2,7573,082375399

One to two years1,3961,863348364

Two to three years8171,497346341

Three to four years5971,411342333

Four to five years4301,308301331

More than five years1,2111,7591,029

243

Total7,20810,9202,7412,011

in EUR thousands

NLB31 Dec 202131 Dec 2020

Banks696,538671,880

Other financial organisations29,72021,819

Enterprises55,28255,361

Total781,540749,060

5.12.

Investmentsin subsidiaries, associates and joint ventures

a) Analysis by type of investment in subsidiaries

NLB realised rental income arising from: investment

properties in the amount of EUR 567 thousand (2020:

EUR471thousand); and movable property in the amount of

EUR 471thousand (2020: EUR 470 thousand) (note 4.8.).

![]()

235

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Data of subsidiaries as included in the consolidated financial statements of NLB Group as at 31 December 2021:

in EUR thousands

Nature of

Business

Country of

Incorporation

Equity as at

31 Dec 2021

Profit/(loss)

for 2021

NLB’s

shareholding %

NLB’s voting

rights %

NLB Group’s

shareholding %

NLB Group’s

voting rights %

Core members

NLB Banka a.d., Skopje

BankingNorth Macedonia243,26739,00086.9786.9786.9786.97

NLB Banka a.d., Podgorica

BankingMontenegro92,64310,05075.9075.9099.8799.87

NLB Banka a.d., Banja Luka

Banking

Bosnia and

Herzegovina

97,14918,18099.8599.8599.8599.85

NLB Banka sh.a., Prishtina

BankingKosovo98,85624,43682.3882.3882.3882.38

NLB Banka d.d., Sarajevo

Banking

Bosnia and

Herzegovina

87,83810,01297.3497.3597.3497.35

NLB Banka a.d., Beograd

BankingSerbia77,9184,293100100100100

Komercijalna banka a.d., Beograd

BankingSerbia634,64334,81886.7088.2886.7088.28

KomBank Invest a.d., BeogradFinanceSerbia1,3454--100100

NLB Skladi d.o.o., Ljubljana

FinanceSlovenia14,9668,969100100100100

NLB Lease&Go, leasing, d.o.o., Ljubljana

FinanceSlovenia16,342(921)100100100100

NLB Zavod za upravljanje kulturne dediščine, Ljubljana

Cultural heritage

management

Slovenia814436100100100100

Non-core members

NLB Leasing d.o.o., Beograd - u likvidaciji

FinanceSerbia5,98540100100100100

NLB Leasing d.o.o., Ljubljana - v likvidaciji\*

FinanceSlovenia18,0582,545--100100

Optima Leasing d.o.o., Zagreb - "u likvidaciji"FinanceCroatia1,258(94)--100100

Tara Hotel d.o.o., Budva

Real estateMontenegro16,802(223)12.7112.71100100

PRO-REM d.o.o., Ljubljana - v likvidaciji

Real estateSlovenia19,966154100100100100

OL Nekretnine d.o.o., Zagreb - u likvidacijiReal estateCroatia1,319(93)--100100

REAM d.o.o., Podgorica

Real estateMontenegro1,69644100100100100

REAM d.o.o., Beograd

Real estateSerbia1,844(217)100100100100

SPV 2 d.o.o., Beograd

Real estateSerbia8319100100100100

S-REAM d.o.o., Ljubljana

Real estateSlovenia2,197850100100100100

REAM d.o.o., ZagrebReal estateCroatia1,0255--100100

NLB Srbija d.o.o., Beograd

Real estateSerbia32,259188100100100100

NLB Crna Gora d.o.o., Podgorica

FinanceMontenegro3,1302,375100100100100

NLB InterFinanz AG, Zürich in Liquidation

FinanceSwitzerland12,3951,725100100100100

NLB InterFinanz d.o.o., BeogradFinanceSerbia3---100100

LHB AG, Frankfurt

FinanceGermany2,221489100100100100

\*100% ownership of NLB Lease&Go, leasing, d.o.o., Ljubljana.

![]()

236

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Data of subsidiaries as included in the consolidated financial statements of NLB Group as at 31 December 2020:

in EUR thousands

Nature of

Business

Country of

Incorporation

Equity as at

31 Dec 2020

Profit/(loss)

for 2020

NLB’s

shareholding %

NLB’s voting

rights %

NLB Group’s

shareholding %

NLB Group’s

voting rights %

Core members

NLB Banka a.d., Skopje

BankingNorth Macedonia229,77719,22286.9786.9786.9786.97

NLB Banka a.d., Podgorica

BankingMontenegro68,5561,38799.8399.8399.8399.83

NLB Banka a.d., Banja Luka

Banking

Bosnia and

Herzegovina

99,87210,12299.8599.8599.8599.85

NLB Banka sh.a., Prishtina

BankingKosovo98,33513,33481.2181.2181.2181.21

NLB Banka d.d., Sarajevo

Banking

Bosnia and

Herzegovina

89,8085,89597.3497.3597.3497.35

NLB Banka a.d., Belgrade

BankingSerbia74,2052,59899.99799.99799.99799.997

Komercijalna banka a.d., Belgrade

BankingSerbia609,943(9,050)81.4283.2381.4283.23

Komercijalna banka a.d., Banja LukaBanking

Bosnia and

Herzegovina

31,045(1,309)0.0020.002100100

Komercijalna banka a.d., PodgoricaBankingMontenegro20,689(1,224)--100100

KomBank Invest a.d., BelgradeFinanceSerbia1,342---100100

NLB Skladi d.o.o., Ljubljana

FinanceSlovenia10,4875,490100100100100

NLB Lease&Go, leasing, d.o.o., Ljubljana

FinanceSlovenia1,938(1,062)100100100100

NLB Zavod za upravljanje kulturne dediščine, Ljubljana

Cultural heritage

management

Slovenia

378

368100100100100

Non-core members

NLB Leasing d.o.o., Ljubljana - v likvidaciji

FinanceSlovenia17,568720100100100100

Optima Leasing d.o.o., Zagreb - "u likvidaciji"FinanceCroatia1,346(996)--100100

NLB Leasing d.o.o., Belgrade - u likvidaciji

FinanceSerbia5,94019100100100100

Tara Hotel d.o.o., Budva

Real estateMontenegro17,025(204)12.7112.71100100

PRO-REM d.o.o., Ljubljana - v likvidaciji

Real estateSlovenia20,870353100100100100

OL Nekretnine d.o.o., Zagreb - u likvidacijiReal estateCroatia1,409(127)--100100

BH-RE d.o.o., Sarajevo - u likvidacijiReal estate

Bosnia and

Herzegovina

7(14)--100100

REAM d.o.o., Podgorica

Real estateMontenegro1,652(166)100100100100

REAM d.o.o., Belgrade

Real estateSerbia1,762(145)100100100100

SPV 2 d.o.o., Belgrade

Real estateSerbia8208100100100100

S-REAM d.o.o., Ljubljana

Real estateSlovenia1,349(236)100100100100

REAM d.o.o., ZagrebReal estateCroatia2,10892--100100

NLB Srbija d.o.o., Belgrade

Real estateSerbia32,0461,149100100100100

NLB Crna Gora d.o.o., Podgorica

Real estateMontenegro755139100100100100

NLB InterFinanz AG, Zürich in Liquidation

FinanceSwitzerland10,783986100100100100

NLB InterFinanz d.o.o., BelgradeFinanceSerbia3(3)--100100

LHB AG, Frankfurt

FinanceGermany1,732(432)100100100100

Changes in ownership interest in subsidiaries of NLB Group in 2021 and 2020 are presented in note 3.

![]()

237

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Data of subsidiaries with significant non-controlling interests, before intercompany eliminations

in EUR thousands

Komercijalna banka,

Beograd

NLB Banka,

Skopje

NLB Banka,

Prishtina

20212020\*2021202020212020

Non-controlling interest in equity in %13.3018.5813.0313.0317.6218.79

Non-controlling interest's voting rights in %11.7216.7713.0313.0317.6218.79

Income statement and statement

of comprehensive income

Revenues156,710-87,86481,67351,50947,699

Profit/(loss) for the year34,818(9,050)39,00019,22224,43613,334

Attributable to non-controlling interest4,631(1,681)5,0822,5054,3062,505

Other comprehensive income(10,117)2,145(759)898(311)

74

Total comprehensive income24,701(6,905)38,24120,12024,12513,408

Attributable to non-controlling interest3,285(1,283)4,9832,6224,2522,519

Paid dividends to non-controlling interest--3,222-4,160-

Statement of financial position

Current assets1,859,6051,455,793719,846690,387446,182443,289

Non-current assets2,305,6442,441,2941,050,742895,265484,363435,775

Current liabilities3,266,2532,978,9591,335,4441,176,539756,702689,776

Non-current liabilities264,353308,185191,877179,33674,98790,953

Equity634,643609,943243,267229,77798,85698,335

Attributable to non-controlling interest84,408113,32731,69829,94017,42118,477

\*Since the acquisition of Komercijalna banka, Beograd was concluded on 30 December 2020, only 12-month expected credit losses and attributable deferred taxes are

included in NLB Group’s income statement for 2020.

![]()

238

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

b)Disposal of Komercijalna banka a.d. Banja Luka

In December 2021, Komercijalna banka a.d. Beograd sold

its subsidiary Komercijalna banka a.d. Banja Luka. The

in EUR thousands

Cash, cash balances at central banks, and other demand deposits at banks75,699

Financial assets measured at fair value through other comprehensive income36,599

Financial assets measured at amortised cost

- loans and advances to customers131,928

- other financial assets381

Tangible assets

Property and equipment2,438

- own property and equipment (note 5.8.b)709

- right-of-use assets1,729

Investment property (note 5.9.)1,215

Intangible assets (note 5.10.)228

Current income tax assets29

Other assets1,026

Total assets249,543

Financial liabilities measured at amortised cost

- deposits from banks and central banks15,514

- due to customers172,900

- borrowings from other customers25,120

- other financial liabilities2,289

Provisions361

Deferred income tax liabilities61

Other liabilities277

Total liabilities216,522

Net assets of subsidiary33,021

Total disposal consideration22,000

Cash and cash equivalents in subisidiary sold(69,832)

Cash outflow on disposal(47,832)

Consideration for disposal of the subsidiary22,000

Carrying amount of net assets disposed of33,021

Transfer of FV OCI revaluation reserve to P&L1,723

Loss from disposal of subsidiary in consolidated financial statements(9,298)

- Non-controlling interest(1,237)

- Attributable to owners of the parent(8,061)

assets and liabilities derecognised from NLB Group financial

statements as a result of the disposal are as follows:

Effect of sale of Komercijalna banka a.d. Banja Luka is included in the segment ‘Strategic Foreign Markets.’

![]()

239

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

c)Acquisition of Komercijalna bankaa.d. Beograd

On 30 December 2020, NLB acquired an 83.23% ordinary

shareholding in Komercijalna banka a.d. Beograd, which

represents 81.42% of total shareholding in Komercijalna banka

a.d. Beograd. At the date of acquisition, the acquired bank had

the following subsidiaries:

Serbia has long been a strategically important market for NLB

Group in the context of the strategy to be the leading international

bank headquartered in and focused on the SEE region. Whilst in

all countries of Group’s operations NLB has a top three market

position, in Serbia (the largest market by population) it was, until

the execution of this transaction, sub-scale.

As a result of the transaction, NLB became the third largest

banking group in Serbia with the acquisition of Komercijalna

banka increasing NLB’s market share from approximately

2% by total assets to over 12% as at 30 September 2020. The

business operations of NLB Group in Serbia will be (besides

the Slovenian market) the largest and most important one,

Subsidiaries

Komercijalna banka

Beograd’s ownership

NLB’s direct

ownership

Komercijalna banka a.d. Podgorica, Montenegro100%-

Komercijalna banka a.d. Banja Luka, Bosnia and Herzegovina99.998%0.002%

Investment Management Company KomBank Invest a.d. Beograd, Serbia100%-

adding more than 800,000 active retail customers and the

largest distribution network in the country of 203 branches to

NLB’s existing operations.

Purchase consideration amounted to EUR 394,718 thousand

and was fully paid in cash. There are no contingent

consideration arrangements. At acquisition date, cash

in acquired entities amounted to EUR 847,488 thousand,

therefore the net inflow of cash amounted to EUR 452,770

thousand (included in statement of cash flows within

payments from investing activities).

![]()

240

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

NLB Group recognises non-controlling interests in Komercijalna

banka Beograd at the non-controlling interest’s proportionate

share of the acquired entity’s net identifiable assets.

Acquisition of Komercijalna banka Beograd resulted in a gain

from a bargain purchase (negative goodwill) in the amount

in EUR thousands

Cash, cash balances at central banks and other demand deposits at banks836,408

Financial assets held for trading66,356

Non-trading financial assets mandatorily at fair value through profit or loss5,628

Financial assets measured at fair value through other comprehensive income (note 5.4.b)1,284,895

Financial assets measured at amortised cost

- debt securities7,214

- loans and advances to banks46,981

- loans and advances to customers1,877,349

- other financial assets23,250

Tangible assets

Property and equipment (notes 5.8.b and 5.11.a)54,771

Investment property (note 5.9.)19,643

Intangible assets (note 5.10.)18,121

Current income tax assets153

Deferred income tax assets1,125

Other assets17,604

Non-current assets held for sale (note 5.7.b)1,969

Total assets4,261,467

Financial liabilities measured at amortised cost

- deposits from banks and central banks35,895

- borrowings from banks and central banks8,788

- due to customers3,443,478

- borrowings from other customers29,295

- other financial liabilities49,072

Provisions (note 5.16.)34,537

Current income tax liabilities4

Deferred income tax liabilities2,112

Other liabilities4,176

Total liabilities3,607,357

Net identifiable assets acquired (100%)654,110

Less: non-controlling interests(121,534)

Net assets acquired (NLB Group share)532,576

Consideration given394,718

Bargain purchase (negative goodwill)137,858

The assets and liabilities recognised as a result of the acquisition are as follows:

of EUR 137,858 thousand, which is recognised in income

statement under line item ‘Negative goodwill.’ The main

reasons for negative goodwill are current market conditions,

when banks are generally valued below their net book values.

![]()

241

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

As a result of the acquisition, NLB Group’s off-balance sheet

liabilities increased by EUR 377,361 thousand:

in EUR thousands

Short-term guarantees19,431

- financial15,437

- non-financial3,994

Long-term guarantees88,123

- financial34,467

- non-financial53,656

Commitments to extend credit266,832

Letters of credit1,440

Other1,535

Total377,361

In 2020, acquisition-related costs amounted to EUR 1,643

thousand and are includedwithin administrative expenses.

NLB obtained all the necessary information for measuring

fair values, therefore no amounts in 2020 financial statements

were measured and recognised on a provisional basis.

Assets acquiredValuation technique

Performing loans

Discounted cash flow approach:

Since these are performing loans, it was assumed that they would be repaid by future

cash flows in accordance with amortisation schedules. Credit risk was considered for loans which are classified in

Stage 2 in Komercijalna banka’s local financial statements, by reducing future cash flows accordingly. Also prepayment

risk was estimated for two retail products namely cash loans and housing loans which have the longest maturity.

As a discount rate, average weighted interest rate for new transactions in the market for the same products, currency and

clients (sector) were used. The source was Serbian central bank (NBS) statistical database, which provided a history of

interest rates data by various products, currencies, maturities, type of interest rates, and size of customer for new loans.

Non-performing loans

Discounted cash flow approach:

Since these are non-performing loans, it could generally not be assumed

that they would be repaid with cash flows from client’s regular business. Instead, gone concern principle was

used, taking into account liquidation value of collateral as expected cash flows. Appropriate haircuts for age

of valuations, type of collateral, type of location, and type of real estate were used to estimate the liquidation

value of collateral, which was then discounted for a period of 4 years, with the required yield of 20%.

Only exceptionally, also cash flows from regular business were considered, also discounted with the required yield of 20%.

Debt securities

For debt securities classified in Level 1 of fair value hierarchy, fair values were determined by an observable market

price in an active market for an identical asset. For valuing debt securities in Level 2, income approach was used,

based on the estimation of future cash flows discounted to the present value. The input parameters used in the

income approach were the risk-free yield curve and the spread over the yield curve (credit, liquidity, country).

Real estate

Three approaches were used for estimating the value of real estate - the income capitalisation approach, the sale comparison

approach and the residual land value approach. Each views the valuation from different perspectives and considers data

from different market sources. The most suitable approach depends on the characteristics and use of individual real estate.

The income capitalization approach:

Values property by the amount of income - cash flow that it can potentially generate.

The value of the property is derived by converting the expected income generated from a property into a present value

estimate using market capitalization rate. This method is commonly used for valuing income-generating properties.

The sale comparison approach:

Values property by comparing similar properties that have been sold recently. This approach

is sometimes referred to as the ‘direct sales comparison approach.’ The reliability of an indication found by this method

depends on the quality of comparable data found in the marketplace and application of adequate adjustments for individually

appraised real estate.When sale transactions are not available, the direct sales comparison approach is not applicable.

Residual land value approach:

is a method for calculating the value of development land. It is performed by

subtracting from the total value of a development project, all costs associated with the development project,

including profit but excluding the cost of the land. It is applicable only for development/construction land.

Core deposits

Acquired core deposit accounts typically provide a low-cost source of funds to the buyer. To replace these

established, low-cost deposit accounts in a timely manner, the buyer’s alternative would be to utilise higher-

cost funds at current market rates. Core deposits value is measured by the present value of the difference, or

spread, between the core deposit’s ongoing cost and the cost of a market alternative replacement.

Trade name

The trade name was valued by applying the relief-from-royalty method under the income approach. This method is based

upon the application of an appropriate royalty rate on the respective revenues to estimate the Fair Value for the trade

name. This method assumes that, by virtue of having ownership of the trade name rather than licensing one for use

Liabilities acquiredValuation technique

Deposits

Discounted cash flow approach:

Aggregated future cash flows were discounted by applying market interest rates

for term deposits. Future cash flows were grouped into 11 groups according to the type of client and currency. As

a discount rate, average weighted interest rate for new transactions in the market in 2020 was applied.

The valuation techniques used for measuring the fair value of

material assets and liabilities acquired were as follows:

![]()

242

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

The fair value of acquired loans and advances to customers

is EUR 1,877,349 thousand, of which EUR 1,836,970 thousand

relates to performing portfolio and EUR 40,379 thousand

to non-performing portfolio. The latter was recognised as

purchased or originated credit-impaired financial assets

(POCI). The gross contractual amount for performing loans

and advances to customers is EUR 1,827,721 thousand and for

this exposure 12-month expected credit losses in the amount

of EUR 10,349 thousand were recognised through the income

statement. The gross contractual amount for non-performing

loans and advances to customers is EUR 149,654 thousand,

and it is expected that approximately EUR 75 million of the

contractual cash flows will not be collected.

Since the transaction was closed on 30 December 2020, only

12-month expected credit losses for Stage 1 financial assets in

the amount of EUR 13,447 thousand and attributable deferred

taxes in the amount of EUR 1,864 thousand are included in NLB

Group income statement. If the acquisition has occurred on 1

January 2020, management estimates that consolidated revenue

(excluding negative goodwill) would have been between EUR

750 and 760 million and consolidated profit for the year would

have been between EUR 260 and 265 million. The exact result is

difficult to assess due to some changed circumstances during the

year, especially the COVID-19 pandemic.

By contractual agreement between the shareholders, NLB

does not control ARG-Nepremičnine, Horjul, but does have a

significant influence. Therefore, the entity is accounted as an

associate.

20212020

Nature of

Business

Country of

Incorporation

Shareholding %Voting rights %Shareholding %Voting rights %

Bankart d.o.o., LjubljanaCard processingSlovenia45.6445.6440.0840.08

ARG - Nepremičnine d.o.o., HorjulReal estateSlovenia75.0075.0075.0075.00

in EUR thousands

20212020

Carrying amount of the NLB Group's interest11,5257,988

NLB Group's share of:

- Profit for the year1,108

874

- Other comprehensive income(30)(41)

- Total comprehensive income1,078833

in EUR thousands

NLB GroupNLB

Carrying amount of the NLB Group's interest31 Dec 202131 Dec 202031 Dec 202131 Dec 2020

Other financial organisations11,5257,9884,2821,382

Enterprises--201280

Total11,5257,9884,4831,662

NLB Group’sassociates

The carrying amount of interests in associates included in the

consolidated financial statements of NLB Group:

d) Analysis by type of investment in associates and joint ventures

![]()

243

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

5.13.

Other assets

in EUR thousands

NLB GroupNLB

31 Dec 202131 Dec 202031 Dec 202131 Dec 2020

Assets. received as collateral (note 6.1.l)75,45076,0174,8274,926

Deferred expenses10,0469,1576,2025,976

Inventories2,1737,85842180

Claim for taxes and other dues1,8262,949

621

467

Prepayments1,7261,159161115

Total91,22197,14011,85311,664

20212020

Nature of Business

Country of

Incorporation

Voting rights%Voting rights%

Prvi Faktor Group, LjubljanaFinanceSlovenia5050

in EUR thousands

NLB Group20212020

Balance as at 1 January7,9887,499

Increase in capital share2,900326

Share of result before tax1,3391,036

Share of tax(231)(162)

Net gains/(losses) recognised in other comprehensive income(30)(41)

Dividends received(441)(670)

Balance as at 31 December11,5257,988

In 2021, NLB Group did not recognise a share of profit of an

associate in the amount of EUR 65 thousand (2020: EUR 31

thousand), as it still has the cumulative unrecognised share of

In 2021, NLB Group did not recognise a share of profit of a joint

venture in the amount of EUR 435 thousand (2020: EUR 556

thousand). The cumulative unrecognised share of losses of a

joint venture as at 31 December 2021 amounted to EUR 14,825

thousand (31 December 2020: EUR 15,259 thousand).

losses of an associate that as at 31 December 2021 amounted

to EUR 2,199 thousand (31 December 2020: EUR 2,264

thousand).

Assets, received as collateral on NLB Group in the amount

of EUR 74,717 thousand (31 December 2020: EUR 75,151

thousand), and on NLB in the amount of EUR 4,827 thousand

(31 December 2020: EUR 4,926 thousand) consist of real estate

(note 6.1.l).

NLB Group’s joint ventures

e) Movements of investments in associates

![]()

244

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

in EUR thousands

NLB Group

Balance as at

1 Jan 2021

Effects of

translation

of foreign

operations to

presentation

currency

Transfers

Increases/

(Decreases)

Write-offs

Changes in

models/risk

parameters

Foreign

exchange

differences

and other

movements

Disposal of

subsidiary

Balance as at

31 Dec 2021

Repayments

of written-off

receivables

Notes4.14.4.14.5.6.b), c), d)4.14.

12-month expected credit losses

Loans and advances to banks141--9-48--

198

-

Loans and advances to individuals25,044514,152(13,005)(164)(7,479)(3)(214)

18,336

-

Loans and advances to other customers49,475204,0362,476(8)(4,292)31(777)

50,961

-

Other financial assets

276

(2)202115(54)(70)10(1)

476

-

Lifetime ECL not credit-impaired

Loans and advances to individuals8,1511(8,554)6,975(35)898(3)(35)

7,398

-

Loans and advances to other customers32,6824(3,515)(240)(231)(1,960)21(137)

26,624

-

Other financial assets30--7(7)9(3)-

36

-

Lifetime ECL credit-impaired

Loans and advances to individuals61,30514(5,598)25,606(15,160)7,8682,135(123)

76,047

7,449

Loans and advances to other customers195,623

587

(521)8(66,532)1,6416,226(425)

136,607

42,272

Other financial assets5,247-(202)1,770(847)(112)(142)-

5,714

470

Of which: Purchased or originated credit-impaired

Loans and advances to individuals-1-(1,157)(702)-1,701-

(157)

-

Loans and advances to other customers1,319--(3,243)(2,312)-4,849-

613

-

Other financial assets4(1)-(602)(9)---

(608)

-

5.14.Movements in allowance for the impairment of financial assets

a)Movements in allowance for the impairment of loans and receivables measured at amortised cost

![]()

245

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

in EUR thousands

NLB Group

Balance as at

1 Jan 2020

Effects of

translation

of foreign

operations to

presentation

currency

Transfers

Increases/

(Decreases)

Write-offs

Changes in

models/risk

parameters

Foreign

exchange

differences

and other

movements

Disposal of

subsidiary

Balance as at

31 Dec 2020

Repayments

of written-off

receivables

Notes4.14.4.14.5.6.b), c), d)4.14.

12-month expected credit losses

Loans and advances to banks95(1)-

62

-(15)--

141

-

Loans and advances to individuals21,613(22)12,806(9,062)(1)(290)--

25,044

-

Loans and advances to other customers35,115(9)5,0047,803(6)1,597(18)(11)

49,475

-

Other financial assets177(1)6380(22)(21)--

276

-

Lifetime ECL not credit-impaired

Loans and advances to individuals6,103(3)(11,149)7,250(3)5,92528-

8,151

-

Loans and advances to other customers27,076(2)(8,675)4,955(4)9,334(2)-

32,682

-

Other financial assets271(17)(143)(4)166--

30

-

Lifetime ECL credit-impaired

Loans and advances to individuals47,737(22)(1,610)29,353(20,159)1,6894,317-

61,305

5,858

Loans and advances to other customers184,800

67

3,62411,750(31,254)9827,584(1,046)

195,623

9,565

Other financial assets4,702(9)(46)2,395(2,258)16485(38)

5,247

499

Of which: Purchased or originated credit-impaired

Loans and advances to other customers1,887--(568)----

1,319

-

Other financial assets3--1----

4

-

Column Increases/(Decreases) for year 2020 also includes

12-month expected credit losses recognised at acquisition of

Komercijalna banka in the amount of EUR 2,150 thousand for

Loans and advances to individuals, in the amount of EUR 8,198

thousand for Loans and advances to other customers and

in the amount of EUR 54 thousand for Other financial assets

(notes 4.14. and 5.12.c).

![]()

246

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

in EUR thousands

NLB

Balance as at

1 Jan 2021

Transfers

Increases/

(Decreases)

Write-offs

Changes in

models/risk

parameters

Foreign

exchange

differences

and other

movements

Balance as at

31 Dec 2021

Repayments

of written-off

receivables

Notes4.14.4.14.5.6.b), c), d)4.14.

12-month expected credit losses

Loans and advances to banks155-27---

182

-

Loans and advances to individuals8,9733,881(4,914)(156)(4,281)-

3,503

-

Loans and advances to other customers16,6644,740(5,419)(1)(5,915)32

10,101

-

Other financial assets731441(12)(57)3

62

-

Lifetime ECL not credit-impaired

Loans and advances to individuals2,351(2,181)2,007(27)2701

2,421

-

Loans and advances to other customers8,936(2,651)(2,715)(3)(1,799)19

1,787

-

Other financial assets2-(1)---

1

-

Lifetime ECL credit-impaired

Loans and advances to individuals22,855(1,700)8,779(6,020)7,56617

31,497

2,597

Loans and advances to other customers83,593(2,089)(659)(33,269)349(815)

47,110

8,682

Other financial assets1,255(14)129(280)--

1,090

120

Of which: Purchased or originated credit-impaired

Loans and advances to other customers1,319-1,339--(1,820)

838

-

Other financial assets4-2---

6

-

![]()

247

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

The contractual amount outstanding on financial assets

that were written off during the year ending 31 December

2021 and that are still subject to enforcement activity for NLB

Group amounted to EUR 76,252 thousand (31 December 2020:

EUR 42,738 thousand), and for NLB amounted to EUR 8,136

thousand (31 December 2020: EUR 9,773 thousand), of which

EUR 2,251 thousand in NLB Group (31 December 2020: EUR

4,162 thousand) and EUR 1,265 thousand in NLB (31 December

2020: EUR 2,537 thousand) represents interest receivables that

have not been recognised in the income statement prior to the

write-off.

in EUR thousands

NLB

Balance as at

1 Jan 2020

Transfers

Increases/

(Decreases)

Write-offs

Changes in

models/risk

parameters

Foreign

exchange

differences

and other

movements

Balance as at

31 Dec 2020

Repayments

of written-off

receivables

Notes4.14.4.14.5.6.b), c), d)4.14.

12-month expected credit losses

Loans and advances to banks141-32-(18)-

155

-

Loans and advances to individuals7,1956,107(6,509)(1)2,181-

8,973

-

Loans and advances to other customers13,5293,254(3,388)(6)3,303(28)

16,664

-

Other financial assets5568(22)(2)(25)(1)

73

-

Lifetime ECL not credit-impaired

Loans and advances to individuals1,396(4,953)3,422(3)2,491(2)

2,351

-

Loans and advances to other customers9,792(3,261)(2,516)(4)4,925-

8,936

-

Other financial assets9(1)(7)-1-

2

-

Lifetime ECL credit-impaired

Loans and advances to individuals15,576(1,154)14,318(6,227)(365)

707

22,855

2,319

Loans and advances to other customers71,2777(2,677)(7,159)(119)22,264

83,593

4,139

Other financial assets1,777(67)411(864)(2)-

1,255

328

Of which: Purchased or originated credit-impaired

Loans and advances to other customers1,856-(537)---

1,319

-

Other financial assets3-1---

4

-

![]()

248

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

b)Movements in allowance for the impairment of debt securities

in EUR thousands

NLB Group

Balance as at

1 Jan 2021

Effects of

translation

of foreign

operations to

presentation

currency

Transfers

Increases/

(Decreases)

Changes in

models/risk

parameters

Foreign

exchange

differences

and other

movements

Disposal of

subsidiary

Balance as at

31 Dec 2021

Notes4.14.4.14.5.6.a), 5.4.a)

12-month expected credit losses

Debt securities measured at amortised cost3,6851(32)997(1,400)2-

3,253

Debt securities measured at fair value

through other comprehensive income

8,6562-812,73118(340)

11,148

Lifetime ECL not credit-impaired

Debt securities measured at amortised cost--32164--

52

Debt securities measured at fair value

through other comprehensive income

28--

24

18--

70

Lifetime ECL credit-impaired

Debt securities measured at fair value

through other comprehensive income

798------

798

in EUR thousands

NLB Group

Balance as at

1 Jan 2020

Effects of

translation

of foreign

operations to

presentation

currency

Transfers

Increases/

(Decreases)

Changes in

models/risk

parameters

Foreign

exchange

differences

and other

movements

Balance as at

31 Dec 2020

Notes4.14.4.14.5.6.a), 5.4.a)

12-month expected credit losses

Debt securities measured at amortised cost3,140(2)-343204-

3,685

Debt securities measured at fair value

through other comprehensive income

4,7572-4,156(253)(6)

8,656

Lifetime ECL not credit-impaired

Debt securities measured at fair value

through other comprehensive income

42--(6)(9)1

28

Lifetime ECL credit-impaired

Debt securities measured at fair value

through other comprehensive income

798-----

798

Column Increases/(Decreases) for year 2020 includes also

12-month expected credit losses recognised at acquisition of

Komercijalna banka in the amount of EUR 32 thousand for

Debt securities measured at amortised cost and in the amount

of EUR 2,932 thousand for Debt securities measured at fair

value through other comprehensive income (notes 4.14. and

5.12.c).

![]()

249

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

in EUR thousands

NLB

Balance as at

1 Jan 2021

Increases/

(Decreases)

Changes in

models/risk

parameters

Foreign exchange

differences and

other movements

Balance as at

31 Dec 2021

Notes4.14.4.14.5.6.a), 5.4.a)

12-month expected credit losses

Debt securities measured at amortised cost1,841456(473)2

1,826

Debt securities measured at fair value through other comprehensive income2,343(22)(126)8

2,203

Lifetime ECL credit-impaired

Debt securities measured at fair value through other comprehensive income798---

798

in EUR thousands

NLB

Balance as at

1 Jan 2020

Increases/

(Decreases)

Changes in

models/risk

parameters

Foreign exchange

differences and

other movements

Balance as at

31 Dec 2020

Notes4.14.4.14.5.6.a), 5.4.a)

12-month expected credit losses

Debt securities measured at amortised cost1,61716208-

1,841

Debt securities measured at fair value through other comprehensive income1,714

626

9(6)

2,343

Lifetime ECL credit-impaired

Debt securities measured at fair value through other comprehensive income798---

798

![]()

250

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

c) Explanation of how significant changes in the gross carrying amount of financial instruments contributed to changes in the loss allowance

Movement of gross carrying amountof loans to banks

Movement of gross carrying amountof loans and advances to individuals

in EUR thousands

NLB GroupNLB

12-month expected credit losses2021202020212020

Balance as at 1 January197,14693,498158,475144,493

Effects of translation of foreign operations to presentation currency(7)(99)--

Acquisition of subsidiaries (note 5.12.c)-46,981--

Decreases/Increases(61,245)56,61641,09413,829

Exchange differences on monetary assets4,987150(100)153

Balance as at 31 December140,881197,146199,469158,475

in EUR thousands

NLB GroupNLB

Individuals

12-month expected

credit losses

Lifetime ECL not

credit - impaired

Lifetime ECL

credit-impaired

Total

12-month expected

credit losses

Lifetime ECL not

credit - impaired

Lifetime ECL

credit-impaired

Total

Balance as at 1 January 20214,777,413132,987117,1935,027,5932,295,63064,67551,6442,411,949

Effects of translation of foreign

operations to presentation currency

1,268(8)261,286----

Transfers(39,411)4,60434,807-(17,729)5,23012,499-

Increases/(Decreases)666,437(16,708)(8,010)641,719291,509(3,888)(764)286,857

Write-offs(164)(35)(15,160)(15,359)(156)(27)(6,020)(6,203)

Exchange differences on monetary assets1,93027321,9891,67145371,753

Modification losses (note 4.12.)(31)(6)(2)(39)----

Disposal of subsidiary(34,891)(626)(601)(36,118)----

Balance as at 31 December 20215,372,551120,235128,2855,621,0712,570,92566,03557,3962,694,356

in EUR thousands

NLB GroupNLB

Individuals

12-month expected

credit losses

Lifetime ECL not

credit - impaired

Lifetime ECL

credit-impaired

Total

12-month expected

credit losses

Lifetime ECL not

credit - impaired

Lifetime ECL

credit-impaired

Total

Balance as at 1 January 20203,822,266103,73487,4884,013,4882,301,33934,82640,6272,376,792

Effects of translation of foreign

operations to presentation currency

(20)(1)-(21)----

Acquisition of subsidiaries (note 5.12.c)843,675-5,753849,428----

Transfers(88,975)44,78544,190-(50,790)36,06614,724-

Increases/(Decreases)203,520(15,470)(4,342)183,70844,914(6,216)1,81240,510

Write-offs(1)(3)(20,159)(20,163)(1)(3)(6,227)(6,231)

Exchange differences on monetary assets(1,983)(88)(54)(2,125)16823173

Excluded interest-304,3174,347--705705

Modification losses (note 4.12.)(1,069)--(1,069)----

Balance as at 31 December 20204,777,413132,987117,1935,027,5932,295,63064,67551,6442,411,949

![]()

251

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

In year 2021, the loss allowance for loans and advances to

individuals increased by EUR 7,281 thousand at NLB Group

level, while at NLB level it increased by EUR 3,242 thousand.

Even though the gross carrying amount increased mainly in

Stage 1 due to new exposures, the increase of loss allowance

was observed mostly in Stage 3. The main reason for this were

changes in risk parameters, which increased loss allowance

for Stage 3 loans and advances to individuals in the amount

of EUR 7,868 thousand at NLB Group level and EUR 7,566

thousand at NLB level.

In year 2020, the loss allowance for loans and advances

to individuals increased by EUR 19,047 thousand at NLB

Group level, while at NLB level it increased by EUR 10,012

thousand. The main reasons for the increase were changed

risk parameters, which increased loss allowance by

EUR7,324thousand at NLB Group level and by EUR 4,307

thousand at NLB level. At the NLB Group level, the gross

carrying amount increased by EUR 1,014,105 thousand, mainly

due to acquisition of subsidiaries, while at the NLB level it

increased by EUR 35,157 thousand.

Acquisition of subsidiaries (note 5.12.c) contributed EUR

849,428 thousand to the gross carrying amount of loans

and advances to individuals on NLB Group level. For the

performing part of this portfolio, 12-month expected credit

losses in the amount of EUR 2,150 thousand were recognised.

The gross carrying amount also increased due to changed

presentation of excluded interest. NLB Group calculates

interest income by applying the effective interest rate to the

gross carrying amount of financial assets other than credit-

impaired assets. When a financial asset becomes credit-

impaired and is, therefore, classified in Stage 3, interest

income is calculated by applying the effective interest rate

to the net amortised cost of the financial asset. Part of the

contractually due interest for Stage 3 exposures that is

not included in the income statement (so-called ‘excluded

interest’) has been in previous periods presented as a

decrease of gross carrying amount of financial assets. In

year 2020, the Bank of Slovenia changed the instructions

for reporting of monetary financial institutions and regards

excluded interest as part of gross carrying amount, even

if not recognised in the income statement. Therefore, NLB

Group changed the presentation as at 31 December 2020 and

increased gross carrying amount and impairments for EUR

4,347 thousand on the Group level and EUR 705 thousand on

the NLB level.

![]()

252

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Movement of gross carrying amountof loans and advances to othercustomers

In year 2021, the gross carrying amount of loans and advances

to other customers increased by EUR 317,476 thousand at NLB

Group level and EUR 251,615 thousand at NLB level, mostly in

Stage 1 due to increased exposure. Regardless of that, loss

allowance decreased (for EUR 63,588 thousand at NLB Group

level and EUR 50,195 thousand), with main reasons being

write-offs (EUR 66,771 thousand at NLB Group level and EUR

33,273 thousand at NLB level) and changes in risk parameters

(decrease of loss allowance at NLB Group level for EUR 4,611

thousand and at NLB level for EUR 7,365 thousand).

In year 2020, the loss allowance for loans and advances to

other customers increased by EUR 30,789 thousand at NLB

Group level, while at NLB level it increased by EUR 14,595

thousand. The main reasons for the increase were changed

risk parameters, which increased loss allowance by EUR

in EUR thousands

NLB GroupNLB

Other customers

12-month expected

credit losses

Lifetime ECL not

credit - impaired

Lifetime ECL

credit-impaired

Total

12-month expected

credit losses

Lifetime ECL not

credit - impaired

Lifetime ECL

credit-impaired

Total

Balance as at 1 January 20214,219,862427,166317,5194,964,5471,982,033193,835119,7332,295,601

Effects of translation of foreign

operations to presentation currency

1,220828522,154----

Transfers(110,801)85,36425,437-(13,004)11,9311,073-

Increases/(Decreases)608,913(98,209)(34,880)475,824379,138(82,687)(15,037)281,414

Write-offs(8)(231)(66,532)(66,771)(1)(3)(33,269)(33,273)

Exchange differences on monetary assets3,6202351594,0143,1092281373,474

Modification losses (note 4.12.)(17)(6)(201)(224)----

Disposal of subsidiary(92,304)(2,217)(3,000)(97,521)----

Balance as at 31 December 20214,630,485412,184239,3545,282,0232,351,275123,30472,6372,547,216

in EUR thousands

NLB GroupNLB

Other customers

12-month expected

credit losses

Lifetime ECL not

credit - impaired

Lifetime ECL

credit-impaired

Total

12-month expected

credit losses

Lifetime ECL not

credit - impaired

Lifetime ECL

credit-impaired

Total

Balance as at 1 January 20203,270,058367,283261,3393,898,6802,049,210154,600106,7622,310,572

Effects of translation of foreign

operations to presentation currency

(2,407)(197)(126)(2,730)----

Acquisition of subsidiaries (note 5.12.c)993,295-34,6261,027,921----

Transfers(169,871)108,99560,876-(100,324)77,76122,563-

Increases/(Decreases)130,986(48,552)(35,202)47,23236,267(38,342)(24,596)(26,671)

Write-offs(6)(4)(31,254)(31,264)(6)(4)(7,159)(7,169)

Exchange differences on monetary assets(168)(2)(3)(173)(3,114)(180)(121)(3,415)

Excluded interest--27,38927,389--22,28422,284

Modification losses (note 4.12.)(2,025)(357)(126)(2,508)----

Balance as at 31 December 20204,219,862427,166317,5194,964,5471,982,033193,835119,7332,295,601

11,029thousand at NLB Group level and by EUR 8,109 thousand

at NLB level. At the NLB Group level, the gross carrying

amount increased by EUR 1,065,867 thousand, mainly due to

acquisition of subsidiaries, while at the NLB level it decreased

by EUR 14,971 thousand.

![]()

253

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Acquisition of subsidiaries (note 5.12.c) contributed EUR

1,027,921 thousand to the gross carrying amount of loans

and advances to customers on NLB Group level. For

the performing part of this portfolio, 12-month expected

credit losses in the amount of EUR 8,183 thousand were

recognised.

The gross carrying amount also increased for EUR 27,389

thousand at NLB Group level and for EUR 22,284 thousand at

NLB level due to changed presentation of excluded interest.

Movement of gross carrying amountof other financial assets

The loss allowance for other financial assets in year 2021 on

NLB Group level moved in line with gross carrying amount

and increased by EUR 673 thousand. At NLB level, gross

carrying amount increased by EUR 37,724 thousand, but

most of this increase relates to receivables with very short

maturity (of that EUR 20,492 thousand to receivables towards

a subsidiary for dividends declared in 2021). Therefore,

the loss allowance in 2021 slightly decreased (by EUR 177

thousand), with main reason being write-offs in the amount

of EUR 292 thousand.

The loss allowance for other financial assets in year 2020

moved in line with gross carrying amount and increased by

EUR 647 thousand at NLB Group level, while at the NLB level it

decreased by EUR 511 thousand.

in EUR thousands

NLB GroupNLB

2021202020212020

12-month expected

credit losses

Lifetime ECL

not credit - impaired

12-month expected

credit losses

12-month expected

credit losses

12-month expected

credit losses

Balance as at 1 January1,506,772-1,656,9881,279,7211,486,783

Effects of translation of foreign operations to presentation currency

74

11(325)--

Acquisition of subsidiaries (note 5.12.c)--7,214--

Additions769,067-303,670639,735181,235

Derecognition(564,041)-(477,592)(486,630)(401,685)

Net interest income13,144-16,1309,50412,701

Exchange differences on monetary assets1,348-(429)1,364(429)

Other(5,444)-1,116(5,444)1,116

Transfers(7,209)7,209---

Balance as at 31 December1,713,7117,2201,506,7721,438,2501,279,721

Movement of gross carrying amount of debt securities measured at amortised cost

![]()

254

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Movement of gross carrying amountof debt securities measured at fair valuethrough other comprehensive income

in EUR thousands

NLB GroupNLB

12-month expected

credit losses

Lifetime ECL not

credit - impaired

Lifetime ECL

credit-impaired

Total

12-month expected

credit losses

Lifetime ECL not

credit - impaired

Lifetime ECL

credit-impaired

Total

Balance as at 1 January 20213,407,3942037983,408,3951,639,915-7981,640,713

Effects of translation of foreign

operations to presentation currency

1,204--1,204----

Additions1,455,823--1,455,823219,733--219,733

Derecognition(1,481,974)(19)-(1,481,993)(352,824)--(352,824)

Net interest income40,310--40,31011,696--11,696

Exchange differences on monetary assets8,367--8,3678,452--8,452

Disposal of subisidiary(35,023)--(35,023)----

Balance as at 31 December 20213,396,1011847983,397,0831,526,972-7981,527,770

in EUR thousands

NLB GroupNLB

12-month expected

credit losses

Lifetime ECL not

credit - impaired

Lifetime ECL

credit-impaired

Total

12-month expected

credit losses

Lifetime ECL not

credit - impaired

Lifetime ECL

credit-impaired

Total

Balance as at 1 January 20202,055,3622207982,056,3801,583,603-7981,584,401

Effects of translation of foreign

operations to presentation currency

(421)--(421)----

Acquisition of subsidiaries (note 5.12.c)1,267,281--1,267,281----

Additions1,856,445--1,856,4451,045,700--1,045,700

Derecognition(1,777,748)(17)-(1,777,765)(988,275)--(988,275)

Net interest income17,370--17,3709,894--9,894

Exchange differences on monetary assets(10,895)--(10,895)(11,007)--(11,007)

Balance as at 31 December 20203,407,3942037983,408,3951,639,915-7981,640,713

![]()

255

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

5.15.Financial liabilities, measured at amortised cost

Analysis by type of financial liabilities, measured at the amortised cost

a)Deposits from banks and central banks and amounts due to customers

in EUR thousands

NLB GroupNLB

31 Dec 202131 Dec 202031 Dec 202131 Dec 2020

Deposits from banks and central banks71,82872,633109,32941,635

Borrowings from banks and central banks858,531158,225873,479143,464

Due to customers17,640,80916,397,1679,659,6058,850,755

Borrowings from other customers74,05191,56040613

Subordinated liabilities288,519288,321288,519288,321

Other financial liabilities206,878182,095102,52788,969

Total19,140,61617,190,00111,033,8659,413,157

in EUR thousands

NLB GroupNLB

31 Dec 202131 Dec 202031 Dec 202131 Dec 2020

Deposit on demand

- banks and central banks56,42752,25094,32341,635

- other customers15,319,11213,633,8898,982,5468,128,950

- governments

401,295307,082109,22886,276

- financial organisations

303,858192,224265,900137,204

- companies

3,653,7133,223,6121,870,1181,551,952

- individuals

10,960,2469,910,9716,737,3006,353,518

Other deposits

- banks and central banks15,40120,38315,006-

- other customers2,321,6972,763,278677,059721,805

- governments

95,062117,42834,80135,515

- financial organisations

125,310134,71671,58234,474

- companies

380,815398,595229,093192,955

- individuals

1,720,5102,112,539341,583458,861

Total17,712,63716,469,8009,768,9348,892,390

![]()

256

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

b)Borrowings from banks and central banks and other customers

As at 31 December 2021, NLB Group and NLB had EUR 94,115

thousand in undrawn borrowings (31 December 2020: EUR

140,713 thousand).

In June 2021, the Bank participated in the ECB TLTRO III.8

operation and had drawn a credit tranche of EUR 750,000

thousand for three years. With targeted longer-term

refinancing operations, the ECB continues to support the

access of enterprises and households to bank loans. The

Bank was successful in achieving the lending performance

threshold in the special reference period and will use the

positive effect from this transaction to partially compensate

for the negative carry of liquidity reserves. Based on

currently available information, the Bank plans to opt for

early repayment in June 2022.

NLB Group accounts for this loan according to the

requirements of IFRS 9. Expected effective interest rate was

estimated based on the expectations of early repayment

in June 2022 and achieving the lending performance

in EUR thousands

NLB GroupNLB

31 Dec 202131 Dec 202031 Dec 202131 Dec 2020

Loans

- banks and central banks858,531158,225873,479143,464

- other customers74,05191,56040613

- governments

20,60720,183--

- financial organisations

52,95870,956--

- companies

48642140613

Total932,582249,785873,885143,477

in EUR thousands

NLB Group and NLB

31 Dec 202131 Dec 2020

CurrencyDue dateInterest rateCarrying amountNominal valueCarrying amountNominal value

Subordinated bonds

EUR06.05.20294.2% to 06.05.2024, thereafter 5Y MS + 4.159% p.a.45,90345,00045,86745,000

EUR19.11.20293.65% to 19.11.2024, thereafter 5Y MS + 3.833% p.a.119,577120,000119,480120,000

EUR05.02.20303.4% to 05.02.2025, thereafter 5Y MS + 3.658% p.a.123,039120,000122,974120,000

Total288,519285,000288,321285,000

threshold. Since the threshold was achieved and early

repayment in June 2022 is still expected, no changes in

estimates of payments due to revised assessment were

needed. By applying the effective interest rate of -1%, NLB

Group recognised in 2021 interest income in the amount of

EUR 3,979 thousand (note 4.1.). The carrying amount of the

loan as at 31 December 2021 amounts to EUR 746,021 thousand.

c) Subordinated liabilities

![]()

257

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Movement of subordinated liabilities

after obtaining approval from the ECB. As such, approval

had not been granted by 23 December 2019, and it was not

reasonably expected to be granted in the near future, NLB

announced the prepayment of the loan, which was exercised

in January 2020.

in EUR thousands

NLB Group and NLB20212020

Balance as at 1 January288,321210,569

Cash flow items:(10,350)67,383

- new issued subordinated liabilities-119,222

- repayment of subordinated liabilities-(45,000)

- repayment of interest(10,350)(6,839)

Non-Cash flow items:10,54810,369

- accrued interest10,54810,243

- other-126

Balance as at 31 December288,519288,321

In September 2019, NLB entered into a loan agreement

relating to a EUR 45 million of subordinated loan intended for

the inclusion into additional capital to strengthen and optimise

its capital structure. NLB may, according to valid legislation,

only include the loan in calculation of additional capital

in EUR thousands

NLB GroupNLB

31 Dec 202131 Dec 202031 Dec 202131 Dec 2020

Items in the course of settlement57,93446,3955,9404,412

Debit or credit card payables27,32522,88324,63820,135

Suppliers17,51420,99312,04915,768

Lease liabilities (note 5.11.a)24,32426,3593,2563,212

Accrued expenses25,85221,31412,90910,635

Fees and commissions1,6091,1001,504

967

Liabilities to brokerage firms and others for

securities purchase and custody services

2972,4592022,443

Other financial liabilities52,02340,59242,02931,397

Total206,878182,095102,52788,969

d) Other financial liabilities

Other financial liabilities mainly include liabilities to

insurance companies, liabilities for received EIB financial

initiatives, received warranties, and obligation for purchase

of securities.

All issued subordinated bonds represent non-convertible

Tier 2 instruments (note 5.22.). In the event of bankruptcy

or liquidation of the issuer, obligations arising from Tier 2

instruments shall be repaid:

a) after repayment of all unsubordinated obligations

of the Issuer, as well as at all subordinated obligations

(if any) which are expressed to rank in priority to Tier 2

instruments;

b) with the same priority (

pari passu

) as, and proportionally

with the obligations arising from other instruments which

qualify as Tier 2 instruments or have the same priority of

repayment as the Tier 2 instruments;

c) in priority to the obligations arising from shares or other

instruments which qualify as Common Equity Tier 1 capital

instruments or additional Tier 1 instruments or have the same

priority of repayment as these instruments.

![]()

258

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

5.16.

Provisions

a) Analysis by type of provisions

in EUR thousands

NLB GroupNLB

31 Dec 202131 Dec 202031 Dec 202131 Dec 2020

Provisions for guarantees and commitments (note 5.23.a)33,44142,17420,56028,543

Stage 112,91215,7963,9097,510

Stage 21,6402,767141732

Stage 318,88923,61116,51020,301

Employee benefit provisions21,44720,70714,20614,220

Restructuring provisions19,21715,56511,13115,354

Provisions for legal risks45,28846,6023,4665,673

Other provisions1111--

Total119,404125,05949,36363,790

Provisions for guarantees and commitments represent

expected credit losses in accordance with IFRS 9, employee

benefits are recognised in accordance with IAS 19, while all

other provisions are recognised according to IAS 37.

Legalrisks

Provisions for legal risks are formed based on expectations

regarding the probable outcome of legal disputes. As at 31

December 2021, NLB Group was involved in 38 (31 December

2020: 39) legal disputes with material claims against Group

members in the total amount of EUR 404,001 thousand,

excluding accrued interest (31 December 2020: EUR 292,098

thousand). As at 31 December 2021, NLB was involved in 16 (31

December 2020: 18) legal disputes with material monetary

claims against NLB. The total amount of these claims,

excluding accrued interest, was EUR 180,077 thousand (31

December 2020: EUR 179,996 thousand).

In connection with legal risks, the largest amount of material

monetary claims relates to civil claims filed by Privredna

banka Zagreb (the PBZ) and Zagrebačka banka (the ZaBa)

against NLB, referring to the old savings of LB Branch Zagreb

savers, which were transferred to these two banks in a

principal amount of approximately EUR 171 million (as per 31

December 2021). Due to the fact the proceedings had been

pending for such a long time, the penalty interest already

exceeds the principal amount. As NLB is not liable for the old

foreign currency savings, based on numerous process and

content-related reasons, NLB has all along objected to these

claims. Two key reasons NLB is not liable for the old foreign

currency savings are that it was only founded on the basis of

the Constitutional Act on 27 July 1994 (at the time the savings

were deposited with LB Branch Zagreb, NLB did not yet exist),

and NLB did not assume any such obligations.

Moreover, this is a former Yugoslavia succession matter, as the

governments of the Republic of Slovenia and the Republic of

Croatia agreed in a Memorandum of Understanding signed

in 2013 whose intent was to find a solution to the transferred

foreign currency savings of Ljubljanska banka in Croatia

(LB) on the basis of the Agreement on Succession Issues. The

Memorandum also said that the Republic of Croatia would

ensure the stay of all the proceedings commenced by the PBZ

and the ZaBa in relation to the transferred foreign currency

savings until the issue was finally resolved.

Despite the agreement in the Memorandum of Understanding

to stay all of the proceedings commenced, the Court of Appeal,

the County Court of Zagreb, ruled in six claims (as explained

below in detail) in favour of the plaintiff. In four of those cases,

NLB filed a constitutional suit after extraordinary legal measure

of NLB with the Supreme Court of the Republic of Croatia was

not successful, and in two NLB filed an extraordinary legal

measure with the Supreme Court of the Republic of Croatia.

![]()

259

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Contrary to the decisions of the court described above in

another case, a claim filed by the PBZ was refused and the

judgment became final in favour of NLB. The extraordinary

legal measure with the Supreme Court of the Republic of

Croatia, filed by the plaintiff, was dismissed by the Supreme

Court on 16 June 2015.

Date of the rulingPlaintiff

Principal

amount

Costs of the

proceedings

Measures taken by NLB

May 2015PBZ254.76 EUR15,781.25 HRK

Constitutional suit against the final judgement, as NLB found the court decision contrary to the legislation in force and

constitutional principles and as well contrary to the Memorandum concluded between the Republic of Slovenia and the Republic

of Croatia. Constitutional Court of the Republic of Croatia rejected the constitutional appeal of NLB d.d. on 21 May 2018.

April 2018PBZ222,426.39 EUR253,283.37 HRK

Constitutional suit against the court decisions (including the decision of the Supreme Court of the Republic of Croatia in

the revision proceeding), as NLB found the court decision contrary to the legislation in force and constitutional principles,

and as well contrary to the Memorandum concluded between the Republic of Slovenia and the Republic of Croatia.

Constitutional Court of the Republic of Croatia rejected the constitutional appeal of NLB d.d. on 5 October 2021.

September 2017ZaBa492,430.53 EUR748,583.75 HRK

Constitutional suit against the court decisions (including the decision of the Supreme Court of the Republic of Croatia in

the revision proceeding), as NLB found the court decision contrary to the legislation in force and constitutional principles,

and as well contrary to the Memorandum concluded between the Republic of Slovenia and the Republic of Croatia.

Constitutional Court of the Republic of Croatia rejected the constitutional appeal of NLB d.d. on 5 October 2021.

November 2017PBZ220,115.98 EUR688,268.12 HRK

NLB challenged the judgments with the extraordinary legal measure (revision) on the Supreme Count of the Republic of

Croatia and later, if necessary, will challenge the judgments with all other available remedies of the obligations of the

old foreign currency savings in accordance with Slovenian Constitutional Law are not the liabilities of NLB.

December 2018PBZ3,855,173.35 SEK679,926.08 HRK

Constitutional suit against the court decisions (including the decision of the Supreme Court of the Republic of Croatia in the

revision proceeding), as NLB found the court decision contrary to the legislation in force and constitutional principles and

as well contrary to the Memorandum concluded between the Republic of Slovenia and the Republic of Croatia.

March 2019PBZ9,185,141.76 USD3,198,760.00 HRK

NLB challenged the judgment with the extraordinary legal measure (revision) on the Supreme Count of the Republic of

Croatia and later, if necessary, will challenge the judgment with all other available remedies of the obligations of the

old foreign currency savings in accordance with Slovenian Constitutional Law are not the liabilities of NLB.

In the other cases, with respect to which court procedures

described above are pending, final court decisions have not yet

been issued.

The table below summarises the amounts according to final

court decisions (not including penalty interest).

The NLB Shareholders’ Meeting provided the Management

Board of NLB with instructions how to act in the event of

existing or potential new final decisions by Croatian courts

against LB and NLB regarding the transferred foreign

currency deposits, especially not to voluntarily settle the

adjudicated amounts, and also gave some additional

instructions on the usage of legal remedies and regarding the

management of the property from that perspective.

On 19 July 2018, the National Assembly of the Republic of

Slovenia passed the ‘Act for Value Protection of Republic of

Slovenia’s Capital Investment in Nova Ljubljanska banka

d.d., Ljubljana’ (Zakon za zaščito vrednosti kapitalske

naložbe Republike Slovenije v Novi Ljubljanski banki d.d.,

Ljubljana, hereinafter: ‘the ZVKNNLB’) which entered into

force on 14 August 2018. In accordance with the ZVKNNLB,

the Succession Fund of the Republic of Slovenia (Sklad

Republike Slovenije za nasledstvo, javni sklad, hereinafter:

‘the Fund’), shall compensate NLB for the sums recovered

from NLB by enforcement of final judgements delivered

by Croatian courts with regard to the transferred foreign

currency deposits, that is the principle amount, accrued

interest, expenses of court, attorney’s expenses and other

expenses of the plaintiff, and expenses related to enforcement

with the accrued interest, and shall not compensate NLB for

its own costs or for the difference between the book value

of its assets sold in enforcement proceedings and the price

obtained for such assets in enforcement proceedings. There

shall be no compensation for any voluntarily made payments

by NLB. In accordance with the ZVKNNLB and pursuant to

the agreement between NLB and the Fund, as envisaged by

the ZVKNNLB (which was concluded on 14 August 2018), NLB

has to contest the claims made against it in court proceedings

in relation to transferred foreign currency deposits, and use

against court decisions that are disadvantageous for NLB,

all reasonable legal remedies and to continue to actively

challenge the judicial decisions of the courts of the Republic

of Croatia in relation to transferred foreign currency deposits

on the basis of which enforcement took place, leading, on

the basis of ZVKNNLB, to the compensation of the sums

recovered from NLB by enforcement. In the aforementioned

case from May 2015, the Succession Fund of the Republic of

Slovenia has already compensated the sums recovered from

NLB by enforcement.

All procedures relating to the receivables of PBZ and ZaBa, as

well as NLB’s view on this matter were also discussed with the

ECB as the supervisor of both Croatian banks.

![]()

260

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

in EUR thousands

NLB Group

Balance as at

1 Jan 2021

Effects of

translation of

foreign operations

to presentation

currency

Transfer

Increases/

(Decreases)

Changes in

models/risk

parameters

Foreign

exchange

differences

and other

movements

Disposal of

subsidiary

Balance as at

31 Dec 2021

Notes4.13.4.13.5.16.a)

12-month expected credit losses

Guarantees and commitments15,79611,388(1,337)(2,810)(4)(122)12,912

Lifetime ECL not credit-impaired

Guarantees and commitments2,767-(730)(358)(37)4(6)1,640

Lifetime ECL credit-impaired

Guarantees and commitments23,6111(659)(4,239)27748(150)18,889

Of which: Purchased or originated credit-impaired

Guarantees and commitments5,057--(755)-42-4,344

b)Provisions for guarantees and commitments

Movements in provisions forguarantees and commitments

Provisions for legal risks for claims filed by PBZ and ZaBa are

not formed, since NLB believes that based on the factual and

legal evaluation there are greater prospects for the court

proceedings to end in favour of NLB than the opposite.

Regardless of the negative judgements, in the financial

statements NLB Group did not recognise the negative

impact due to protection provided by the ZVKNNLB. For final

judgements, NLB Group recognised the liabilities and related

assets which currently amount to approximately EUR 22

million. They are included within other financial assets (note

5.6.d) and other financial liabilities (note 5.15.d).

in EUR thousands

NLB Group

Balance as at

1 Jan 2020

Effects of

translation of

foreign operations

to presentation

currency

Acquisition of

subsidiaries

Transfer

Increases/

(Decreases)

Changes in

models/risk

parameters

Foreign

exchange

differences

and other

movements

Balance as at

31 Dec 2020

Notes4.13.4.13.5.16.a)

12-month expected credit losses

Guarantees and commitments12,909(4)1,0496591,863(676)(4)15,796

Lifetime ECL not credit-impaired

Guarantees and commitments2,444(5)-(300)(99)727-2,767

Lifetime ECL credit-impaired

Guarantees and commitments24,06811,249(359)(1,293)(40)(15)23,611

Of which: Purchased or originated credit-impaired

Guarantees and commitments1,984-1,249-1,838-(14)5,057

![]()

261

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

in EUR thousands

NLB

Balance as at

1 Jan 2021

Transfer

Increases/

(Decreases)

Changes in

models/risk

parameters

Foreign

exchange

differences

and other

movements

Balance as at

31 Dec 2021

Notes4.13.4.13.5.16.a)

12-month expected credit losses

Guarantees and commitments7,510530(1,451)(2,683)3

3,909

Lifetime ECL not credit-impaired

Guarantees and commitments732(123)(340)(129)1

141

Lifetime ECL credit-impaired

Guarantees and commitments20,301(407)(3,698)27341

16,510

Of which: Purchased or originated credit-impaired

Guarantees and commitments3,808-186-47

4,041

in EUR thousands

NLB

Balance as at

1 Jan 2020

Transfer

Increases/

(Decreases)

Changes in

models/risk

parameters

Foreign

exchange

differences

and other

movements

Balance as at

31 Dec 2020

Notes4.13.4.13.5.16.a)

12-month expected credit losses

Guarantees and commitments6,145

193

947

228

(3)

7,510

Lifetime ECL not credit-impaired

Guarantees and commitments653136(418)363(2)

732

Lifetime ECL credit-impaired

Guarantees and commitments22,365(329)(1,622)(97)(16)

20,301

Of which: Purchased or originated credit-impaired

Guarantees and commitments1,984-1,838-(14)

3,808

![]()

262

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Movement of contractualamounts of guarantees and commitments in off-balance sheet

in EUR thousands

NLB GroupNLB

12-month expected

credit losses

Lifetime ECL not

credit - impaired

Lifetime ECL

credit-impaired

Total

12-month expected

credit losses

Lifetime ECL not

credit - impaired

Lifetime ECL

credit-impaired

Total

Balance as at 1 January 20212,824,750103,95046,2702,974,9701,896,41873,25534,9072,004,580

Effects of translation of foreign

operations to presentation currency

68724

9720----

Increases/(Decreases)219,688(4,666)(9,309)205,7134,769(14,315)(8,167)(17,713)

Foreign exchange differences2,733101512,8852,57092482,710

Transfers(685)(1,752)2,437-9,815(9,930)115-

Disposal of subsidiary(19,202)(121)(460)(19,783)----

Balance as at 31 December 20213,027,97197,53638,9983,164,5051,913,57249,10226,9031,989,577

in EUR thousands

NLB GroupNLB

12-month expected

credit losses

Lifetime ECL not

credit - impaired

Lifetime ECL

credit-impaired

Total

12-month expected

credit losses

Lifetime ECL not

credit - impaired

Lifetime ECL

credit-impaired

Total

Balance as at 1 January 20202,108,271112,61673,1962,294,0831,575,21162,42969,6401,707,280

Effects of translation of foreign

operations to presentation currency

(543)(56)(3)(602)----

Acquisition of subsidiaries (note 5.12.c)369,847-7,514377,361----

Increases/(Decreases)368,553(16,936)(43,564)308,053346,086(6,940)(37,834)301,312

Foreign exchange differences(3,615)(147)(163)(3,925)(3,702)(147)(163)(4,012)

Transfers(17,763)8,4739,290-(21,177)17,9133,264-

Balance as at 31 December 20202,824,750103,95046,2702,974,9701,896,41873,25534,9072,004,580

![]()

263

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

c)Movements in employeebenefit provisions

Post-employment benefits

Other employee benefits

in EUR thousands

NLB GroupNLB

2021202020212020

Balance as at 1 January18,16215,32012,69513,165

Effects of translation of foreign operations

to presentation currency

-(2)--

Acquisition of subsidiaries (note 5.12.c)-3,374--

Disposal of subsidiaries(83)---

Additional provisions (note 4.9.)1,957983723

672

Provisions released (note 4.9.)(1,831)(560)(750)(433)

Interest expenses (note 4.1.)177

76

4327

Utilised during year (payments)(532)(151)(45)(36)

Actuarial gains and losses1,377(878)115(700)

Balance as at 31 December19,22718,16212,78112,695

in EUR thousands

NLB GroupNLB

2021202020212020

Balance as at 1 January2,5452,3841,5251,578

Effects of translation of foreign operations

to presentation currency

-(1)--

Acquisition of subsidiaries (note 5.12.c)-179--

Additional provisions (note 4.9.)222234100103

Provisions released (note 4.9.)(275)(112)(132)(38)

Interest expenses (note 4.1.)25

24

53

Utilised during year(297)(163)(73)(121)

Balance as at 31 December2,2202,5451,4251,525

Other employee benefits include NLB Group’s obligations for jubilee long-service benefits.

![]()

264

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

d) Movements in restructuring provisions

Following the acquisition of Komercijalna banka a.d.

Beograd in December 2020, NLB Group prepared a plan for

optimisation of operations, including anticipated merger

of banks in Serbia and decreased number of employees.

Therefore in 2021, Serbian banks recognised restructuring

provisions in the amount of EUR 14,797 thousand, of which EUR

6,868 thousand were already utilised during the year. The rest

is expected to be paid to employees leaving the bank within

the next twelve months.

in EUR thousands

NLB GroupNLB

2021202020212020

Balance as at 1 January15,56514,50015,35414,182

Effects of translation of foreign operations to presentation currency11(1)--

Disposal of subsidiaries-(50)--

Additional provisions (note 4.13.)14,7973,500-3,500

Utilised during year(11,156)(2,384)(4,223)(2,328)

Balance as at 31 December19,21715,56511,13115,354

in EUR thousands

NLB GroupNLB

2021202020212020

Balance as at 1 January46,60216,6275,6732,211

Effects of translation of foreign operations to presentation currency40(8)--

Acquisition of subsidiaries (note 5.12.c)-28,686--

Disposal of subsidiaries-(119)--

Additional provisions (note 4.13.)16,6326,3551,8814,411

Provisions released (note 4.13.)(8,759)(1,659)(1,809)(181)

Utilised during year(9,227)(3,280)(2,279)(768)

Balance as at 31 December45,28846,6023,4665,673

Significant amount of restructuring provisions relates also

to NLB, which has in previous periods adopted a business

strategy and initiatedkey strategicinitiatives, aiming

among others towards a leaner organisation, optimisation

of processes, implementation of a new IT strategy with a

focus on digitalisation and simplification, and adjustment of

the organisational structure. These initiatives will result in

decreased number of employees in the coming years.

e)Movements in provisions for legal risks

![]()

265

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

f) Movements in other provisions

5.17.Deferred income tax

a) Analysis by type of deferred income taxes

in EUR thousands

NLB GroupNLB

2021202020212020

Balance as at 1 January11

162

-85

Additional provisions (note 4.13.)-34--

Provisions released (note 4.13.)-(153)-(85)

Utilised during year-(32)--

Balance as at 31 December1111--

in EUR thousands

NLB GroupNLB

31 Dec 202131 Dec 202031 Dec 202131 Dec 2020

Deferred income tax assets

Valuation of financial instruments and capital investments33,00237,72931,69637,650

Impairment of financial assets5,8793,190917

947

Provisions for liabilities and charges10,1288,4892,6603,138

Depreciation and valuation of non-financial assets3,5054,063112140

Fair value adjustments of financial assets

measured at amortised cost

320938--

Unpaid dividends3,876-3,876-

Tax losses253---

Tax reliefs

945

1,179--

Other

62

111--

Total deferred income tax assets57,97055,69939,26141,875

Deferred income tax liabilities

Valuation of financial instruments12,02621,0236,62011,871

Depreciation and valuation of non-financial assets1,3741,515

169

193

Impairment of financial assets3,9603,271570597

Fair value adjustments of financial assets

measured at amortised cost

3,338592--

Other1,3401,984--

Total deferred income tax liabilities22,03828,3857,35912,661

Net deferred income tax assets38,97731,78931,90229,214

Net deferred income tax liabilities(3,045)(4,475)--

![]()

266

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Temporary differences on which NLB did not recognise

deferred tax assets, as related deferred tax assets would

exceed the amount of deferred tax assets expected to be

in EUR thousands

NLB GroupNLB

2021202020212020

Included in the income statement3,4233,238112540

- valuation of financial instruments and capital investments(1,024)308(3,241)308

- impairment of financial assets2,2603,108(30)163

- provisions for liabilities and charges1,45354(489)75

- depreciation and valuation of non-financial assets(338)(336)(4)(6)

- tax losses253---

- unpaid dividends3,876-3,876-

- tax reliefs(234)---

-fair value adjustments of financial assets

measured at amortised cost

(3,413)---

- other590104--

Included in other comprehensive income4,950(1,619)2,576(895)

-valuation and impairment of financial assets measured

at fair value through other comprehensive income

4,772(1,486)2,565(762)

- actuarial assumptions and experience

178

(133)11(133)

Included in equity - transfer of fair value reserve368---

-valuation of financial assets measured at fair

value through other comprehensive income

368---

in EUR thousands

31 Dec 202131 Dec 2020

NLB

Temporary

difference

Non-recognised

deferred tax assets

Temporary

difference

Non-recognised

deferred tax assets

Tax loss974,902185,231922,898175,351

Tax reliefs4,329823--

Impairments and valuation of capital

investments and financial instruments

73,35913,938242,86146,144

reversed in five years are presented in the table below,

together with non-recognised deferred tax assets.

Tax loss on which NLB did not recognise deferred tax assets,

as at 31 December 2021 amounts to EUR 974,902 thousand

(31December 2020: 922,898 thousand). Slovenian tax law

does not set deadlines by which uncovered tax losses must be

utilised, but the use of tax loss is limited to 50% of the actual

tax base. Other banking members have no unrecognised

deferred tax assets for tax losses.

NLB Group did not recognise deferred tax assets on

temporary differences arising from the impairments of

investments in subsidiaries and associates where it is not

probable that the temporary difference will reverse in the

foreseeable future. These temporary differences amount to

EUR 315,531 thousand as at 31 December 2021 (31 December

2020: EUR 347,040 thousand).

![]()

267

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

in EUR thousands

NLB Group

Provisions for

liabilities and

charges

Valuation

of financial

instruments and

capital investments

Depreciation and

valuation of non-

financial assets

Impairment of

financial assets

Unpaid

dividends

Tax lossesTax relief

Fair value

adjustments of

financial assets

measured at

amortised cost

OtherTotal

Balance as at 1 January 20204,10936,2861,087910-----42,392

Effects of translation of foreign operations

to presentation currency

4--2-----6

(Charged)/credited to profit and loss54188(156)2,247----1042,437

(Charged)/credited to other comprehensive income(133)1,240-------1,107

Acquisition of subsidiaries4,455153,13231--1,17993879,757

Balance as at 31 December 20208,48937,7294,0633,190--1,17993811155,699

Effects of translation of foreign operations

to presentation currency

8-14----215

(Charged)/credited to profit and loss1,453(3,368)(480)2,7913,876253(234)(618)(51)3,622

(Charged)/credited to other comprehensive income

178

(1,359)-------(1,181)

Disposal of subisidiaries--(79)(106)-----(185)

Balance as at 31 December 202110,12833,0023,5055,8793,876253

945

320

62

57,970

in EUR thousands

NLB

Provisions for

liabilities and

charges

Valuation

of financial

instruments and

capital investments

Depreciation and

valuation of non-

financial assets

Impairment

of financial

assets

Unpaid

dividends

Total

Balance as at 1 January 20203,19636,244154

784

-40,378

(Charged)/credited to profit and loss75188(14)163-412

(Charged)/credited to other

comprehensive income

(133)1,218---1,085

Balance as at 31 December 20203,13837,650140

947

-41,875

(Charged)/credited to profit and loss(489)(3,367)(28)(30)3,876(38)

(Charged)/credited to other

comprehensive income

11(2,587)---(2,576)

Balance as at 31 December 20212,66031,6961129173,87639,261

b) Movements in deferred income taxes

Deferred income tax assets

![]()

268

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

in EUR thousands

NLB Group

Impairment

of financial

assets

Valuation

of financial

instruments and

capital investments

Depreciation and

valuation of non-

financial assets

Other

Fair value adjustments

of financial assets

measured at

amortised cost

Total

Balance as at 1 January 20203,27011,1591,296--15,725

Effects of translation of foreign operations to presentation currency(7)-(2)--(9)

Charged/(credited) to profit and loss(861)(120)180--(801)

Charged/(credited) to other comprehensive income

696

2,030---2,726

Acquisition of subsidiaries1737,954411,98459210,744

Balance as at 31 December 20203,27121,0231,5151,98459228,385

Effects of translation of foreign operations to presentation currency131117

Charged/(credited) to profit and loss531(2,344)(142)(641)2,795199

Charged/(credited)to other comprehensive income157(6,656)---(6,499)

Disposal of subisidiaries---(4)(50)(54)

Balance as at 31 December 20213,96012,0261,3741,3403,33822,038

in EUR thousands

NLB

Impairment

of financial

assets

Valuation

of financial

instruments and

capital investments

Depreciation and

valuation of non-

financial assets

Total

Balance as at 1 January 202047710,13120110,809

Charged/(credited) to profit and loss-(120)(8)(128)

Charged/(credited) to other comprehensive income1201,860-1,980

Balance as at 31 December 202059711,87119312,661

Charged/(credited) to profit and loss-(126)(24)(150)

Charged/(credited) to other comprehensive income(27)(5,125)-(5,152)

Balance as at 31 December 20215706,620

169

7,359

Deferred income tax liabilities

![]()

269

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

5.18.

Income tax relating to components of other comprehensive income

in EUR thousands

2021NLB GroupNLB

Before taxTax expenseNet of taxBefore taxTax expenseNet of tax

Actuarial gains and losses(1,377)

178

(1,199)(115)11(104)

Financial assets measured at fair value through

other comprehensive income

(34,322)4,772(29,550)(17,742)2,565(15,177)

Share of associates and joint ventures(30)-(30)---

Total(35,729)4,950(30,779)(17,857)2,576(15,281)

in EUR thousands

2020NLB GroupNLB

Before taxTax expenseNet of taxBefore taxTax expenseNet of tax

Actuarial gains and losses

878

(133)

745

700(133)

567

Financial assets measured at fair value through

other comprehensive income

10,364(1,486)8,8784,012(762)3,250

Share of associates and joint ventures(11,067)-(11,067)---

Total175(1,619)(1,444)4,712(895)3,817

5.19.

Other liabilities

in EUR thousands

NLB GroupNLB

31 Dec 202131 Dec 202031 Dec 202131 Dec 2020

Accrued salaries18,61519,0689,0509,807

Unused annual leave6,0326,1372,4252,497

Deferred income11,37412,3645,2575,391

Taxes payable9,4505,0093,9994,107

Payments received in advance3,9972,195308199

Other liabilities-859--

Total49,46845,63221,03922,001

![]()

270

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

5.20.Share capital

The share capital of NLB amounts to EUR 200,000 thousand

and did not change in 2021. It is comprised of 20,000,000 no-

par-value ordinary registered shares, with the corresponding

value of EUR 10.0 for one share. All issued shares are fully paid

and there are no un-issued authorised shares. As at 31 December

2021, the major shareholder of NLB with significant influence is

the Republic of Slovenia, owning 25.00% plus one share.

The book value of a NLB share on a consolidated level as at 31

December 2021 was EUR 103.9 (31 December 2020: EUR 97.6),

and on solo level was EUR 77.6 (31 December 2020: EUR 72.5).

It is calculated as the ratio of net assets’ book value excluding

other equity instruments issued and the number of shares.

Distributable profit as at 31 December 2021 amounts to EUR

458,266 thousand (31 December 2020: EUR 341,992 thousand),

consists of NLB net profit for 2021 in the amount of EUR

208,421 thousand (2020: EUR 113,952 thousand), the transfer of

fair value reserve in the amount of EUR 53 thousand on the

derecognition of equity financial instruments measured at

fair value through OCI and retained earnings from previous

years in the amount of EUR 249,792 thousand. Its allocation

will be subject to a decision by the Bank’s General Assembly.

The proposal for the General Assembly will be prepared by

the Management and the Supervisory Board, considering

restrictions imposed by the regulators, Group’s risk appetite,

target capital adequacy at Group’s level and actual prevailing

capital position at the time of the proposal.

The shares give to their holders the right to vote at the NLB’s

meeting of shareholders where, as a rule, each share entitles

its holder to one vote. Nevertheless, a shareholder who

acquires shares which, together with the shares already held

by such shareholder or by a third person on behalf of such

shareholder, represent more than 25% of the NLB’s share

capital, may only exercise its voting rights under such shares

if NLB’s Supervisory Board approves such an acquisition.

The Supervisory Board’s approval may only be rejected if,

following such an acquisition, such a person would hold

shares representing more than 25% of NLB’s issued share

capital plus one share. The approval shall be considered

given if not expressly rejected in 20 days. No such approval

is necessary in respect of the shares acquired by a person

on behalf of third persons provided that such a person is

not entitled to exercise the voting rights arising out of such

shares at its own discretion and undertakes to NLB that it will

not exercise the voting rights based on voting instructions

unless such voting instructions are accompanied with a

confirmation that the person giving such instructions is the

beneficial owner of the shares in respect of which votes are

to be exercised and does not hold in the aggregate, directly

or indirectly 25% or more NLB shares with voting rights.

The shares also give their holders the right to be informed, as

well as the pre-emptive right to subscribe for new shares on a

pro rata basis in case of a share capital increase, the right to

a pro-rata share of remaining assets in case of bankruptcy or

liquidation or NLB and the right to receive a dividend. In 2021,

NLB paid dividends for previous year in the amount of 4.61 EUR

per share (2020: NLB did not pay out any dividends for previous

year), which decreased retained earnings for EUR 92,200

thousand.

As at 31 December 2021 and 31 December 2020, NLB holds

no own shares. In June 2019, the General Assembly of NLB

authorised the Management Board that in the period of 36

months from the adoption of the shareholders’ resolution, it

can buy own shares of the Bank for the payment of variable

remuneration to certain employees as required by the

Banking Act and other relevant regulations. NLB did not buy

any own shares based on this authorisation.

in EUR thousands

NLB GroupNLB

31 Dec 202131 Dec 202031 Dec 202131 Dec 2020

Financial assets measured at fair value through

other comprehensive income - debt securities

8,54038,85212,36527,242

Financial assets measured at fair value through other

comprehensive income - equity securities

2,8263,64499452

Actuarial defined benefit pension plans(5,488)(4,399)(3,696)(3,592)

Foreign currency translation(17,184)(17,724)--

Hedge of a net investment in a foreign operation754754--

Total(10,552)21,1278,76824,102

b)Accumulated other comprehensive income

5.21.

Accumulated other comprehensive income and reserves

a)Reserves

The share premium account as at 31 December 2021 and 31

December 2020 comprises paid-up premiums in the amount

of EUR 822,173 thousand and the revaluation of share capital

from previous years in the amount of EUR 49,205 thousand.

As at 31 December 2021 and 31 December 2020, profit reserves

in the amount of EUR 13,522 thousand relate entirely to legal

reserves in accordance with the Companies Act.

In 2021, NLB recorded a net profit in the amount of EUR 208,421

thousand (2020: net profit EUR 113,952 thousand) which is

included in the retained earnings as at 31 December2021.

![]()

271

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

5.22.

Capital adequacy ratios

in EUR thousands

NLB GroupNLB

31 Dec 202131 Dec 202031 Dec 202131 Dec 2020

Paid up capital instruments200,000200,000200,000200,000

Share premium871,378871,378871,378871,378

Retained earnings - from previous years767,152552,146249,845228,040

Profit eligible - from current year135,96863,63539,61321,658

Accumulated other comprehensive income(10,091)21,5888,76824,102

Other reserves13,52213,52213,52213,522

Minority interest27,90571,562--

Prudential filters: Additional Valuation Adjustments (AVA)(3,498)(3,632)(1,606)(1,755)

(-) Goodwill(3,529)(3,529)--

(-) Other intangible assets(39,116)(33,222)(18,829)(9,914)

(-) Insufficient coverage for non-performing exposures(90)-(10)-

COMMON EQUITYTIER 1 CAPITAL (CET1)1,959,6011,753,4481,362,6811,347,031

Minority interest5,95014,614--

Additional Tier 1 capital5,95014,614--

TIER 1 CAPITAL1,965,5511,768,0621,362,6811,347,031

Capital instruments and subordinated loans eligible as Tier 2 capital284,595284,595284,595284,595

Minority interest2,34412,806--

TIER 2 CAPITAL286,939297,401284,595284,595

TOTAL CAPITAL2,252,4902,065,4631,647,2761,631,626

RWA for credit risk10,205,17210,222,9235,411,4334,805,127

RWA for market risks1,206,3631,250,563698,463657,088

RWA for credit valuation adjustment risk11,85020011,850200

RWA for operational risk1,244,023947,342586,781566,385

TOTAL RISK EXPOSURE AMOUNT (RWA)12,667,40812,421,0286,708,5276,028,800

Common EquityTier 1 Ratio15.5%14.1%20.3%22.3%

Tier 1 Ratio15.5%14.2%20.3%22.3%

Total Capital Ratio17.8%16.6%24.6%27.1%

European banking capital legislation – CRD IV, is based on the

Basel III guidelines. The legislation defines three capital ratios

reflecting a different quality of capital:

•Common Equity Tier 1 ratio (ratio between common or CET1

capital and risk-weighted exposure amount or RWA), which

must be at least 4.5%;

•Tier 1 capital ratio (Tier 1 capital to RWA), which must be at

least 6%; and

•Total capital ratio (total capital to RWA), which must be at

least 8%.

In addition to the aforementioned ratios which form the

Pillar 1 requirement, NLB must meet other requirements

and recommendations that are imposed by the supervisory

institutions orby thelegislation:

•The Pillar 2 Requirement (SREP requirement): bank-specific,

obligatory requirement set by the supervisory institution

through the SREP process (together with the Pillar 1

requirement it represents the minimum total SREP capital

requirement – TSCR);

•The applicable combined buffer requirement (CBR): a

system of capital buffers to be added on top of TSCR –

breaching of the CBR is not a breach of capital requirement,

but triggers limitations in the payment of dividends and

other distributions from capital. Some of the buffers are

prescribed by law for all banks and some of them are bank-

specific, set by the supervisory institution (CBR and TSCR

together form the overall capital requirement – OCR);

•

Pillar 2 Capital Guidance: capital recommendation set

by the supervisory institution through the SREP process.

It is bank-specific and is a recommendation, and not

obligatory. Any non-compliance does not affect dividends

or other distributions from capital; however, it might lead to

intensified supervision and the imposition of measures to

re-establish a prudent level of capital (including preparation

of capital restoration plan).

![]()

272

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

NLB’s overallcapital requirementon the consolidated level

The Overall Capital Requirement (OCR) amounted to 14.25%

for NLB on the consolidated basis, consisting of:

•10.75% TSCR (8% Pillar 1 Requirement and 2.75% Pillar 2

Requirement); and

•3.5% CBR (2.5% Capital Conservation buffer, 1% O-SII buffer

and 0% Countercyclical buffer).

Pillar 2 Guidance (P2G) which should be comprised entirely of

CET1 capital, remains at a relatively low level 1.0%.

The Pillar 2 Requirement for 2022 decreased by 0.15 p.p. to

2.60%, as a result of better overall SREP assessment.

The capital adequacy of NLB and NLB Group at the end ofyear

2021 remains strong in accordance with risk appetite orientations,

at a level which covers all the current and announced regulatory

capital requirements, including capital buffers and other

currently known requirements, as well as the P2G.

As at 31 December 2021, NLB Group capital ratios on a

consolidated basis stand at:

•15.5% CET1 ratio,

•15.5% Tier 1 ratio,

•17.8% Total Capital ratio.

In the scope of regulatory risks, which include credit

risk, operational risk, and market risk, NLB Group uses a

standardised approach for credit and market risks, while

the calculation of capital requirement for operational risks

is made according to a basic indicator approach. The same

approaches are used for calculating the capital requirements

for NLB on a standalone basis, except for the calculation

of the capital requirement for operational risks where the

standardised approach is used.

As at 31 December 2021, theTotal Capital Ratio for NLB Group

stood at 17.8% (or 1.2 p.p. higher than at the end of 2020), and

SREP requirement2021

From 12 March

2020 onwards

As at 1 January

till 11 March 2020

CET14.5%4.5%4.5%

Pillar 1 (P1R)

AT1

1.5%1.5%1.5%

T22.0%2.0%2.0%

CET11.55%1.55%2.75%

Pillar 2 (P2R)Tier 12.06%2.06%2.75%

Total Capital2.75%2.75%2.75%

CET16.05%6.05%7.25%

Total SREP Capital Requirement (TSCR)Tier 18.06%8.06%8.75%

Total Capital10.75%10.75%10.75%

Combined buffer requirement (CBR)

Conservation bufferCET12.5%2.5%2.5%

O-SII bufferCET11.0%1.0%1.0%

Countercyclical bufferCET10.0%0.0%0.0%

CET19.55%9.55%10.75%

Overall capital requirement (OCR) = MDA thresholdTier 111.56%11.56%12.25%

Total Capital14.25%14.25%14.25%

Pillar 2 Guidance (P2G)CET11.0%1.0%1.0%

OCR + P2GCET110.55%10.55%11.75%

for NLB at 24.6% (or 2.5 p.p. lower than at the end of 2020). As at

31 December 2021, the CET1 ratio stood at 15.5% (1.4 p.p. higher

than at the end of 2020). The higher NLB Group total capital

adequacy compared to the end of 2020 derives from higher

capital (increase of EUR 187.0 million compared to 31December

2020) which compensated RWA increase of EUR 246.4 million

compared to 31 December 2020 for the Group. Higher RWA

derives mainly from the increase of RWA for operational risk.

Total capital increased mainly due to inclusion of Negative

goodwill in retained earnings in the amount of EUR 137.9 million

and partial inclusion of 2021 profit (EUR 136.0 million). The capital

calculation as at 31 December 2021 does not include part of the

2021 result in the amount of EUR 100.0 million. Therefore, there

will be no effect on the capital in case the dividends are paid.

The RWA for credit risk decreased by EUR 17.8 million compared

to 31 December 2020. On one hand, the factors for increase

were loan growth to the corporates and retail, new investments

in subordinated, state, and EU institutions bonds. On the

other hand, the increase was compensated by regulatory

changes, namely the inclusion of Bosnia and Herzegovina

and Macedonia on EBA’s third party equivalent list, legislation

criteria changes for the CRR collateral adequacy, signing

of agreements with MIGA as well as changed investment

policy such as the shift of some liquid assets from the central

governments to lower risk weighted counterparties (NLB Banka,

Prishtina, NLB Banka, Podgorica) or optimisation of deposits

with banks (Komercijalna banka, Beograd). Furthermore,

successful recovery of NPLclients, where the biggest part

represented repayments by a large client, contributed to

the RWA decrease, while in contrast, the RWA for high-risk

exposures is higher mainly due to new project finance loans.

The RWA for market risk decreased by EUR 32.6 million

compared to 31 December 2020 due to the lower fixed

income position in the trading book. And yet, RWA for FX risk

increased by EUR 35.3 million compared to 31 December 2020,

and RWA for CVA increased by EUR 10.7 million – of which

EUR 10.6 million as a result of new regulatory requirements

which became effective from June 2021 onward (calculation

of original exposure method (OEM) with residual maturity).

The increase in the RWA for operating risks (EUR 296.7 million

compared to 31 December 2020) derives from the higher

three-year average of relevant income, as defined in Article

316 of CRR, which represents the basis for the calculation.

The main reason for increased relevant income was the

acquisition of Komercijalna banka Beograd in 2020.

![]()

273

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

The most important goal of internal capital adequacy assessment

process (ICAAP) in NLB Group, set up in accordance with ECB

Guidelines, is ensuring adequate capital and sustainability on

an ongoing basis. The purpose of this process is to have in place

sound, effective, and comprehensive strategies and processes

to assess and maintain capital on an ongoing basis, as well the

adequate distribution of internal capital for covering the nature

and level of the risks to which NLB Group is or might be exposed.

In addition, NLB Group gives strong emphasis on its integration

into the overall risk management system in order to assure

proactive support for informed decision-making.

From an economic perspective, NLB Group manages its

capital adequacy by ensuring that all its risks are adequately

covered by internal capital. A normative perspective is a

multiyear forward-looking assessment of NLB Group which

shows its ability to fulfil all of its capital-related regulatory

and supervisory requirements and risk appetite of NLB

Fee income from issued non-financial guarantees amounted to

EUR 7,578 thousand (2020: EUR 4,910 thousand) in NLB Group,

and to EUR 4,547 thousand (2020: EUR 4,397 thousand) in NLB.

In addition to the instruments presented in the table above,

NLB Group and NLB have also some low-risk off-balance

sheet items, for which 0% credit conversion factor is applied

in EUR thousands

NLB GroupNLB

31 Dec 202131 Dec 202031 Dec 202131 Dec 2020

Short-term guarantees258,975222,440112,758122,136

- financial

139,732119,30963,18861,322

- non-financial

119,243103,13149,57060,814

Long-term guarantees977,759904,002614,343567,532

- financial

393,901359,787226,747196,681

- non-financial

583,858544,215387,596370,851

Loan commitments1,878,9881,816,4411,259,4891,306,791

Letters of credit35,61521,7941,9502,256

Other13,16710,2931,0375,865

3,164,5042,974,9701,989,5772,004,580

Provisions (note 5.16.b)(33,441)(42,174)(20,560)(28,543)

Total3,131,0632,932,7961,969,0171,976,037

in accordance with the Capital Requirements Regulation

(credit and other lines which can be irrevocably cancelled by

a bank). As at 31 December 2021 these items at the NLB Group

level amount to EUR 372,403 thousand (31 December 2020:

EUR 307,093 thousand), and at the NLB level EUR 302,063

thousand (31 December 2020: EUR 236,542 thousand).

5.23.Off-balance sheet liabilities

a) Contractual amounts of off-balance sheet financial instruments

Group. Within these capital constraints, NLB Group defines its

management buffers in the Risk appetite above the regulatory

and supervisory requirement and internal capital needs that

allow it to sustainably follow its business strategy. A normative

perspective includes several stress scenarios which are

integrated into NLB Group’s annual business plan review and

budgeting process.

![]()

274

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

b)Analysis of derivative financial instruments bynotional amounts

The notional amounts of derivative financial instruments that

qualify for hedge accounting at NLB Group and NLB amount

to EUR 572,455 thousand (31 December 2020: EUR 573,753

thousand) (note 5.5.b). Derivatives that qualify for hedge

accounting are used to hedge interest rate risk.

in EUR thousands

NLB GroupNLB

31 Dec 202131 Dec 202031 Dec 202131 Dec 2020

Capital commitments for purchase of:

- property and equipment1,6962,4331,6232,429

- intangible assets4,2439,5664,0949,403

Total5,93911,9995,71711,832

in EUR thousands

NLB GroupNLB

31 Dec 202131 Dec 202031 Dec 202131 Dec 2020

Short-termLong-termShort-termLong-termShort-termLong-termShort-termLong-term

Swaps99,3491,284,83299,4201,425,765109,1371,284,83278,4131,425,765

- currency swaps

99,34916,84499,4206,068109,13716,84478,4136,068

- interest rate swaps

-1,267,988-1,419,697-1,267,988-1,419,697

Options9,88030,94512,81127,0009,88030,94512,81127,000

- interest rate options

-30,945-27,000-30,945-27,000

- securities options

9,880-12,811-9,880-12,811-

Forward contracts38,82526,92191,30941,42337,51126,92193,84641,423

- currency forward

38,82526,92191,30941,42337,51126,92193,84641,423

Total148,0541,342,698203,5401,494,188156,5281,342,698185,0701,494,188

1,490,7521,697,7281,499,2261,679,258

The fair values of derivative financial instruments are

disclosed in notes 5.2. and 5.5.

c)Capital commitments

![]()

275

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

5.24.Funds managed on behalf of third parties

Funds managed on behalf of third parties are accounted

separately from NLB Group’s funds. Income and expenses

arising with respect to these funds are charged to the

Fiduciary activities

in EUR thousands

NLB GroupNLB

31 Dec 202131 Dec 202031 Dec 202131 Dec 2020

Fiduciary activities26,165,58025,713,79924,806,89424,466,910

Settlement and other services1,079,500971,600977,197907,132

Total27,245,08026,685,39925,784,09125,374,042

in EUR thousands

NLB GroupNLB

31 Dec 202131 Dec 202031 Dec 202131 Dec 2020

Assets

Clearing or transaction account claims for client assets26,071,58925,633,70624,741,05224,396,203

- from financial instruments26,024,70025,630,24424,694,27524,392,773

- receipt, processing, and execution of orders

10,085,4099,194,5399,346,0028,502,331

- management of financial instruments portfolio

588,761528,206--

- custody services

15,350,53015,907,49915,348,27315,890,442

- to Central Securities Clearing Corporation or bank

settlement account for sold financial instrument

180496817

- to other settlement systems and institutions for

bought financial instrument (debtors)

46,7093,41346,7093,413

Clients' money94,93480,09465,84270,707

- at settlement account for client assets75,15142,02946,05932,642

- at bank transaction accounts19,78338,06519,78338,065

Liabilities

Clearing or transaction liabilities for client assets26,165,58025,713,79924,806,89424,466,910

- to client from cash and financial instruments26,129,50325,707,58124,797,05724,461,033

- receipt, processing, and execution of orders

10,110,1249,230,4069,371,7078,538,198

- management of financial instruments portfolio

591,772537,283--

- custody services

15,427,60715,939,89215,425,35015,922,835

- to Central Securities Clearing Corporation or bank

settlement account for bought financial instrument

3,8657213472

- to other settlement systems and institutions for

bought financial instrument (creditors)

31,8255,7559,3165,414

- to bank or settlement bank account for fees and costs, etc.

387

391

387

391

respective fund, and no liability falls on NLB Group in

connection with these transactions. NLB Group charges fees

for its services.

Funds managed on behalf of thirdparties

![]()

276

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Fee income for funds managed on behalf of third parties

Risk management function acts as a second line of defence.

Set governance and different risk management tools enable

adequate oversight of the Group’s risk profile. Moreover,

they support business operations and enable efficient risk

management by incorporating escalation procedures and

different mitigation measures when necessary.

a)Risk management strategies and processes

The key goal of NLB Group’s Risk Management is to

proactively manage, assess, and monitor risks within the

Group. Sound and holistic understanding of risk management

is embedded into the entire organisation, focusing on risk

identification at a very early stage, efficient risk management,

and mitigation of them with the aim of ensuring the prudent

use of its capital and adequate liquidity structure to support

the financial resilience of the Group.

Key strategic risk management principles of NLB Group are

defined by its Risk Appetite and Risk Strategy, designed in

accordance with the Group’s business model, integrating

forward-looking perspective. The Strategy of NLB Group,

the Risk Appetite, Risk Strategy, and the key internal policies

of NLB Group – which are approved by the Management

and Supervisory Boards – specify the strategic goals, risk

appetite guidelines, approaches, and methodologies for

monitoring, measuring, and managing all types of risk

in order to meet internal strategic objectives and fulfil all

external requirements. The main strategic risk guidelines are

comprehensively integratedinto decision-making, including

the business plan review and budgeting process.

NLB Group plans a prudent risk profile and optimal capital

usage, representing an important element of its business

strategy and related mid-term financial targets. The

management of credit risk, which is the most important risk

category in NLB Group, concentrates on taking moderate

risks – a diversified credit portfolio, adequate credit portfolio

quality, the sustainable costs of risk, and ensuring an optimal

return considering the risks assumed. As regards liquidity risk,

the tolerance is low, while the activities are geared towards

ensuring an adequate liquidity position on an ongoing basis.

The Group limited exposure to credit spread risk, arising

from the valuation risk of debt securities portfolio servicing

as liquidity reserves, to moderate level. The fundamental

orientation in the management of interest rate risk is to

limit unexpected negative effects on revenues and capital,

therefore, a moderate tolerance for this risk is stated. When

assuming operational risk, theGroup pursues theorientation

that such a risk must not significantly impact its operations.

On this basis, changes of control activities, processes, and/

or organisation are performed. Besides the Group also

focuseson proactive mitigation, prevention, andminimisation

of potential damage. The conclusion of transactions with

derivative financial instruments at NLB is primarily limited to

servicing customers and hedging Bank’s own positions. In

the area of currency risk, NLB Group pursues the goals of low

to moderate exposure. The tolerance for other risk types is

low and focuses on minimising their possible impacts on NLB

Group’sentireoperations.

Environmental, social, and governance (ESG) risks do not

represent a new risk category, but rather an aggravating

factor for the types of risks, not least credit and operational

risk. The Group integrates and manages them within the

established risk management framework. The management

of ESG risks follows ECB and EBA guidelines with the

tendency to comprehensively integrate them into all relevant

processes. The availability of ESG data in the region where

NLB Group operates is still lacking. Nevertheless, the Group

strives to obtain relevant clients’ data as prerequisite for

adequate decision-making and the corresponding proactive

management of ESG risks.

Risk management focuses on managing and mitigating risks

in line with the Group’s Risk Appetite and Risk Strategy. Within

these frameworks, the Group monitors a range of risk metrics,

including internal capital allocation, in order to assure Group’s

risk profile is in line with its risk appetite. The usage of risk

limits and potential deviations from limits and target values

are regularly reported to the respective committees and/or

the Management Board of the Bank. The banking subsidiaries

within NLB Group adapted a corresponding approach to

monitor and manage their target risk profiles.

in EUR thousands

NLB GroupNLB

2021202020212020

Fiduciary activities (note 4.3.b)11,3859,8128,9118,494

Settlement and other services1,5679251,552864

Total12,95210,73710,4639,358

6.

Riskmanagement

Risk management in NLB Group is implemented in accordance

with the set strategic guidelines, established internal policies,

and procedures which take into account European banking

regulations, the regulations adopted by the Bank of Slovenia,

the current EBA guidelines, and relevant good banking

practices. In addition, the Group is constantly enhancing and

complementing the existing approaches, methodologies, and

processes in all risk management segments with the aim to

proactivelysupport decision-making.

Managing risks and capital efficiently is crucial for NLB

Group sustained long-term profitable operations. Robust Risk

Management framework is comprehensively integrated into

decision-making, steering, and mitigation processes within the

Group. NLB Group gives high importance to the risk culture and

awareness of all relevant risks within the entire Group.

NLB Group’s Risk management framework supports

business decision-making on strategic and operating levels,

comprehensive steering, proactive risk management, and

mitigation byincorporating:

•

risk appetite statement and risk strategy orientations;

•yearly review of strategic business goals, budgeting, and

capital planning process;

•internal capital adequacy assessment process (ICAAP) and

internal liquidity adequacy assessment process (ILAAP);

•

recovery plan activities;

•

other internal stress-testing capabilities, early warning

systems, and regular risk analysis;

•

regulatory and internal management reporting.

NLB Group uses the ‘three lines of defence framework’ as an

important element of its internal governance, wherebythe

![]()

277

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

NLB Group established a comprehensive stress-testing framework

and other early warning systems in different risk areas with the

intention to strengthen the existing internal controls and timely

response when necessary. Robust and uniform stress-testing

programme includes all material types of risk and relevant stress

scenario analysis, according to the vulnerability of the Group’s

business model. In 2021, the Group established own ESG stress

testing concept to identify most relevant financial vulnerabilities

stemming from climate risk. Stress-testing is integrated into the risk

appetite, ICAAP, ILAAP, Recovery Plan, and budgeting process to

support proactive management of the Group’s risk profile, namely

the capital and liquidity positions in a forward-looking perspective.

In addition, the Group also performs reverse stress tests with

the aim to test its maximum recovery capacity. Other partial risk

assessments are covered by other risk analysis, based on relevant

risk parameters, and integrated into the process of setting a risk

management limit system.

For the purpose of an efficient risk mitigation process,

NLB Group applies a single set of standards to retail and

corporate loan collateral, representing a secondary source

of repayment with the aim of efficient credit risk management

and optimal capital consumption. The Group has a system

for monitoring and reporting collateral at fair (market) value

in accordance with theInternationalValuation Standards

(IVS). The eligibility of collateral, by types and ratios referring

to prudent lending criteria, is set within internal lending

guidelines. Credit risk mitigation principles and rules in NLB

Group are described in more relevant details in the section

‘Credit risk management.’ When hedging market risks, namely

interest rate risk and foreign exchange risk, in line with the set

risk appetite, NLB Group follows the principle of natural hedge

or using derivatives in line with hedge accounting principles.

b)Risk management structure and organisation

NLB Group’s corporate governance framework is based

on the principles of sound and responsible governance, in

accordance with the applicable legislation of the Republic

of Slovenia, particularly the provisions of the Companies Act

(ZGD-1) and the Banking Act (ZBan-3), Regulation on Internal

Governance Arrangements, the Management Body, and the

Internal Capital Adequacy Assessment Process for Banks and

Savings Banks, the EBA Guidelines on internal governance,

the EBA Guidelines on the assessment of the suitability of

members of the management body, and key function holders,

as well as the EBA Guidelines on remuneration practices.

Several layers of management provide cohesive risk

management governance in NLBGroup.

NLB Group established three lines of a defence framework

with the aim of managing risks effectively. The three lines of

defence concept provides a clear division of activities and

defines roles and responsibilities for risk management at

different levels within the Group. Risk management in the

Group acts as a second line of defence, accountable for

appropriate managing, assessing, monitoring, and reporting

of risks in the Bank as the main entity in Slovenia, and as the

competence centre in charge of seven banking members and

other non-core subsidiaries which are in a controlled wind-

out.

Overall, the organisation and delineation of competencies

in NLB Group’s risk management structure is designed

to prevent conflicts of interest and ensure a transparent

and documented decision-making process, subject to an

appropriate upward and downward flow of information.

Risk management in NLB Group is managed within the

Risk management competence line, which is a specialised

competence line encompassing several professional areas

for which the Global Risk Department, the Credit Risk –

Corporate Department, the Credit Risk – Retail Department

and theEvaluationand Control Department are responsible

within NLB, and which reports to the Assets and Liabilities

Committee (ALCO) of the Management Board and the Risk

Committee of the Supervisory Board. The risk management

competence line is in charge of formulating and controlling

the risk management policies of NLB Group, setting limits,

establishing methodologies, overseeing the harmonisation of

risk management policies within the NLB Group, monitoring

NLB Group’s risk exposures, and preparing external and

internal reports.

All members of NLB Group that are included in the financial

statements of NLB Group, report their exposure to risks to the

competent organisational units within the Risk management

competence line. These organisational units then report

all relevant risk information to the Assets and Liabilities

Committee (ALCO) of the Management Board and the Risk

Committee of the Supervisory Board, which is where the

Management Board and the Supervisory Board, adopt

appropriate measures.

The credit ratings of clients that are materially important

to NLB Group and the issuing of credit risk opinions are

centralised via the Credit Committee of NLB. The process

follows the co-decision principle, in which the credit

committee of the respective Group member first approves

their decision, following which the Credit Committee of NLB

gives their opinion. The resolution of the Credit Committee

of NLB is made on the basis of all available documentation,

including a non-binding rating opinion prepared by the

underwriting department of NLB. This same principle and

process is set also for the issuing of credit exposures for the

materially important clients of NLB Group.

Risk monitoring in NLB Group members is operating within

an independent and/or separate organisational unit. This

way, monitoring of risks is established based on standardised

and systemic risk management approaches. This monitoring

enables a comprehensive overview of the Group’s and of each

member’s statement of financial position. In compliance with

the risk appetite, risk management strategy and policies of

NLB Group, risk monitoring in each NLB Group member is

separated from its management and/or business function to

maintain the objectivity required when assessing business

decisions. The organisational unit for managing risks directly

reports to the Management Board and its committees (Credit

Committee, ALCO and the Operational Risk Committee), which

report to the Supervisory Board (the Risk Committee of the

Supervisory Board or Board of Directors).

c)Risk measurement and reporting systems

As a systemic banking group, NLB Group is subject to the

Single Supervisory Mechanism (SSM), which is supervised

by the Joint Supervisory Team (JST) of the ECB and the

Bank of Slovenia. The Group member complies with the ECB

regulation, while NLB Group subsidiaries operating outside

Slovenia are also compliant with the rules set by the local

regulators. A third-party equivalent was approved in Serbia,

Bosnia and Herzegovina, and North Macedonia, resulting in

alignment of local regulation with CRR rules. With regards to

capital adequacy, based on the provisions of the Directive

(CRD), Decision (CRR), NLB Group applies a standardised

approach to credit and market risk, and the basic approach

(a simplified approach with less data granularity) to

operational risks, with the exception of NLB which applies the

standardised approach.

Across the Group, risks are assessed, monitored, managed,

or mitigated in a uniform manner, as defined in the Group’s

Risk management standards, considering also the specifics

of the markets in which individual NLB Group members

operate. For the purposes of measuring exposure to credit

risk, liquidity risk, interest rate, and credit spread risk in

the banking book, operational risk, market risk, and non-

![]()

278

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

financial risks, in addition to the prescribed regulations, NLB

Group uses internal methodologies and approaches that

enable more detailed monitoring and management of risks.

These internal methodologies are aligned with ECB, EBA,

and Basel guidelines, as well as best practices in banking

methodologies.

As for risk reporting, NLB Group’s internal guidelines reflect,

in addition to internal requirements, the substance and

frequency of reporting required by the Bank of Slovenia

and the ECB. In addition, each member of NLB Group also

complies with the requirements of its local regulations.

Risk reporting is carried out in the form of standardised

reports, pursuant to risk management policies based on

common methodologies for measuring exposure to risks,

uniform database structure within Data Warehouse (DWH),

comprehensive data quality assurance, and automated

report preparation, which ensures the quality of reports and

reduces the possibility of errors.

d) Data and IT system

Risk data are calculated and stored in NLB Group DWH,

collected from NLB and other Group member’s DWH. The

established process provides an integrated information

in common reference structure where business users can

access in a consistent and subject-oriented format. Data are

regularly checked and validated. Data used for internal risk

assessment, management, and reporting are the same as

data which NLB Group uses for regulatory reporting.

e) Main emphasis of risk management in 2021

Efficient managing of risks and capital remains crucial

for NLB Group to sustain long-term profitable operations.

The Group further enhanced the robustness of its risk

management system in all respective risk categories in

order tomanage them proactively, comprehensively,

and prudently. Risk identification in a very early stage,

its efficient managing, and the corresponding mitigation

processes represent essential steps in such a system. The

business and operating environment relevant for NLB Group

operations is changing with trends, such as: changing

customer behaviours, emerging new technologies and

competitors, sustainable financing, actively contributing to

a more balanced and inclusive economic and social system,

and increasing new regulatory requirements. Respectfully,

the risk management framework is regularly adapted

with the aim of detecting and managing new potential

emergingrisks.

The NLB Group gives special focus on the inclusion of risk

analysis into the decision-making process on strategic and

operating levels, diversification in order to avoid a large

concentration, optimal usage of internal capital, appropriate

risk-adjusted pricing, regular education/trainings at all levels

of management, and the assurance of overall compliance with

internal policies/rules and relevant regulations.

COVID-19 did not have a meaningful impact on the quality of

the credit portfolio. NLB Group is compliant with EBA guidelines

on payment moratoria and is very prudent in identifying any

increase in credit risk.The vast schemes introduced by the

governments in the Group countries providing moratoriums

to eligible clients as part of the COVID-19 pandemic measures

had been phasing out during the 2021. Though COVID-19

coupled with its implications on the business environment the

Group faced growing excess liquidity and managed to stay well

capitalised. Besides, the Group has taken necessary measures

to protect its customers and employees by ensuring the relevant

safety conditions and making sure that the services offered by

the Group are provided without any disruption.

NLB Group is engaged in contributing to sustainable finance

by incorporating environmental, social, and governance

(ESG) risks into its business strategies, risk management

framework, and internal governance arrangements. With the

adoption of the NLB Group Sustainability programme, NLB

Group implemented sustainability elements into its business

model. Thus, sustainable finance integrates ESG criteria into

the Group’s business and investment decisions for the lasting

benefit of the Group’s clients and society. The NLB Group

Sustainability Committee oversees the integration of the ESG

factors to the NLB Group business model. The management

of ESG risks addresses the NLB Group’s overall credit

approval process and relatedcredit portfoliomanagement.

It follows ECB and EBA guidelines with a tendency of their

comprehensive integration into all relevant processes. The

availability of ESG data in the region where NLB Group

operates is still lacking, nevertheless, the NLB Group strives

to obtain relevant clients’ data as prerequisite for adequate

decision-making. In addition, the NLB Group carefully

considers potential reputation and liability risks which could

arise from sustainable financing of its clients.

6.1.

Credit risk management

a) Introduction

In its operations, NLB Group is exposed to credit risk, or

the risk of losses due to the failure of a debtor to settle its

liabilities to NLB Group. For that reason, it proactively and

comprehensively monitors and assesses the aforementioned

risk. In that process, NLB Group follows the International

Financial Reporting Standards, regulations issued by the

European Central Bank or Bank of Slovenia, and the EBA

guidelines. This area is governed in greater detail by the

internal methodologies and procedures set out in internal

acts.

Through regular reviews of the business practices and the

credit portfolios of NLB entities, NLB ensures that the credit

risk management of those entities function in accordance

with NLB Group’s risk management standards to enable

meaningfully uniform procedures atthe consolidated level.

NLB Group manages credit risk at two levels:

•At the level of the individual customer/group of customers

appropriate procedures are followed in various phases of

the relationship with a customer prior to, during, and after

the conclusion of an agreement. Prior to concluding an

agreement, a customer’s performance, financial position,

and past cooperation with NLB are assessed. To objectively

assess a client’s operation, internal scoring models for

particular client segments or product types have been

developed. It is also important to secure high-quality

collateral even though it does not affect a customer’s credit

rating. This is followed by various forms of monitoring

a customer, in particular an assessment of its ability to

generate sufficient cash flows for the regular settlement of

its liabilities and contractual obligations. In this part of the

credit process, regular monitoring of clients within the Early

Warning System (EWS) is important. In the case of client

default, restructuring or work-out is initiated depending on

the severity of the client’s position.

•The quality and trends in the credit portfolio, including

on-balance and off-balance sheet exposures, are actively

monitored and analysed at the level of the overall portfolio

of NLB Group and single banking entities.

Comprehensive analyses are regularly performed to assure

monitoring of the portfolio quality through time and to

identify any breach of limits or targets. Great emphasis is

placed on the evolution of portfolio structure in terms of client

segmentation, credit rating structure, structure by stages

(based on IFRS 9), and NPL ratios. Furthermore, the coverage

of NPL is an important indicator of potential future losses that

is closely monitored.

![]()

279

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Apart from analysing the portfolio as a whole, vintage

analysis is used to monitor the quality of new loans production

and test the conservativity of the lending standards, which

should ensure the portfolio quality is maintained within the

Group Risk Appetite.

Apart from default risk, the portfolio management is

also focused on monitoring single name and industry

concentration, migration, and FX lending risk. Increasing

emphasis is also placed on stress tests that forecast the

effects of negative macroeconomic movements on the

portfolio, on the level of impairments and provisions, and on

capital adequacy. Capital requirements for credit risk at NLB

Group level within the first pillar are calculated according to

the Standardised approach, while within the second pillar an

internal IRB approach is used to estimate the RWA for default,

migration, and FX lending risk. In addition, a single name

concentration add-on is based on the Granularity adjustment

methodology and an industry concentration add-on is

estimated basedon the HHI concentration indexes.

NLB and other NLB Group members assess the level of credit

risk losses on an individual basis for material claims, and at

the collective level for the rest of the portfolio.

An individual review is performed for material Stage 3

financial assets which have been rated as non-performing

based on the information regarding significant financial

problems encountered by a customer, regarding actual

breaches of contractual obligations such as arrears in

the settlement of liabilities, whether financial assets will

be restructured for economic or legal reasons, and the

likelihood that a customer will enter bankruptcy or a financial

reorganisation. Expected future cash flows (from ordinary

operations and possible redemption of collateral) are

assessed following an individual review. If their discounted

value differs from the book value of the financial asset in

question, impairment must be recognised.

Collective ECL allowances are made for the remainder of

the portfolio, which is not assessed on an individual basis.

Based on IFRS 9 requirements, financial assets measured at

amortised cost or at fair value through other comprehensive

income are attributed to the appropriate stage based on the

estimated increase of credit risk of a single exposure since

initial recognition. The stage of financial assets determines

whether a 12-month or lifetime ECL must be considered. The

ECL calculation is based on the forward-looking probability

of default (PD) and loss given default (LGD), which are

calculated using historic data and statistical modelling, as

well as predicted macroeconomic parameters for different

scenarios. For off-balance financial assets, the probability of

the redemption of guarantees is considered when creating

collective provisions. The models used to estimate future risk

parameters are validated and back-tested on a regular basis

to make loss estimations as realistic as possible.

The management of ESG risks addresses the Group’s

overall credit approvalprocess and relatedcredit portfolio

management. Sustainable financing is implemented through

amended documentary framework:

•Lending Policy for Non-Financial Companies in NLB d.d. and

NLB Group where in special Chapter Environmental and

Social Framework three categories are defined (prohibited,

restricted, normal activities)

•Policy Environmental and Social Transaction Framework in

NLB d.d. and NLB Group applies to certain transactions with

greatest potential for significant E&S impact (exclusion list,

regulatory compliance check, category A list).

•Methodology Environmental and Social Transaction

Categorisation Methodology Framework in NLB d.d. and

NLB Group that provides a guide to the typical level of

inherent environmental and social risk according to NACE

codes.

Beside addressing ESG risks in all relevant stages of the

credit-granting process relevant ESG criteria were considered

also in the collateral evaluation process. On portfolio level the

Group does not face any large concentration towards specific

NACE industrial sectors exposed to climate risk, whereby the

role of transitional risk is more prevailing. The availability

of ESG data in the region where NLB Group operates is still

lacking, nevertheless the Group strives toobtain relevant

clients’ data as prerequisite for adequate decision-making.

b) Main emphasis in 2021

In the process of constantly complementing and enhancing

credit risk management, NLB Group focuses on taking

moderate risks, and at the same time ensuring an optimal

return considering the risks assumed. Preserving high credit

portfolio quality represents the most important key aim,

with a focus on the quality of new placements leading to

a diversified portfolio of customers. The Group is actively

present on the market in the region, financing existing and

new creditworthy clients. To further enhance existing risk

management tools, the Group is constantly developing a wide

range of advanced approaches supported by mathematical

and statistical models in credit risk assessment in line with

best banking practises, while at the same time enabling faster

responsiveness towards clients.

Lending growth in the corporate segment remained relatively

moderate, while the SME and retail segment experienced a

considerable growth in 2021 after a temporary slowdown in

2020 due to COVID-19 circumstances. After the acquisition

of Komercijalna banka as at 30 December 2020, the Bank

worked actively on harmonisation of risk management

methodologies with the NLB Group. Credit portfolio remains

well-diversified, there is no large concentration in any specific

industry or client segment. The share of retail portfolio in the

whole credit portfolio is quite substantial with still prevailing

segment of mortgage loans.

COVID-19 did not have a meaningful impact on the quality

of the credit portfolio. The vast schemes introduced by the

governments in theGroup countries providingmoratoriums

to eligible clients as part of the COVID-19 pandemic measures

had been phasing out during the 2021.

In addition to moratoria, the governments in Serbia and

Slovenia provided public guarantee schemes for new

financing of clients whose business has been materially

impacted due to the COVID-19 pandemic; none of the

guarantees have been exercised.

In 2021, the Group’s credit portfolio quality remained solid

with a stable rating structure and diversified portfolio. Great

emphasis was placed on intensive and proactive handling

of problematic customers and early warning system for

detecting increased credit risk at a very early stage. The

stock of NPE volume decreased, as a result of active workout

management. As at 31 December 2021, the share of non-

performing exposure by EBA methodology in NLB Group was

1.7% (2.8% at the end of 2020). Moreover, the coverage ratio

remains high at 57.9%, which is well above the EU average

published by the EBA (45.1% in 3Q 2021).

![]()

280

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

c) Maximum exposure to credit risk

in EUR thousands

NLB GroupNLB

31 Dec 202131 Dec 202031 Dec 202131 Dec 2020

Cash. cash balances at central banks.

and other demand deposits at banks

5,005,0523,961,8123,250,4372,261,533

Financial assets held for trading7,67884,8557,68218,831

Non-trading financial assets mandatorily

at fair value through profit or loss

4,26127,2337,88830.935

Financial assets at fair value through

other comprehensive income

3,395,2613,446,4911,541,0421,671,204

Financial assets at amortised cost

Debt securities1,717,6261,503,0871,436,4241,277,880

Loans to governments281,010368,400143,864170,742

Loans to banks140,683197,005199,287158,320

Loans to financial organisations141,709158,871226,144177,198

Loans to individuals5,519,2904,933,0932,656,9352,377,770

Loans to other customers4,645,1124,159,4962,118,2101,838,468

Other financial assets122,229113,13892,40454,503

Derivatives - hedge accounting568-568-

Total net financial assets20,980,47918,953,48111,680,88510,037,384

Guarantees1,236,7341,126,442727,101689,668

Financial guarantees

533,633479,096289,935258,003

Non-financial guarantees

703,101647,346437,166431,665

Loan commitments1,878,9881,816,4411,259,4891,306,791

Other potential liabilities48,78232,0872,9878,121

Total contingent liabilities3,164,5042,974,9701,989,5772,004,580

Total maximum exposure to credit risk24,144,98321,928,45113,670,46212,041,964

Maximum exposure to credit risk is a presentation of NLB

Group’s exposure to credit risk separately by individual types

of financial assets and contingent liabilities. Exposures stated

in the above table are shown for the balance sheet items in

their net book value as reported in the statement of financial

position, and for off-balance sheet items in the amount of their

nominal value.

![]()

281

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

d) Collateral from financial assets that are credit-impaired

in EUR thousands

31 Dec 2021NLB Group

Fully/over collateralised financial assets

Financial assets not or not fully covered

with collateral

Net value of

financial assets

Fair value of

collateral

Net value of

financial assets

Fair value of

collateral

Financial assets at amortised cost

Loans to individuals32,372122,20518,7187,645

Loans to other customers79,120446,30823,36423,694

Other financial assets1276,6612,09832

Total111,619575,17444,18031,371

in EUR thousands

31 Dec 2020NLB Group

Fully/over collateralised financial assets

Financial assets not or not fully covered

with collateral

Net value of

financial assets

Fair value of

collateral

Net value of

financial assets

Fair value of

collateral

Financial assets at amortised cost

Loans to individuals33,375132,53220,8225,922

Loans to other customers78,426532,99045,16155,545

Other financial assets1492,3381,47889

Total111,950667,86067,46161,556

in EUR thousands

31 Dec 2021NLB

Fully/over collateralised financial assets

Financial assets not or not fully covered

with collateral

Net value of

financial assets

Fair value of

collateral

Net value of

financial assets

Fair value of

collateral

Financial assets at amortised cost

Loans to individuals17,78549,5188,1143,924

Loans to other customers21,490117,8624,0374,478

Other financial assets6408225

Total39,281167,78812,1738,407

in EUR thousands

31 Dec 2020NLB

Fully/over collateralised financial assets

Financial assets not or not fully covered

with collateral

Net value of

financial assets

Fair value of collateral

Net value of

financial assets

Fair value of collateral

Financial assets at amortised cost

Loans to individuals17,35945,75611,4312,672

Loans to other customers30,058116,0736,08120,757

Other financial assets74487044

Total47,424162,27717,58223,473

![]()

282

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

e)Collateral from loans mandatorily at fair value throughprofit or loss

in EUR thousands

NLB Group

Fully/over collateralised loans

31 Dec 202131 Dec 2020

Net value of

loans

Fair value of

collateral

Net value of

loans

Fair value of

collateral

Loans mandatorily at fair value through profit or loss--25,07647,725

in EUR thousands

31 Dec 2021NLB

Fully/over collateralised loans

Loans not or not fully covered with

collateral

Net value of

loans

Fair value of

collateral

Net value of

loans

Fair value of

collateral

Loans mandatorily at fair value through profit or loss4,1984,5003,6902,050

in EUR thousands

31 Dec 2020NLB

Fully/over collateralised loans

Loans not or not fully covered with

collateral

Net value of

loans

Fair value of

collateral

Net value of

loans

Fair value of

collateral

Loans mandatorily at fair value through profit or loss22,98943,6207,9461,787

f) Credit protection policy

NLB Group applies a single set of standards to retail and

corporate loan collateral, as developed by NLB Group

members in accordance with regulatory requirements. The

master document regulating loan collateral in the NLB Group

is the Loan Collateral Policy in NLB d.d. and NLB Group. The

Policy has been adopted by the Management Board of NLB

Group. The Policy represents the basic principles that NLB

Group’s employees must take into account when signing,

evaluating, monitoring, and reporting collateral, with the aim

of reducing credit risk.

In line with the policy, the primary source of loan repayment

is the debtor’s solvency, and the accepted collateral is a

secondary source of repayment in case the debtor ceases to

repaythe contractualobligations.

NLB Group primarily accepts collateral complying with

the Basel II requirements with the aim of improving credit

risk management and consuming capital economically. In

accordance with Basel II, collateral may consist of pledged

deposits, government guarantees, bank guarantees, debt

securities issued by central governments and central banks,

bank debt securities, and real-estate mortgages (the real

estate must be, beside other criteria, located in the European

Economic Area or in country recognised in EBA’s third party

equivalent list for the effect on capital to be recognised).

Loans made to companies and sole proprietors may be

secured by other forms of collateral, as well (e.g., a lien on

movable property, a pledge of an equity stake, investment

coupons, collateral by pledged/assigned receivables, etc.) if it

is assessed that the collateral could generate a cash flow if it

were needed as a secondary source of payment. If there is of

a lower probability that this type of collateral would generate

a cash flow, NLB Group takes a conservative approach and

accepts the collateral while reporting its value as zero.

g)The processes for valuing collateral

In compliance with relevant regulations, NLB Group has

established a system for monitoring and reporting collateral

at fair (market) value.

The market value of real estate used as collateral is obtained

from valuation reports of licensed appraisers. The market

value of movable property is obtained from valuation reports

of licensed appraisers or from sales agreements. Both,

valuation reports and sales agreements must not be older

than one year. In NLB and members of NLB Group, most

![]()

283

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

reports of external real estate appraisers are controlled.

Controls are performed by internal appraisers. The subject of

control is the content, value, scope, and format of the report,

its compliance with international valuation standards, and

the estimatedvalue.If theynoticedeviations, theyestimate

needed correction of the value of the external valuation (in

%) and correct the value of the external valuation. The value

adjustment can only be negative and can be applied only in

a limited range. For the purposes of business decisions and

the calculation of the necessary impairments and provisions,

additional deductions (haircuts) are applied to the eventual

adjusted market value, depending on the type of collateral.

These haircuts for purpose of liquidation value arefor real

estate in the range of 30 to 70%, depending on the type of real

estate and location, and for movables they range between 50

and 100%, depending on the type of movable.

The market value of financial instruments held by NLB Group

is obtained from the organised market – such as the stock

exchange, for listed financial instruments or determined

in accordance with the internal methodology for unlisted

financial instruments (such collateral is used exceptionally

and on a small scale in loans granted to companies and sole

proprietors).

NLB has compiled a reference list of licensed real estate

appraisers for real estate. All appraisals must be made for

the purpose of secured lending and in accordance with

the international valuation standards (IVS, EVS, and RICS).

Appraisals related to retail loans are generally ordered only

from appraisers with whom the NLB has a contract for real-

estate valuations. For corporate loans, appraisals are usually

submitted by clients. If a client submits an appraisal that is

not made by an appraiser included on the NLB’s reference

list, the NLB’s expert department which employs certified real

estate appraisers in construction with licences granted by the

Slovenian Ministry of Justice, and certified real-estate value

appraisers with licences granted by the Slovenian Institute of

Auditors, will verify the appraisal. The expert department is

also responsible for reviewing valuations of real estate serving

as collateral for large loans.

Other NLB Group members obtain valuations from in-house

appraisers and outsourced appraisers, all possessing the

necessary licences. NLB Group has compiled a reference list

of appraisers for valuations of real estate located outside the

Republic of Slovenia. Appraisals must be made in accordance

with the international valuation standards, and for larger

exposures, real-estate evaluations must also be reviewed by

an internal licensed appraiser with knowledge of the local

real-estate market. If the appraisal does not correspond to the

international valuation standards or if the value adjustment is

greater than certain limit, the appraisal is rejected as inadequate.

When assuring collateral, NLB Group follows the internal

regulations which define the minimum security or pledge

ratios. NLB Group strives to obtain collateral with a higher

value than the underlying exposure (depending on the

borrower’s rating, loan maturity, etc.) with the aim of reducing

negative consequences resulting from any major swings

in market prices of the assets used as collateral. If real

estate, movable property, and financial instruments serve

as collateral, NLB Group’s lien on such assets should be top

ranking. Exceptionally, where the value of the mortgaged real

estate is large enough, the lien can have a different priority

order.

NLB Group monitors the value of collateral during the loan

repayment period in accordance with the mandatory periods

and internal instructions. For example, the value of collateral

using mortgaged real estate is monitored annually by either

preparing individual assessments or using the internal

methodology for preparing an own value appraisal of real

estate (which applies to Republic of Slovenia, and partly, for

the housing segment to Serbia, Montenegro, and Bosnia and

Herzegovina) based on public records and indexes of real-

estate value published bythe relevantgovernment authorities

(the Surveying and Mapping Authority in the Republic

of Slovenia). The value of pledged movable property is

monitored once a year (in NLB automated, with a straight-line

depreciation over the period of the remaining useful life).

h) The main types of collateral taken by the NLB Group

NLB Group accepts different forms of material and personal

security as loan collateral.

Material loan collateral gives the right in the case of a debtor

(borrower) defaulting on their contractual obligations to sell

a specific property to recover claims, keep specific non-cash

property or cash, or reduce or offset the amount of exposure

against the counterparty’s debt to the Bank.

NLB Group accepts the following material types of loan

collateral:

•Collateral in the form of business and residential real

estate: land, buildings, and individual parts of buildings in

a storeyed property intended for living in or performing

a business activity, such as land in the area foreseen for

construction, apartments, residential buildings, garages

and holiday homes, business premises, industrial buildings,

offices, shops, hotels, branches and warehouses, forests,

parking spaces, etc. Objects can be completed or under

construction. Priority is given to property where the pledge

right of the Bank is entered in the first place and real estate

is already owned by the debtor and/or the pledger. For real

estate, there must be a market, and it must be redeemable

within a reasonable time;

•Collateral in the form of movable property: priority is given

to the types of movable property, that are highly likely to be

sold in the event of execution, and the funds received are

used to repay the collateralised claims (their market value

must be estimated with considerable reliability). Among the

appropriate types of movable property, the Bank includes

motor vehicles, agricultural machinery, construction

machinery,production linesand series-produced machines,

and some custom-made production machines;

•Collateral by a pledge of financial assets (Bank deposits or

cash-like instruments, debt securities of different issuers,

investment fund units, equity securities, or convertible

bonds):

•Cash receivable collateral: bank deposits and savings with

Bank are appropriate in domestic and foreign currency;

•Debt securities: shares and bonds which, according to the

Bank’s assessment, are suitable for securing investments

and are traded on a regulated market (marketable

securities of higher-quality Slovenian and foreign issuers);

•The pledge of investment coupons of mutual funds

managed by management companies (a priority company

NLB Skladi) and are, according to the Bank’s assessment,

suitable for insurance of investments.

•

A pledge of an equity stake: non-marketable capital shares

with a credit rating of at least B are adequate;

•A pledge or assignment of receivables as collateral: cash

receivables must have longer maturities than the maturity of

the investment and they must not be due and not be paid;

•Other material forms of loan collateral (e.g., life insurance

policies pledged to NLB): The Bank accepts products of

Vita, life insurance company d.d. Ljubljana – a pledge of an

investment life insurance policy and a life insurance policy

with a guaranteed return that includes saving, in addition to

insurance.

![]()

284

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Personal loan collateral is a method for reducing credit risk

whereby a third party undertakes to pay the debt in case of

the primary debtor (borrower) defaulting.

NLB Group accepts the following types of personal loan

collateral:

•Joint and several guarantees by retail and corporate

clients: for the collateralisation of private individuals’ loans,

employees, or pensioners are adequate guarantors. They

must not be in the process of personal bankruptcy. They are

responsible for fulfilling the debtor’s obligations for loans

with a repayment period not exceeding 60 months. For the

collateralisation of legal entitiesinvestments, legal entities,

individuals, or private individuals are adequate guarantors.

•

Bankguarantees;

•Government guarantees (e.g., of the Republic of Slovenia);

•Guarantees by national and regional development agencies

with which the Bank has a contract on the acceptance of

guarantees (e.g. Slovene Enterprise Fund);

•Other types of personal loan collateral.

Loans are very often secured by a combination of collateral

types. The general recommendations on loan collateral are

specified in the internal instructions and include the elements

specified below. The decision on the type of collateral and

the coverage of loan by collateral depends on the client’s

creditworthiness (credit rating),loan maturity, and varies

depending on whether the loan is granted to retail or a

corporate client.

NLB has also created, in the area of real-estate loan collateral,

an ‘online’ connection with the Surveying and Mapping

Authority in the Republic of Slovenia, which allows direct and

immediate verification of the existence of property.

NLB Group strives to ensure the best possible collateral for

long-term loans, in particular mortgages where possible. As a

result, the mortgaging of real estate is the most frequent form

of loan collateral of corporate and retail clients. In corporate

exposures, the next most frequent forms of collateral are

government and corporate guarantees, while in retail loans, it

is guarantors.

i) Risks, deriving from valuation ofreceived collateral

Client/counterparty credit risk is the key decision parameter

when approving exposures. Collateral is a secondary source

of repayment, and therefore decisions on approvals of

exposures should not primarily be based on the provided

collateral. However, collateral is an important comfort element

in the approval process and, depending on the credit rating

of the client, a prerequisite. NLB Group has prescribed the

minimum ratios between the value of collateral and the loan

amount, depending on the type of collateral, loan maturity

and the client rating. The ratios are based on experience and

regulatory guidelines.

NLB Group pays particular attention to closely monitoring

the fair value of collateral, and to receiving regular and

independent revaluationsby applying theInternational

Valuation Standards. Through a detailed examination of all

collateral received, NLB has ensured that only collateral from

which payment can be realistically expected if it is liquidated,

is considered.

NLB Group has the largest concentration of collaterals arising

from mortgages on realestate, which is arelatively reliable

and quality type of collateral. Due to the possible decrease

of real estate market prices, the Bank closely monitors the

real-estate collateral values and, where required, establishes

higher amounts of impairments and provisions for non-

performing loans secured by real estate, based on estimated

discounts of the real-estate value, which are expected to be

achieved in a sale (expected payment from collateral). Priority

is given to property where the pledge right of the Bank is

entered in the first place and the real estate is already owned

by the debtor and/or the pledger. For real estate, there must

be a market, and it must be redeemable within a reasonable

time.

Collateral consisting of securities entails market risk,

specifically the risk of changes in the prices of securities on

capital markets. To limit such risks and restrict the possibility

of the value of instruments received as collateral falling below

approved limits, the Rules determine minimum pledge ratios

for securing loansbased on pledgedsecurities and equity

shares in NLB. Deviations from the Rules are subject to the

prior approval of the respective decision bodies of the Bank.

The ratio between the loan amount and the securities’ value

is determined regarding the securities’ liquidity,maturity,

correlation with changes in market indexes, i.e., by considering

the key features reflecting the level of volatility of market

prices, and the ability to sell the securities at the market price.

Collateral consisting of the sureties of corporate clients,

sureties of private individuals, and bank guarantees entail

the credit risk of the provider of the collateral. NLB Group

includes the amount of the guarantees received in the

exposure of the guarantor, and guarantees are only taken into

account as collateral if the guarantor has sufficient overall

creditworthiness.

The Business Rules – Collateral for Retail and Corporate

Loans regulate which forms of collateral are acceptable, and

which preconditions a type of collateral needs to fulfil to be

able to be considered.

![]()

285

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

j) Credit quality analysis for financial assets and contingent liabilities

in EUR thousands

NLB GroupNLB

31 Dec 2021

12-month

expected

credit losses

Lifetime ECL

not credit -

impaired

Lifetime ECL

credit-

impaired

Purchased

credit-impaired

financial assets

Total

12-month

expected

credit losses

Lifetime ECL

not credit -

impaired

Lifetime ECL

credit-

impaired

Purchased

credit-impaired

financial assets

Total

Debt securities at amortised cost

A1,218,597---1,218,5971,183,578---1,183,578

B495,114---495,114254,672---254,672

C-7,220--7,220-----

Loss allowance(3,253)(52)--(3,305)(1,826)---(1,826)

Carrying amount1,710,4587,168--1,717,6261,436,424---1,436,424

Loans and advances to banks at amortised cost

A89,499---89,499199,390---199,390

B51,382---51,38279---79

Loss allowance(198)---(198)(182)---(182)

Carrying amount140,683---140,683199,287---199,287

Loans and advances to individuals

at amortised cost

A5,305,83346,972-

249

5,353,0542,554,00626,634--2,580,640

B60,89123,933-1684,84016,91915,108--32,027

C5,82749,330-29355,450-24,293--24,293

D and E--125,2972,430127,727--57,396-57,396

Loss allowance(18,336)(7,398)(76,204)157(101,781)(3,503)(2,421)(31,497)-(37,421)

Carrying amount5,354,215112,83749,0933,1455,519,2902,567,42263,61425,899-2,656,935

Loans and advances to other

customers at amortised cost

A1,172,77059-31,172,832875,91226--875,938

B3,333,087198,824-263,531,9371,421,39885,402--1,506,800

C124,628213,301-17337,94653,96537,876--91,841

D and E--209,22930,079239,308--68,7823,85572,637

Loss allowance(50,961)(26,624)(135,994)(613)(214,192)(10,101)(1,787)(46,272)(838)(58,998)

Carrying amount4,579,524385,56073,23529,5125,067,8312,341,174121,51722,5103,0172,488,218

Other financial assets at amortised cost

A92,43037--92,46783,9431--83,944

B26,908128--27,0365,22319--5,242

C319

694

--1,0133,22429--3,253

D and E--6,7031,2367,939--1,107111,118

Loss allowance(476)(36)(6,322)608(6,226)(62)(1)(1,084)(6)(1,153)

Carrying amount119,1818233811,844122,22992,3284823592,404

Debt instruments at fair value through

other comprehensive income

A1,587,032---1,587,0321,308,690---1,308,690

B1,809,069---1,809,069218,282---218,282

C-184--184-----

D and E--798-798--798-798

Loss allowance(11,148)(70)(798)-(12,016)(2,203)-(798)-(3,001)

Contingent liabilities

A1,405,5336,451-381,412,0221,041,2955,657--1,046,952

B1,574,40167,514-111,641,926844,52634,180--878,706

C48,03723,571-1871,62627,7519,265--37,016

D and E--24,56514,36638,931--19,2527,65126,903

Loss allowance(12,912)(1,640)(14,545)(4,344)(33,441)(3,909)(141)(12,469)(4,041)(20,560)

Carrying amount3,015,05995,89610,02010,0893,131,0641,909,66348,9616,7833,6101,969,017

![]()

286

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

in EUR thousands

NLB GroupNLB

31 Dec 2020

12-month

expected

credit losses

Lifetime ECL

not credit -

impaired

Lifetime ECL

credit-

impaired

Purchased

credit-impaired

financial assets

Total

12-month

expected

credit losses

Lifetime ECL

not credit -

impaired

Lifetime ECL

credit-

impaired

Purchased

credit-impaired

financial assets

Total

Debt securities at amortised cost

A1,118,700---1,118,7001,118,700---1,118,700

B388,072---388,072161,021---161,021

Loss allowance(3,685)---(3,685)(1,841)---(1,841)

Carrying amount1,503,087---1,503,0871,277,880---1,277,880

Loans and advances to banks

at amortised cost

A67,862---67,862158,475---158,475

B128,784---128,784-----

C500---500-----

Loss allowance(141)---(141)(155)---(155)

Carrying amount197,005---197,005158,320---158,320

Loans and advances to individuals

at amortised cost

A4,739,47076,080--4,815,5502,290,49842,642--2,333,140

B34,4159,471--43,8865,132460--5,592

C3,52847,436--50,964-21,573--21,573

D and E--111,1186,075117,193--51,644-51,644

Loss allowance(25,044)(8,151)(61,305)-(94,500)(8,973)(2,351)(22,855)-(34,179)

Carrying amount4,752,369124,83649,8136,0754,933,0932,286,65762,32428,789-2,377,770

Loans and advances to other

customers at amortised cost

A1,070,367373--1,070,740820,241120--820,361

B2,930,393188,641--3,119,0341,127,454111,223--1,238,677

C219,102238,152--457,25434,33882,492--116,830

D and E--279,80337,716317,519--117,3922,341119,733

Loss allowance(49,475)(32,682)(194,298)(1,325)(277,780)(16,664)(8,936)(82,274)(1,319)(109,193)

Carrying amount4,170,387394,48485,50536,3914,686,7671,965,369184,89935,1181,0222,186,408

Other financial assets at amortised cost

A64,69128--64,71948,9941--48,995

B46,38255--46,4375,38628--5,414

C223438--6615636--92

D and E--5,6551,2196,874--1,32481,332

Loss allowance(276)(30)(5,243)(4)(5,553)(73)(2)(1,251)(4)(1,330)

Carrying amount111,0204914121,215113,13854,3636373454,503

Debt instruments at fair value through

other comprehensive income

A1,568,201---1,568,2011,422,777---1,422,777

B1,839,167229--1,839,396217,138---217,138

D and E--798-798--798-798

Loss allowance(8,656)(28)(798)-(9,482)(2,343)-(798)-(3,141)

Contingent liabilities

A1,285,492843--1,286,335984,496238--984,734

B1,490,92953,326--1,544,255889,66941,654--931,323

C48,32949,781--98,11022,25331,363--53,616

D and E--31,47414,79646,270--27,8557,05234,907

Loss allowance(15,796)(2,767)(18,554)(5,057)(42,174)(7,510)(732)(16,493)(3,808)(28,543)

Carrying amount2,808,954101,18312,9209,7392,932,7961,888,90872,52311,3623,2441,976,037

![]()

287

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

The NLB Group’s client credit rating classification is based

on an internally developed methodology, drawing from

internal statistical analyses, good banking practices, as well

as Bank of Slovenia regulations, and ECB and EBA guidelines

and requirements. The aligned rating methodology is used

across the entire NLB Group. It includes a uniform credit

grade scale of 12 rating classes, out of which nine represent

performing clients and three non-performing clients.

Rating Group A (AAA to A rating classes) includes the best

clients with a low degree of default probability, characterised

by high coverage of financial liabilities with free cash flow.

The Rating Group A is considered as investment grade

classification.

Rating Group B (BBB to B rating classes) includes clients

with a low credit risk, starting one notch lower than ‘A’

rating group clients. These clients show stable performance,

acceptable financial ratios, and qualitative elements, and

have sufficient cash flow to settle their obligations, but may

be more sensitive to changes in the industry or the economy.

The Rating Group B classification is an investment grade for

BBB, and an ‘invest with care’ for BB and B.

Rating Group C (CCC to C rating classes) includes clients who

are exposed to a higher and above-average level of credit

risk. CCC rated clients are financed by the Bank only in the

case when such support brings more positive effects for the

Bank; however, the Rating Group C is overall considered as a

substantial risk. The Bank reasonably restricts cooperation

with such clients and decreases its exposure to them.

Rating Groups D (D and DF rating classes) and E represent

non-performing clients that are treated as defaulted. D, DF,

and E rating classified clients are ordinarily transferred to the

specialised units for restructuring (which performs business

and financial restructuring with a goal of minimising losses and

restoring the client to a performing status) or workout and legal

support (with the goal of minimising losses due to default).

In 2020, NLB Group applied a new default definition based on

the EBA guidelines, where the materiality threshold for delays

is determined in absolute and relative terms (EUR 100 for

retail and EUR 500 for non-retail segment and 1% of the total

on-balance exposure on the client level). At the same time, the

assessment of rating for private individuals was improved by

establishing a common rating on the client level.

A standard corporate rating methodology, with the prescribed

set of parameters (qualitative and quantitative) applies to all

the NLB Group bank entities. Groups of connected clients are

treated as materially important for the NLB Group whenever

exposure exceeds EUR 7 million or EUR 15 million for NLB Group

members with total assets greater than EUR 1 billion. Materially

important clients are submitted to the NLB Credit Committee.

NLB regularly reviews the business practices and credit

portfolios of NLB Group entities to make sure they are operating

in accordance with the minimum risk management standards

of NLB Group. This ensures appropriate standard processes for

managing and reporting credit risks at the consolidated level.

in EUR thousands

NLB Group

31 Dec 2021All forborne exposures

Impairment, provisions and value

adjustments

Collateral and

financial

guarantees

received on

forborne

exposures

Non - performing

Performing

forborne exposures

Non-performing

forborne exposures

Gross carrying

amount

PerformingImpairedDefaulted

Loans and advances (including at amortised cost and fair value)239,20857,058182,094182,150(4,602)(100,963)109,177

Governments1,093828265265(11)(265)-

Other financial organisations2,7442132,5312,531(8)(2,531)12

Non-financial organisations180,75435,422145,276145,332(3,268)(83,243)79,260

Households54,61720,59534,02234,022(1,315)(14,924)29,905

Debt instruments other than held for trading239,20857,058182,094182,150(4,602)(100,963)109,177

Loan commitments given718

96

622622

-(374)

294

Total exposures with forbearance measures239,92657,154182,716182,772(4,602)(101,337)109,471

k) Forborne loans

![]()

288

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

in EUR thousands

NLB

31 Dec 2021All forborne exposures

Impairment, provisions and value

adjustments

Collateral and

financial

guarantees

received on

forborne

exposures

Non - performing

Performing

forborne exposures

Non-performing

forborne exposures

Gross carrying

amount

PerformingImpairedDefaulted

Loans and advances (including at amortised cost and fair value)109,67425,48584,13384,189(1,130)(48,898)51,837

Other financial organisations2,7442132,5312,531(8)(2,531)12

Non-financial organisations69,29913,10056,14356,199(291)(35,930)31,564

Households37,63112,17225,45925,459(831)(10,437)20,261

Debt instruments other than held for trading109,67425,48584,13384,189(1,130)(48,898)51,837

Loan commitments given688

96

592592-(344)

294

Total exposures with forbearance measures110,36225,58184,72584,781(1,130)(49,242)52,131

in EUR thousands

NLB Group

31 Dec 2020All forborne exposures

Impairment, provisions and value

adjustments

Collateral and

financial

guarantees

received on

forborne

exposures

Non - performing

Performing

forborne exposures

Non-performing

forborne exposures

Gross carrying

amount

PerformingImpairedDefaulted

Loans and advances (including at amortised cost and fair value)303,80255,354223,376248,448(5,761)(141,372)142,714

Governments1,3421,050292292(5)(292)-

Other financial organisations2,425502,3752,375-(2,375)50

Non-financial organisations254,94733,882195,993221,065(4,739)(129,550)114,395

Households45,08820,37224,71624,716(1,017)(9,155)28,269

Debt instruments other than held for trading303,80255,354223,376248,448(5,761)(141,372)142,714

Loan commitments given1,586

942

644644(4)(37)1,332

Total exposures with forbearance measures305,38856,296224,020249,092(5,765)(141,409)144,046

![]()

289

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Forborne exposures of debtinstruments by periodsof forbearance

in EUR thousands

NLB

31 Dec 2020All forborne exposures

Impairment, provisions and value

adjustments

Collateral and

financial

guarantees

received on

forborne

exposures

Non - performing

Performing

forborne exposures

Non-performing

forborne exposures

Gross carrying

amount

PerformingImpairedDefaulted

Loans and advances (including at amortised cost and fair value)148,25121,976103,287126,275(1,522)(73,298)76,210

Other financial organisations2,397222,3752,375-(2,375)22

Non-financial organisations117,6719,52285,161108,149(742)(66,055)58,447

Households28,18312,43215,75115,751(780)(4,868)17,741

Debt instruments other than held for trading148,25121,976103,287126,275(1,522)(73,298)76,210

Loan commitments given1,560920640640(2)(35)1,332

Total exposures with forbearance measures149,81122,896103,927126,915(1,524)(73,333)77,542

in EUR thousands

NLB Group

31 Dec 2021Up to 3 months3 to 6 months6 to 12 monthsOver 12 months

Performing exposures7,4115,0559,86030,130

Non-performing exposures26,8354,85618,54030,956

Total exposures with forbearance measures34,2469,91128,40061,086

31 Dec 2020

Performing exposures13,4559,9631,85824,317

Non-performing exposures32,9501,7867,14065,200

Total exposures with forbearance measures46,40511,7498,99889,517

in EUR thousands

NLB

31 Dec 2021Up to 3 months3 to 6 months6 to 12 monthsOver 12 months

Performing exposures2,8193,8987,00810,630

Non-performing exposures7,4672,41013,86311,551

Total exposures with forbearance measures10,2866,30820,87122,181

31 Dec 2020

Performing exposures8,3049311,3989,821

Non-performing exposures3,969

942

5,51342,553

Total exposures with forbearance measures12,2731,8736,91152,374

The main forbearance measurements used by NLB Group

and NLB are: deferral of payment, reduction of interest rates,

acquisition of collateral for partial repayment of claims, and

others, either as a single forbearance measurement or as a

combination of those.

![]()

290

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

l) Repossessedassets

NLB Group and NLB received the following assets by taking possession of collateral held as security and held them at the reporting date:

in EUR thousands

NLB GroupNLB

31 Dec 202131 Dec 202031 Dec 202131 Dec 2020

Nature of assetsNet valueNet value

Investment property (note 5.9.)36,00936,1304,1764,079

Property and equipment (note 5.8.)13,55913,26877

Investments in subsidiaries and associates--2,3332,412

Real estates (note 5.13.)74,71775,1514,8274,926

Other assets (note 5.13.)733866--

Non-current assets held for sale (note 5.7.)

699699

--

Total125,717126,11411,34311,424

m) Analysis of loans and advances by industry sectors

in EUR thousands

NLB Group31 Dec 202131 Dec 2020

Industry sectorGross loans

Impairment

provisions

Net loans(%)Gross loans

Impairment

provisions

Net loans(%)

Banks140,881(198)140,6831.30197,146(141)197,0051.98

Finance90,538(2,851)87,6870.81116,593(3,126)113,4671.14

Electricity, gas, and water361,520(5,392)356,1283.28298,612(6,971)291,6412.93

Construction industry420,173(29,459)390,7143.60361,494(27,548)333,9463.35

Heavy industry1,059,774(30,352)1,029,4229.49952,671(44,446)908,2259.12

Education12,888(1,358)11,5300.1113,883(1,111)12,7720.13

Agriculture, forestry, and fishing91,735(3,530)88,2050.8191,780(7,023)84,7570.85

Public sector231,488(5,269)226,2192.08301,205(5,737)295,4682.97

Individuals5,621,071(101,781)5,519,29050.875,027,648(94,555)4,933,09349.55

Mining49,936(1,604)48,3320.4579,662(1,230)78,4320.79

Entrepreneurs341,670(7,554)334,1163.08314,276(7,268)307,0083.08

Services778,569(34,587)743,9826.86725,020(71,133)653,8876.57

Transport and communications798,822(25,902)772,9207.12811,517(25,029)786,4887.90

Trade industry1,008,369(64,364)944,0058.70874,235(75,309)798,9268.03

Health care and social security36,541(1,970)34,5710.3248,620(1,794)46,8260.47

Other financial assets128,455(6,226)122,2291.13118,691(5,553)113,1381.14

Total11,172,430(322,397)10,850,033100.0010,333,053(377,974)9,955,079100.00

![]()

291

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

in EUR thousands

NLB31 Dec 202131 Dec 2020

Industry sectorGross loans

Impairment

provisions

Net loans(%)Gross loans

Impairment

provisions

Net loans(%)

Banks199,469(182)199,2873.66158,475(155)158,3203.29

Finance169,679(3,109)166,5703.06135,040(4,405)130,6352.72

Electricity, gas, and water228,423(724)227,6994.18157,515(2,892)154,6233.22

Construction industry71,989(9,870)62,1191.1463,025(8,463)54,5621.13

Heavy industry583,658(6,747)576,91110.60519,880(14,445)505,43510.51

Education4,045(27)4,0180.075,197(38)5,1590.11

Agriculture, forestry, and fishing13,073(100)12,9730.2415,099(865)14,2340.30

Public sector94,176(974)93,2021.7195,930(1,793)94,1371.96

Individuals2,694,356(37,421)2,656,93548.802,411,949(34,179)2,377,77049.46

Mining22,316(514)21,8020.408,580(74)8,5060.18

Entrepreneurs54,600(1,942)52,6580.9752,216(3,014)49,2021.02

Services482,176(11,421)470,7558.65454,154(44,827)409,3278.51

Transport and communications556,786(5,459)551,32710.13589,269(4,965)584,30412.15

Trade industry248,823(16,492)232,3314.27204,343(22,190)182,1533.79

Health care and social security25,360(1,619)23,7410.4426,288(1,222)25,0660.52

Other financial assets93,557(1,153)92,4041.7055,833(1,330)54,5031.13

Total5,542,486(97,754)5,444,732100.004,952,793(144,857)4,807,936100.00

n) Analysis ofnet loans and advances by geographical sectors

in EUR thousands

NLB GroupNLB

Country31 Dec 202131 Dec 202031 Dec 202131 Dec 2020

Slovenia4,861,9684,360,0514,856,3054,354,155

Other European Union members249,772157,557156,42573,252

Serbia2,320,4912,146,793136,696134,303

Other countries3,417,8023,290,678295,306246,226

Total10,850,0339,955,0795,444,7324,807,936

As at 31 December 2021, Other countries include direct

exposure to Russia in the amount of EUR 94 thousand at

NLB Group level and EUR 84 thousand at NLB level. Direct

exposure to Ukraine amount to EUR 4 thousand at NLB Group

level and EUR 2 thousand at NLB level.

![]()

292

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

o)Analysis of debt securities and derivative financial instruments by geographical sectors

in EUR thousands

31 Dec 2021NLB GroupNLB

Country

Financial assets

measured at

amortised cost

Financial assets

held for trading

Financial assets

measured at fair

value through OCI

Non-trading financial

assets mandatorily

at FV through profit

or loss

Derivative

financial

instruments

Financial assets

measured at

amortised cost

Financial assets

held for trading

Financial assets

measured at fair

value through OCI

Derivative

financial

instruments

Slovenia324,705-331,155-6,835324,705-280,1746,835

Other members of European Union1,076,225-1,180,5212,4281,3881,041,207-970,1921,388

- Austria

76,628-81,063--76,628-56,551-

- Belgium

126,828-93,404-642126,828-59,830642

- Bulgaria

43,374-3,173--43,374-3,173-

- Czech Republic

--12,795----12,795-

- Cyprus

12,447-1,755--12,447-1,755-

- Denmark

--20,234----20,234-

- Finland

45,899-107,633--45,899-99,578-

- France

170,425-193,668-528160,423-162,625528

- Germany

105,368-115,180-

167

95,361-92,622

167

- Greece

-14,805---14,805-

- Hungary

21,719-6,547--21,719-6,547-

- Ireland

51,906-100,689--51,906-32,639-

- Italy

26,190-10,910

107

-26,190-10,910-

- Latvia

24,929----24,929---

- Lithuania

15,321-27,226--15,321-27,226-

- Luxembourg

78,097-30,087--78,097-30,087-

- Netherlands

67,678

-143,5462,3215157,670-135,52951

- Poland

17,829-18,989--17,829-18,989-

- Portugal

47,842-18,704--47,842-18,704-

- Romania

23,365-5,484--23,365-5,484-

- Slovakia

21,603-34,627--21,603-34,627-

- Spain

70,347-64,377--65,346-49,857-

- Sweden

15,128-75,625--15,128-75,625-

- Other

13,302----13,302---

United States of America5,061-75,4981,833-5,061-8,667-

Other countries311,635-1,808,087-2365,451-282,00927

- Bosnia and Herzegovina

4,048-145,522--4,048-3,204-

- Kosovo

--76,533-1---1

- Montenegro

37,349-23,578--6,799-3,073-

- North Macedonia

221,697-152,886-613,230-57,867-

- Serbia

7,167-1,196,724----5,02110

- Albania

--29,823----29,823-

- Canada

14,026-27,247--14,026-27,247-

- Great Britain

--81,218-16--81,21816

- Iceland

5,768-8,857--5,768-8,857-

- Israel

--10,468----10,468-

- Kazakhstan

--14,254----14,254-

- Norway

14,606-16,210--14,606-16,210-

- Russia

--20,105----20,105-

- Other

6,974-4,662--6,974-4,662-

Total1,717,626-3,395,2614,2618,2461,436,424-1,541,0428,250

Other members of the European Union included in the line

item ‘Other’ are Malta and Estonia.

Other members of the ‘Other countries’ in the line item ‘Other’

are Egypt, Uzbekistan, and Oman.

![]()

293

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

in EUR thousands

31 Dec 2020NLB GroupNLB

Country

Financial assets

measured at

amortised cost

Financial assets

held for trading

Financial assets

measured at fair

value through OCI

Non-trading financial

assets mandatorily

at FV through profit

or loss

Derivative

financial

instruments

Financial assets

measured at

amortised cost

Financial assets

held for trading

Financial assets

measured at fair

value through OCI

Derivative

financial

instruments

Slovenia305,697-484,875-14,498305,697-389,93214,498

Other members of European Union930,258-978,504111

672

930,258-932,714

672

- Austria

78,720-73,959--78,720-59,163-

- Belgium

121,657-78,858--121,657-57,167-

- Bulgaria

36,910-3,255--36,910-3,255-

- Czech Republic

1,025-16,420--1,025-16,420-

- Cyprus

12,662-1,826--12,662-1,826-

- Denmark

--15,976----15,976-

- Finland

38,515-81,905--38,515-80,827-

- France

151,981-155,580-80151,981-149,67380

- Germany

63,155-104,967-12063,155-104,967120

- Greece

--7,001----7,001-

- Hungary

20,907-9,924--20,907-9,924-

- Ireland

45,576-36,464--45,576-34,146-

- Italy

7,088-11,048111-7,088-11,048-

- Latvia

22,112-

749

--22,112-

749

-

- Lithuania

11,626-18,385--11,626-18,385-

- Luxembourg

71,821-37,853--71,821-37,853-

- Netherlands

50,409-133,360-9050,409-133,36090

- Poland

26,432-17,023--26,432-17,023-

- Portugal

45,937-19,377--45,937-19,377-

- Romania

23,600-5,599--23,600-5,599-

- Slovakia

21,662-36,350--21,662-36,350-

- Spain

66,622-53,201--66,622-53,201-

- Sweden

8,072-59,424--8,072-59,424-

- Other

3,769---3823,769--382

United States of America9,7862,45079,5432,046-9,7862,45056,742-

Other countries257,34666,3561,903,569-

879

32,139-291,8161,211

- Bosnia and Herzegovina

--167,131-----4

- Kosovo

--75,223-

786

---

786

- Montenegro

20,386-18,649--6,816-3,134-

- North Macedonia

204,455-143,059-7--56,433-

- Serbia

7,18266,3561,267,258-30---365

- Albania

--30,548----30,548-

- Canada

14,037-27,514--14,037-27,514-

- Great Britain

--104,493-56--104,49356

- Iceland

4,993-8,988--4,993-8,988-

- Israel

--9,511----9,511-

- Kazakhstan

--12,261----12,261-

- Norway

6,293-20,526--6,293-20,526-

- Russia

--18,408----18,408-

Total1,503,08768,8063,446,4912,15716,0491,277,8802,4501,671,20416,381

Other members of the European Union included in the line

item ‘Other’ are Malta and Croatia.

![]()

294

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

p)Internal rating of derivativescounterparties

in %

NLB GroupNLB

31 Dec 202131 Dec 202031 Dec 202131 Dec 2020

A74.0873.5674.2573.75

B25.6915.3525.5315.24

C0.0310.900.0310.82

D and E0.190.190.190.19

Total100.00100.00100.00100.00

in EUR thousands

31 Dec 2021NLB GroupNLB

Internal ratingABCDTotalABCDTotal

Financial assets measured at fair value through

other comprehensive income

48,099---48,09933,107---33,107

Financial assets measured at amortised cost

- loans and advances to banks-----84,399---84,399

- loans and advances to customers-------6,522-6,522

Total48,099---48,099117,506-6,522-124,028

in EUR thousands

31 Dec 2020NLB GroupNLB

Internal ratingABCDTotalABCDTotal

Financial assets measured at fair value through

other comprehensive income

-14,796--14,796-----

Financial assets measured at amortised cost

- loans and advances to banks-----67,128---67,128

- loans and advances to customers-------5,858-5,858

Total-14,796--14,79667,128-5,858-72,986

All derivatives in the banking book are entered into with

counterparties with an external investment-graderating.

When derivatives are entered into on behalf of NLB Group’s

customers, such customers usually do not have an external

rating, but all such transactions are covered through back-

to-back transactions involving third parties with an external

investment-graderating.

r) Debt securities in NLB Group’s and NLB’s portfolio that represent subordinated liabilities for the issuer

![]()

295

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

s) Presentation of net financial instruments by measurement category

in EUR thousands

NLB Group

31 Dec 2021

Financial assets

held for trading

Non-trading financial

assets mandatorily at FV

through P&L

Financial assets

measured at

FV through OCI

Financial assets

measured at

amortised cost

Financial leases

Derivatives for

hedge accounting

Total

Cash and obligatory reserves

with central banks, and other

demand deposits at banks

---5,005,052--5,005,052

Securities-21,1613,461,8601,717,626--5,200,647

- Bonds-4,2613,251,8261,707,960--4,964,047

- Shares-4,47266,599---71,071

- Commercial bills--37,569---37,569

- Treasury bills

--105,8669,666--115,532

- Investment funds-12,428----12,428

Derivatives7,678----5688,246

Loans and receivables---10,619,525108,279-10,727,804

- Loans to governments---280,96149-281,010

- Loans to banks---140,683--140,683

- Loans to financial organisations---141,69811-141,709

- Loans to individuals---5,473,27846,012-5,519,290

- Loans to other customers---4,582,90662,206-4,645,112

Other financial assets---122,229--122,229

Total financial assets7,67821,1613,461,86017,464,432108,27956821,063,978

in EUR thousands

NLB Group

31 Dec 2020

Financial assets

held for trading

Non-trading financial

assets mandatorily at

FV through P&L

Financial assets

measured at

FV through OCI

Financial assets

measured at

amortised cost

Financial leasesTotal

Cash and obligatory reserves

with central banks, and other

demand deposits at banks

---3,961,812-3,961,812

Securities68,80617,3173,514,2901,503,087-5,103,500

- Bonds68,8062,1573,260,9401,480,478-4,812,381

- Shares-4,17167,799--71,970

- Commercial bills--50,449--50,449

- Treasury bills

--135,10222,609-157,711

- Investment funds-10,989---10,989

Derivatives16,049----16,049

Loans and receivables-25,076-9,768,23248,6339,841,941

- Loans to governments---365,3393,061368,400

- Loans to banks---197,005-197,005

- Loans to financial organisations---158,84526158,871

- Loans to individuals---4,913,79319,3004,933,093

- Loans to other customers-25,076-4,133,25026,2464,184,572

Other financial assets---113,138-113,138

Total financial assets84,85542,3933,514,29015,346,26948,63319,036,440

![]()

296

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

in EUR thousands

NLB

31 Dec 2021

Financial assets

held for trading

Non-trading financial

assets mandatorily at

FV through P&L

Financial assets

measured at

FV through OCI

Financial assets

measured at

amortised cost

Derivatives for

hedge accounting

Total

Cash and obligatory reserves

with central banks, and other

demand deposits at banks

---3,250,437-3,250,437

Securities-4,4721,585,7511,436,424-3,026,647

- Bonds--1,526,2371,436,424-2,962,661

- Shares-4,47244,709--49,181

- Treasury bills

--14,805--14,805

Derivatives7,682---5688,250

Loans and receivables-7,888-5,344,440-5,352,328

- Loans to governments--143,864-143,864

- Loans to banks--199,287-199,287

- Loans to financial organisations--226,144-226,144

- Loans to individuals---2,656,935-2,656,935

- Loans to other customers-7,888-2,118,210-2,126,098

Other financial assets---92,404-92,404

Total financial assets7,68212,3601,585,75110,123,70556811,730,066

in EUR thousands

NLB

31 Dec 2020

Financial assets

held for trading

Non-trading financial

assets mandatorily at

FV through P&L

Financial assets

measured at

FV through OCI

Financial assets

measured at

amortised cost

Total

Cash and obligatory reserves

with central banks, and other

demand deposits at banks

---2,261,5332,261,533

Securities2,4504,1711,716,3511,277,8803,000,852

- Bonds2,450-1,598,7601,277,8802,879,090

- Shares-4,17145,147-49,318

- Treasury bills

--72,444-72,444

Derivatives16,381---16,381

Loans and receivables-30,935-4,722,4984,753,433

- Loans to governments---170,742170,742

- Loans to banks---158,320158,320

- Loans to financial organisations---177,198177,198

- Loans to individuals---2,377,7702,377,770

- Loans to other customers-30,935-1,838,4681,869,403

Other financial assets---54,50354,503

Total financial assets18,83135,1061,716,3518,316,41410,086,702

As at 31 December 2021 and 31 December 2020, all of NLB

Group’s financial liabilities, except forderivatives designated

as hedging instruments, trading liabilities, and financial

liabilities measured at fair value through profit or loss, were

carried at amortised cost.

![]()

297

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

6.2.

Market risk

NLB defines market risk as the risk of potential financial losses

due to changes in rates and/or market prices (exchange

rates, credit spreads, and equity prices), or in parameters

that affect prices (volatilities and correlations). Losses may

impact profit or loss directly, for example in the case of trading

book positions. However, for the banking book positions they

are reflected in the revaluation reserve. The exposure to the

market risk is to a certain degree integrated into the banking

industry and offers an opportunity to create financial results

and value.

The Global Risk Department of NLB is independent from

the trading activities and reports to the Bank’s Assets and

Liabilities Committee (ALCO). Global Risk also monitors and

manages exposure to market risks separately for the banking

and trading books. Exposures and limits are monitored daily

and reported to the ALCO committee on a regular basis.

The Bank uses a wide selection of quantitative and qualitative

tools for measuring, managing, and reporting market risks

such as value-at-risk (VaR), sensitivity analysis, stress-

testing, back-testing, scenarios, other market risk mitigants

(concentration of exposures, gap limits, stop-loss limits, etc.),

net interest income sensitivity, economic value of equity, and

economic capital. Stress-testing provides an indication of the

potential losses that could occur in severe market conditions.

In the area of currency risk, NLB Group pursues the goal of low

to medium exposure. NLB monitors the open position of NLB

Group on an ongoing basis. The orientation of NLB Group in

interest rate risk management is to prevent negative effects on

the net revenues arising from changed market interest rates.The

conclusion of transactions involving derivatives at NLB is limited

to the servicing of the clients’ and hedging of the Group’s own

open positions. In accordance with the provisions of the Strategy

on trading with financial instruments in NLB Group, the trading

activities in other NLB Group members are very restricted.

For monitoring and managing NLB Group’s exposure to

market risks uniform guidelines and exposure limits for each

type of risk are set for individual NLB Group entities. The

methodologies are in line with regulatory requirements on

individual and consolidated levels, while reporting to the

regulator on the consolidated level is carried out using the

standardised approach. Pursuant to the relevant policies,

NLB Group entities must monitor and manage exposure to

market risks and report to NLB accordingly. The exposure

of an individual NLB Group entity is regularly monitored and

reported to the Assets and Liabilities Committee of NLB Group

(NLB GroupALCO).

6.2.1.Currency risk (FX)

Foreign currency risk (FX) is a risk of the potential losses

from the open FX positions due to the changes of the foreign

currency rates. The exposures of NLB to the movement of the

FX rates have impact on the financial position and cash flows

of the Bank. The Bank measures and manages the FX risk with

a usage of combination of sensitivity analysis, VaR, scenarios,

and stress-testing.

In the trading book, similar to the other market risks, risk is

managed on the basis of VaR limits which are approved by

the Management Board of the Bank and in accordance to the

adopted policy of managing market risk in the trading book of

NLB. Trading FX risk is managed on an integrated basis at a

portfoliolevel.

NLB monitors and manages FX risk in the banking book

according to the policy of managing FX risk in NLB. The

policy is primarily composed to protect Common Equity

Tier 1 against the negative effects of the volatility of the FX

rates, whilst limiting the volatility in the income statement. FX

exposures in banking book result from core banking business

activities.

Each member is responsible for its own currency risk policy,

which also includes a limit system and is in line with the parent

Bank’s guidelines and standards, as well as local regulatory

requirements. Policies are confirmed by either the local

Management Board or Supervisory Board. NLB monitors and

manages NLB Group currency risk exposure on a monthly

basis for each member and on the consolidated level.

NLB Group banks follow the guidelines for managing FX

lending in NLB Group. The guidelines’ goal is to address

risks stemming from the potential excessive growth of FX

lending, to identify hidden risks, and tail-event risks related

to FX lending, to mitigate the respective risk, to internalise the

respective costs, and to hold adequate capital with respect to

FX lending.

The positions of all currencies in the statement of financial

position of NLB, for which a daily limit is set, are monitored

daily. FX positions are managed on the currency level so that

they are always within the limits.

Regarding structural FX positions on a consolidation level,

assets, and liabilities held in foreign operations are translated

into euro currency at the closing FX rate on the reporting

date. Foreign exchange differences of non-euro assets and

liabilities against euro are recognised in OCI, and therefore

affect shareholder’s equity and CET1 capital. NLB Group ALM

employs strategies to manage this foreign currency exposure,

including matched funding of assets and liabilities.

Exposure to currency risks is discussed at daily liquidity

meetings and monthly meetings of the ALCO committee of the

NLB Group, and quarterly on the consolidated level.

![]()

298

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

a)Analysis of financial instruments by currency exposure

in EUR thousands

NLB Group

31 Dec 2021EURRSDUSDCHFOtherTotal

Financial assets

Cash, cash balances at central banks, and other demand deposits at banks4,035,603294,45958,367112,880503,7435,005,052

Financial assets held for trading7,678----7,678

Non-trading financial assets mandatorily at fair value through profit or loss11,0005,6894,472--21,161

Financial assets measured at fair value through other comprehensive income2,349,722802,321206,58314,99288,2423,461,860

Financial assets measured at amortised cost

- debt securities1,489,2797,16819,172-202,0071,717,626

- loans and advances to banks79,53014537,07017,2936,645140,683

- loans and advances to customers8,582,987763,85619,47868,2841,152,51610,587,121

- other financial assets61,71312,46320,8134827,192122,229

Derivatives - hedge accounting568----568

Fair value changes of the hedged items in portfolio hedge of interest rate risk7,082----7,082

Total financial assets16,625,1621,886,101365,955213,4971,980,34521,071,060

Financial liabilities

Financial liabilities held for trading7,585----7,585

Derivatives - hedge accounting35,377----35,377

Financial liabilities measured at amortised cost

- deposits from banks and central banks49,3511,4566,3702,11412,53771,828

- borrowings from banks and central banks845,649-12,882--858,531

- due to customers14,295,1981,244,161358,851179,9341,562,66517,640,809

- borrowings from other customers73,645-406--74,051

- subordinated liabilities288,519----288,519

- other financial liabilities133,55524,47126,1312,64120,080206,878

Total financial liabilities15,728,8791,270,088404,640184,6891,595,28219,183,578

Net on-balance sheet financial position896,283616,013(38,685)28,808385,0631,887,482

Derivative financial instruments(27,149)2,00244,115(24,124)(13,568)(18,724)

Net financial position869,134618,0155,4304,684371,4951,868,758

31 Dec 2020

Total financial assets14,728,7671,921,270376,572176,8901,846,78519,050,284

Total financial liabilities13,962,7291,254,761371,229175,2751,502,65317,266,647

Net on-balance sheet financial position766,038666,5095,3431,615344,1321,783,637

Derivative financial instruments30,748-651(2,303)(43,314)(14,218)

Net financial position796,786666,5095,994(688)300,8181,769,419

![]()

299

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

in EUR thousands

NLB

31 Dec 2021EURRSDUSDCHFOtherTotal

Financial assets

Cash, cash balances at central banks, and other demand deposits at banks3,165,6041,21224,18513,64845,7883,250,437

Financial assets held for trading7,682----7,682

Non-trading financial assets mandatorily at fair value through profit or loss7,888-4,472--12,360

Financial assets measured at fair value through other comprehensive income1,477,670-82,038-26,0431,585,751

Financial assets measured at amortised cost

- debt securities1,407,226-19,172-10,0261,436,424

- loans and advances to banks199,287----199,287

- loans and advances to customers5,060,091-13,93269,8081,3225,145,153

- other financial assets50,515720,755121,12692,404

Derivatives - hedge accounting568----568

Fair value changes of the hedged items in portfolio hedge of interest rate risk7,082----7,082

Total financial assets11,383,6131,219164,55483,457104,30511,737,148

Financial liabilities

Financial liabilities held for trading7,602----7,602

Financial liabilities measured at fair value through profit or loss352----352

Derivatives - hedge accounting35,377----35,377

Financial liabilities measured at amortised cost

- deposits from banks and central banks75,1491310,8782,41620,873109,329

- borrowings from banks and central banks860,597-12,882--873,479

- due to customers9,412,4525148,36455,39143,3939,659,605

- borrowings from other customers--406--406

- subordinated liabilities288,519----288,519

- other financial liabilities79,050-22,1741531,150102,527

Total financial liabilities10,759,09818194,70457,96065,41611,077,196

Net on-balance sheetfinancial position624,5151,201(30,150)25,49738,889659,952

Derivative financial instruments(15,358)-35,825(25,132)(14,076)(18,741)

Net financial position609,1571,2015,67536524,813641,211

31 Dec 2020

Total financial assets9,780,3722,289177,77163,15376,96110,100,546

Total financial liabilities9,199,76313171,28160,01558,7469,489,818

Net on-balance sheet financial position580,6092,2766,4903,13818,215610,728

Derivative financial instruments4,136-(2,491)(3,299)(12,169)(13,823)

Net financial position584,7452,2763,999(161)6,046596,905

![]()

300

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

b) FX sensitivity analysis

NLB Group and NLB

Scenarios31 Dec 202131 Dec 2020

USD+/-5.74%+/-7.89%

CHF+/-4.23%+/-4.02%

CZK+/-4.55%+/-8.57%

RSD+/-0.35%+/-0.97%

MKD+/-1.34%+/-3.46%

JPY

+/-5.66%+/-8.56%

AUD

+/-6.77%+/-10.70%

HUF+/-6.53%+/-9.63%

HRK+/-1.38%+/-2.02%

BAM

+/-0%+/-0%

in EUR thousands

NLB GroupNLB

31 Dec 2021

Effects on income

statement

Effects on other

comprehensive income

Effects on income

statement

Effects on other

comprehensive income

Appreciation of

USD454-(132)42

CHF(358)5666-

CZK11-11-

RSD22,5014-

MKD23,570285-

Other2370(17)-

Effects on comprehensive income1346,70715742

Depreciation of

USD(405)-117(38)

CHF329(520)(5)-

CZK(10)-(10)-

RSD(2)(2,484)(4)-

MKD(2)(3,476)(277)-

Other(21)(69)15-

Effects on comprehensive income(111)(6,549)(164)(38)

![]()

301

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

The effect on the other comprehensive income statement of

NLB Group has decreased by half due to the lower translation

positions in MKD and RSD currencies and due to the lower

volatility growths’ scenarios for MKD and RSD currencies.

6.2.2.Managing market risks in the trading book

Market risk exposure in the trading book arises mostly as a

result of the changes in interest rates, credit spreads, FX rates,

and equity prices.

The Management Board determines lowtotal risk appetite

and limits by the risk type. The limits are monitored daily by

the Global Risk Department.

NLB uses an internal VaR model based on the variance-

covariance method for other market risks. The daily

calculation of the VAR value is adjusted to Basel standards

(99% confidence interval, a monitored period of 250 business

days, a 10-day holding position period).

6.2.3.Interest rate risk

Interest rate risk is the risk to NLB Group’s capital and profit

or loss arising from changes in market interest rates. Interest

rate risk management of NLB Group includes all interest rate-

sensitive on and off-balance sheet assets and liabilities which

are divided into the trading and banking book according

to regulatory standards. It takes into account the positions

in each currency. Interest rate risk management in NLB

Group is adopted in accordance with the risk appetite and

risk strategy, based on general Basel standards on interest

rate management in the banking book (IRRBB; hereinafter:

‘Standards’) and European Banking Authority guidelines.

In the trading book, interest rate risk is measured on the basis of

the VaR method and BPV method, in accordance with the adopted

policy for managing market risk in the trading book of NLB.

The interest rate risk in the banking book is measured

and monitored within a framework of interest rate

risk management policy that establishes consistent

methodologies, models, and limit systems. NLB Group

manages interest rate risk exposure through application of

two main measures:

•Economic value sensitivity – using BPV method (Basis Point

Value), which measures the extent to which the economic

value of the banking book would change if interest rates

change according to the scenario.

•Sensitivity of net interest income – using EaR method

(Earnings at Risk), which measures the impact of the interest

rate change on future net interest income over a one-year

period, assuming constant balance sheet volume and

structure.

NLB Group regularly measures interest rate risk exposure in

the banking book under various standardised and additional

scenarios of changes in the level and shape of interest rate

yield curve, including all significant sources of risk, taking

into account behavioural and modelling assumptions. Part of

non-maturing deposits, which is considered as a core part is

allocated long-term by using replicating portfolio. Optionality

risk is mainly derived from behavioural options, reflected in

prepayments and withdrawals, and embedded options such

as caps and floors. Moreover, considering expected cash flows,

non-performing exposures, as well as off-balance sheet items

are considered when measuring interest rate risk exposure.

The interest rate risk is closely measured, monitored, and

managed within approved risk limits and controls. The Group

manages interest rate positions and stabilises its interest rate

margin primarily with the pricing policy and a fund transfer

pricing policy. An important part of the interest rate risk

management is presented by the banking book securities

portfolio, whose primary purpose is to maintain adequate

liquidity reserves, while it also contributes to the stability of

the interest rate margin, which is why valuation risk has been

included in the Group’s interest rate risk management model.

in EUR thousands

NLB GroupNLB

31 Dec 2020

Effects on income

statement

Effects on other

comprehensive income

Effects on income

statement

Effects on other

comprehensive income

Appreciation of

USD(345)-(97)(11)

CHF(293)231(32)-

CZK(4)-(4)-

RSD97,09622-

MKD47,66319-

Other859189-

Effects on comprehensive income(544)15,081(3)(11)

Depreciation of

USD295-8310

CHF270(213)29-

CZK3-3-

RSD(9)(6,959)(22)-

MKD(4)(7,151)(18)-

Other(68)(89)(70)-

Effects on comprehensive income

487

(14,412)510

![]()

302

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

NLB Group also manages interest rates risk by using plain

vanilla derivative financial instruments (interest rate swaps,

overnight index swaps, cross currency swaps, and forward

rate agreements), most of which are treated according to

hedge accounting rules. Interest rate risk exposure arises

mainly from banking book positions; particularly in a current

low interest rate environment, where NLB Group recorded an

increased volume of fixed interest rate loans and long-term

banking book securities on the assets side and transformation

of deposits from term to sight.

Each member of NLB Group is responsible for its own interest

rate risk policy, which includes the limit system and is in line

with the parent Bank’s guidelines and standards, as well

as with the local regulatory requirements. NLB regularly

monitors the interest rate risk exposure of each individual

member of NLB Group in accordance with the Standards

for Risk Management in NLB Group. The aforementioned

document comprises guidelines for uniform and effective

interest rate risk management within individual NLB Group

members.

in EUR thousands

31 Dec 2021NLB Group

Currency1 - 3 years3 - 5 years5 - 10 years

Over 10 Years

EUR

(2,404,620)

1,211,2481,573,325

446,585

RSD203,340341,21462,4581,912

MKD141,26121,96013,8359,378

Other(32,296)124,13266,7263,234

in EUR thousands

31 Dec 2020NLB Group

Currency1 - 3 years3 - 5 years5 - 10 years

Over 10 Years

EUR(1,856,327)816,9801,397,446279,265

RSD216,751175,362167,139-

MKD74,78843,7255,22411,032

Other(134,917)49,45116,095(2,886)

in EUR thousands

31 Dec 2021NLB

Currency1 - 3 years3 - 5 years5 - 10 years

Over 10 Years

EUR(1,803,603)815,3561,203,636389,570

Other1,62632,3251,2426,627

in EUR thousands

31 Dec 2020NLB

Currency1 - 3 years3 - 5 years5 - 10 years

Over 10 Years

EUR(1,479,227)451,0081,071,925227,828

Other(9,471)9,1715,628(7)

Interest rate risk in the banking book is measured, monitored,

and reported by the Global Risk Department (weekly in the

case of NLB and monthly on Group level), while positions are

managed by Financial Markets. Exposure to interest rate risk

is discussed on ALCO monthly on NLB’s individual level and

quarterly on the consolidated level.

a)Analysis of financial instruments according tothe

exposure to interest rate risk

The following table presents open net interest rate risk

positions by the most important currencies of NLB Group.

Financial instruments without maturity such as sight deposits

are presented in the first gap irrespective of their behavioural

characteristics and the NLB Group’s expectations.

![]()

303

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

b) Net interest income sensitivity analysis and an economic

view of interest rate risk in the banking book

The analysis of interest income sensitivity for the horizon of the

next 12 months assumes a sudden parallel interest rate shock

down by 50 basis points or 100 basis points. The analysis

assumes that the positions used remain unchanged.

The assessment of the impact of a change in interest rates of

50/100 basis points on the amount of net interest income of

the banking book position:

in EUR thousands

NLB GroupNLB

31 Dec 202131 Dec 202031 Dec 202131 Dec 2020

Net interest income sensitivity18,52013,8526,6687,493

Net interest income sensitivity - as % of Equity0.94%0.78%0.49%0.55%

in EUR thousands

NLB GroupNLB

31 Dec 202131 Dec 202031 Dec 202131 Dec 2020

Interest risk in banking book - EVE126,651128,37084,13082,116

Interest risk in banking book - EVE as % of Equity6.42%7.27%6.14%5.98%

The values in the table are calculated on short-term interest

rate gaps, where the applied parallel interest rate shock down

by 50/100 basis points represents a realistic and practical

scenario. The calculations of the sensitivity of net interest

income are implemented in technological support.

The ‘EVE’ (Economic Value of Equity) method is a measure

of the sensitivity of changes in market interest rates on the

economic value of financial instruments. The EVE represents

the present value of net future cash flows and provides a

comprehensive view of the possible long-term effects of

changing interest rates at least under the six prescribed

standardised interest rate shock scenarios or more if

necessary, according to the situation on financial markets.

Calculations are considering behavioural and automatic

options, as well as the allocation of non-maturing deposits.

The assessment of the impact of a change in interest rates of

200 basis points on the economic value of the banking book

position:

The applied sudden parallel interest rate shock up is by 200

basis points, which represents a “worst case” scenario for NLB

Group. The calculation takes into the account allocation of the

core part of non-maturing deposits and other behavioural

assumptions.

Exposure to the interest rate risk of the banking book mainly

arises from investments in long-term debt securities and

loans with fixed interest rate, as well as from transformation of

term to sight deposits due to a low interest rate environment.

Long-term interest positions of other members in NLB Group,

which present a majority of their exposure to interest-rate risk

(an economic point of view), mainly arise from a portfolio of

mortgage loans with a fixed interest rate.

![]()

304

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

6.3.

Liquidity risk

Liquidity risk is the risk of the NLB Group being unable

to fulfil current or future expected and unexpected cash

requirements, across all time horizons. The risk may stem from

the reduction in funding sources or a reduction in the liquidity

of certain assets.

Liquidity risk is related to funding liquidity risk (the NLB

Group’s liquidity on the liabilities-side) and market liquidity

risk (counterbalancing capacity on the assets-side). On

the liabilities-side, liquidity risk can result in a loss if the

Bank is unable to settle all its liabilities or when the Bank,

because of its incapacity to provide sufficient funds to settle

its obligations, is forced to raise the necessary funds at a

cost which significantly exceeds the normal cost. On the

assets-side, the liquidity risk is related to the market value of

counterbalancing capacity and arises in case of significant

reduction of market value of an individual financial instrument

and may result in insufficient value of counterbalancing

capacity to cover the NLB Group’s liquidity needs.

Intraday liquidity risk is the capacity required during

the business day to enable financial institutions to make

payments andsettle obligations.

In the risk identification process, first the reasons for the

realisation of each identified material risk are analysed and

grouped together in short risk descriptions. Material risks

are then classified into three groups based on what part of

liquidity is affected by the realisation of the material risks:

liabilities side, assets side, intraday liquidity risk. Based on the

identified material risks, key liquidity risk drivers are defined.

Key risk drivers of the liquidity position are factors that are

expected to trigger a substantial deterioration of the Group’s

liquidity position. This deterioration may take place in the form

of an increase in outflows, a decrease in inflows or a decrease

in the liquidity value of the counterbalancing capacity.

Liquidity risk is defined as an important risk type for NLB Group,

and one which must be managed carefully. NLB Group has

a liquidity risk management framework in place that enables

maintaining a low risk tolerance for liquidity risk. NLB Group

formulated a set of liquidity risk metrics and limits to manage

liquidity position within the requirements set by the regulator.

By maintaining a smooth long-term maturity profile, limiting

dependence on wholesale funding, and holding a solid liquidity

buffer, the NLB Group maintains a sound and robust liquidity

position, even under severely adverse conditions.

The Management Board approves the Liquidity Risk

Management Policy, which outlines the key principles for

the Bank’sliquidity management. ALCO receives a regular

report on the liquidity position and the performance against

approved limits and targets. ALCO oversees the development

of the Bank’s funding and liquidity position and decides on

liquidity risk-related issues in NLB Group.

Risk tolerance for liquidity risk is low, therefore NLB Group

must be able to provide sufficient funds for settling its liabilities

at all times, even if a specific stress scenario is realised. NLB

Group measures and manages its liquidity in two stages:

•

Static view (current exposure),

•Forward-looking and stress-testing.

The objectives of monitoring and managing liquidity risk in

NLB Group are as follows:

•ensuring a sufficient amount of liquidity for the settlement of

all NLB Group’s liabilities;

•

minimising the costs of maintaining liquidity;

•

determining an adequate amount of counterbalancing

capacity and optimal liquidity management;

•

ensuring adequate control environment;

•

ensuring an appropriate level of liquidity for different

situations and stress scenarios;

•anticipating emergencies or crisis conditions, and

implementing contingency plans in the event of

extraordinary circumstances;

•ensuring regular projections of future cash flows and stress-

testing of liquidity risk;

•

preparing proposals for establishing additional financial

assets as collateral for sources of funding.

Overall assessment of the liquidity position of NLB Group

is assessed in the Internal Liquidity Adequacy Assessment

Process (ILAAP) at least once per year for NLB Group, and

it includes a clear formal statement on liquidity adequacy,

supported by an analysis of ILAAP outcomes. The ILAAP

process is integral to risk management frameworks and is

aligned with the NLB Group’s risk appetite which is consistent

with the business model and approved by the management

board. Based on the Risk Appetite, the NLB Group prepares

a business plan and financial forecasts which are crucial for

defining internal capital needs (ICAAP process) and internal

liquidity assessment (ILAAP process). Both processes are

conducted from the normative and economic perspectives

and supplemented by the stress-testing programme.

NLB Group performs stress tests on a regular basis for a

variety of bank-specific and market-wide stress scenarios

(individually and in combination) to identify sources of

potential liquidity strain and to ensure that current exposures

remain in accordance with the NLB Group’s established

liquidity risk tolerance. Stress test outcomes are used to

adjust its liquidity risk management strategies, policies, and

positions, define minimum amount of counterbalancing

capacity, and to develop effective contingency plans.

The NLB Group has a formal liquidity contingency plan (LCP)

that clearly sets out the procedures for addressing liquidity

shortfalls in stressed situations. The plan outlines procedures

to manage a range of stress environments, establish clear

lines of responsibility, include clear invocation and escalation

procedures, and is regularly tested and updated to ensure

that it is operationally robust.

NLB Group maintains a sufficient amount of liquidity

reserves in the form of high credit quality debt securities

that are eligible for refinancing via the ECB/central bank

or on the market. In the current situation, NLB Group also

strives to follow as closely as possible the long-term trend

of diversification on both the liability and asset sides of

the balance sheet. NLB Group regularly performs stress

tests with the aim of testing the liquidity stability and the

availability of liquidity reserves in various stress situations.

In addition, special attention is given to the fulfilment of

the liquidity regulation (CRR/CRD), with monitoring and

reporting of the liquidity coverage ratio (LCR) according to

the Delegated Act and net stable funding ratio (NSFR). This

also includes monitoring and reporting of Additional Liquidity

Monitoring Metrics (ALMM) on solo and consolidated levels.

In accordance with theCommissionImplementingRegulation

(EU), NLB Group regularly monitors and issues quarterly

reports on asset encumbrance.

The Group manages its liquidity position (liquidity within one

day) daily, for a period of several days or weeks in advance,

based on the planning and monitoring of cash flows. Each

NLB Group member is responsible for its own liquidity position

and carries out thefollowing activities:

•

managing intraday liquidity;

•planning and monitoring cash flows;

•monitoring and complying with the liquidity regulations of

the central bank;

•adopting business decisions;

•

forming and managing liquidity reserves; and

![]()

305

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

•performing liquidity stress test to define the liquidity buffer

for smooth functioning of the payment system in stressed

circumstances.

NLB Group members actively manage liquidity over the

course of a day, taking into account the characteristics

of payment settlements to ensure the timely settlement of

liabilities in normal and stressed circumstances.

Liquidity risk management in NLB Group is under strict

monitoring by NLB as a parent bank. Reporting to NLB by

all Group members is performed daily. Global Risk gives

guidelines and defines minimal standards for Group members

regarding liquidity risk management in NLB Group Risk

Management Standards. Each Group member is responsible

for ensuring adequate liquidity via the necessary sources of

funding and their appropriate diversification and maturity,

and by managing liquidity reserves and fulfilling the

requirements of regulations governing liquidity. The exposure

of an individual NLB Group member towards liquidity risk is

regularly monitored and reported to ALCO, and to local Assets

and Liabilities Committees.

a)Managing NLB Group’s liquidity reserves

NLB Group has liquidity reserves available to cover liabilities

that fall or may become due. Liquidity reserves must become

available on short notice. Liquidity reserves are comprised

of cash, the settlement account at the central bank above

reserve requirement, debt securities, and loans eligible as

collateral for the Eurosystem’s liquidity providing operations,

on the basis of which the Bank may generate the requisite

liquidity at any time. The available liquidity reserves are

liquidity reserves decreased by the required balances for

the continuous performance ofpayment transactions,

encumbered securities, and/or credit claims for different

purposes (secured funding).

The minimum amount of liquidity reserves is determined on

the basis of the methodology pertaining to liquidity risk stress

tests. The amount represents a sum of liquidity reserves that

would enable the survival of a severe stress over a period of

one month in a combined stress scenario and comprises high

quality liquid assets according to LCR methodology, specified

in Commission Delegated Regulation (EU) 2015/61 and the

later amendments.

in EUR thousands

NLB GroupNLB

31 Dec 202131 Dec 202031 Dec 202131 Dec 2020

Liquidity reserves

Cash, cash balances at central banks\*3,567,8732,683,8513,068,1232,106,517

Trading book securities-68,809-2,450

Banking book securities4,615,3744,946,6322,479,9522,896,747

ECB eligible loans80,043582,98680,043582,986

Total available liquidity reserves8,263,2908,282,2785,628,1185,588,700

Encumbered liquidity reserves874,82752,336874,82752,336

\*above reserve requirement

As at 31 December 2021, 79.8% (31 December 2020: 81.8%)

of debt securities in the banking book of NLB Group were

government securities (includinggovernment guaranteed

bonds – GGB), and 10.0% (31 December 2020: 8.4%) were

senior unsecured bonds.

The purpose of banking book securities is to provide liquidity,

along with stabilisation of the interest margin and the interest

rate risk management, simultaneously. When managing the

portfolio, NLB Group uses conservative principles, particularly

with respect to the portfolio’s structure in terms of issuers’

ratings and asset class. The framework for managing the

banking book securities is the Policy for managing debt

securities in the Financial Markets’ banking book and the

Policy for Managing Domestic (Slovenian) Corporate Debt

Securities in Large Corporates, which clearly define the

objectives and characteristics of the associated portfolio.

The ECB-eligible credit claims comprise loans which fulfil the

high eligibility criteria set by the ECB itself and for domestic

loans are specified in the general terms about execution of

monetary policy framework (Part 4) adopted by the Bank of

Slovenia. NLB is the only member of NLB Group that complies

with the conditions set by the Eurosystem to classify as an

eligible counterparty. As such, these ECB credit claims are

included among liquidity reserves.

Members of NLB Group manage their liquid assets on a

decentralised basis in compliance with the local liquidity

regulation and validpolicies of NLB Group.

The structure of liquidity reserves is shown in the following table.

![]()

306

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

b)Encumbered/unencumbered assets

in EUR thousands

NLB GroupNLB

31 Dec 2021

Carrying amount

of encumbered

assets

Fair value of

encumbered

securities

Carrying amount

of unencumbered

assets

Fair value of

unencumbered

securities

Carrying amount

of encumbered

assets

Fair value of

encumbered

securities

Carrying amount

of unencumbered

assets

Fair value of

unencumbered

securities

Loans on demand1,083,713-3,411,743-101,854-2,970,538-

Equity instruments

780780

82,71982,719--49,18149,181

Debt securities454,939455,6314,662,2094,689,116497,515500,3282,479,9512,501,899

Loans and advances other

than loans on demand

471,556-10,378,477-464,027-4,980,705-

Other assets--1,031,360---1,155,761-

Total2,010,98819,566,5081,063,39611,636,136

in EUR thousands

NLB GroupNLB

31 Dec 2020

Carrying amount

of encumbered

assets

Fair value of

encumbered

securities

Carrying amount

of unencumbered

assets

Fair value of

unencumbered

securities

Carrying amount

of encumbered

assets

Fair value of

encumbered

securities

Carrying amount

of unencumbered

assets

Fair value of

unencumbered

securities

Loans on demand991,649-2,462,193-102,458-1,966,670-

Equity instruments70870882,25180,949--49,31849,318

Debt securities52,33655,5194,968,2055,017,86752,33655,5192,899,1972,951,975

Loans and advances other

than loans on demand

80,204-9,874,875-72,943-4,734,993-

Other assets--1,053,435---1,148,687-

Total1,124,89718,440,959227,73710,798,865

![]()

307

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

c)Collateral received – unencumbered

The nominal amount of collateral received, or own debt

securities issued not available for encumbrance are shown in

the table below:

d) Source ofencumbrance

in EUR thousands

NLB GroupNLB

31 Dec 202131 Dec 202031 Dec 202131 Dec 2020

Equity instruments242,682268,249203,620198,874

Debt securities-10,438--

Loans and advances other than loans on demand140,751146,75020,24520,165

Other assets9,839,84810,679,6304,120,9403,809,244

Total10,223,28111,105,0674,344,8054,028,283

in EUR thousands

NLB GroupNLB

31 Dec 202131 Dec 202031 Dec 202131 Dec 2020

Collateralised

liability

Assets given as

collateral

Collateralised

liability

Assets given as

collateral

Collateralised

liability

Assets given as

collateral

Collateralised

liability

Assets given as

collateral

Derivatives42,29253,74476,18791,25042,29253,74476,18791,250

Deposits746,021835,0665,97812,055790,505877,6415,97812,055

Other sources of encumbrance3,6981,122,1793,8751,021,592-132,010-124,433

Total792,0112,010,98986,0401,124,897832,7971,063,39582,165227,738

As at 31 December 2021, NLB Group and NLB had a large share

of unencumberedassets. Other sources of encumbrance

mostly relate to the obligatory reserve. On the NLB Group

level, the amount of encumbered assets equalled EUR 2,011

million (31 December 2020: EUR 1,125 million), relating to the

deposit guarantee scheme and to targeted longer-term

refinancing operations (TLTRO).

![]()

308

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

e) Non-derivative cash flows

The tables below illustrate the cash flows from non-derivative

financial instruments by residual maturities at the end of the

year. The amounts disclosed in the table are the undiscounted

contractual cash flows determined on the basis of spot rates

at the end of the reporting period.

in EUR thousands

NLB Group

31 Dec 2021Up to 1 Month1 Month to 3 Months3 Months to 1 Year

1 Yearto 5 YearsOver 5 Years

Total

Financial liabilities and credit-related commitments

Financial liabilities measured at amortised cost

- deposits from banks and central banks56,07317368415,448-72,378

- borrowings from banks and central banks954480748,49699,8426,048855,820

- due to customers15,772,513270,238859,204743,77422,54317,668,272

- borrowings from other customers6141,9296,82429,55440,86279,783

- subordinated liabilities-4,4276,80341,400318,201370,831

- other financial liabilities120,69411,67817,86655,3211,319206,878

Credit risk related commitments578,233166,473838,890470,308407,4992,461,403

Non-financial guarantees30,42672,983195,917342,42661,349703,101

Total16,559,507528,3812,674,6841,798,073857,82122,418,466

Total financial assets6,179,369820,0222,704,3228,110,0385,031,99422,845,745

in EUR thousands

NLB Group

31 Dec 2020Up to 1 Month1 Month to 3 Months3 Months to 1 Year

1 Year to 5 YearsOver 5 Years

Total

Financial liabilities and credit-related commitments

Financial liabilities measured at amortised cost

- deposits from banks and central banks52,43419,813558491-73,296

- borrowings from banks and central banks66672718,146130,82110,273160,633

- due to customers14,111,895379,1271,080,487848,23719,05916,438,805

- borrowings from other customers1,0412,8999,71943,38239,74396,784

- subordinated liabilities-4,4266,80341,400328,352380,981

- other financial liabilities112,2588,76214,40242,9173,756182,095

Credit risk related commitments563,821226,551703,691408,880424,6812,327,624

Non-financial guarantees25,17767,127154,766334,07866,198647,346

Total14,867,292709,4321,988,5721,850,206892,06220,307,564

Total financial assets5,228,895651,5412,434,5897,867,3864,621,08320,803,494

![]()

309

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

in EUR thousands

NLB

31 Dec 2021Up to 1 Month1 Month to 3 Months3 Months to 1 Year

1 Yearto 5 YearsOver 5 Years

Total

Financial liabilities and credit-related commitments

Financial liabilities measured at fair

value through profit or loss

---352-352

Financial liabilities measured at amortised cost

- deposits from banks and central banks94,326--15,197-109,523

- borrowings from banks and central banks44,569-742,58482,882-870,035

- due to customers9,303,78465,745125,834158,6378,7069,662,706

- borrowings from other customers---406-406

- subordinated liabilities-4,4276,80341,400318,201370,831

- other financial liabilities71,9424,04161625,501427102,527

Credit risk related commitments503,49296,524451,614280,201220,5801,552,411

Non-financial guarantees16,71445,786100,102240,76133,803437,166

Total10,034,827216,5231,427,553845,337581,71713,105,957

Total financial assets3,678,758308,1971,061,5884,150,7143,280,84612,480,103

in EUR thousands

NLB

31 Dec 2020Up to 1 Month1 Month to 3 Months3 Months to 1 Year

1 Year to 5 YearsOver 5 Years

Total

Financial liabilities and credit-related commitments

Financial liabilities measured at amortised cost

- deposits from banks and central banks41,635----41,635

- borrowings from banks and central banks8570413,547121,7519,561145,648

- due to customers8,412,546108,942184,159143,1154,7758,853,537

- borrowings from other customers--13--13

- subordinated liabilities-4,4266,80341,400328,352380,981

- other financial liabilities57,9136,13458223,81352788,969

Credit risk related commitments478,872143,562418,866261,282270,3331,572,915

Non-financial guarantees18,20341,59990,299245,15836,406431,665

Total9,009,254305,367714,269836,519649,95411,515,363

Total financial assets2,800,273217,3091,008,1083,878,9262,904,50610,809,122

When determining the gap between the financial liabilities

and financial assets in the maturity bucket of up to one month,

it is necessary to be aware of the fact that financial liabilities

include total demand deposits, and that NLB may apply a

stability weight of 60% to demand deposits when ensuring

compliance withthe central bank’sregulations concerning

calculation of the liquidity position. To ensure NLB Group’s

and NLB’s liquidity, and based on its approach to risk, in

previous years NLB Group compiled a substantial amount of

high-quality liquid investments, mostly government securities

and selected loans, which are accepted as adequate financial

assets by the ECB.

Liabilities and credit-related commitments are included in

maturity buckets based on their residual contractual maturity,

with the exception of the TLTRO loan, which is included based

on expected early repayment in June 2022 (note 5.15.b).

![]()

310

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

in EUR thousands

NLB Group

31 Dec 2021Up to 1 Month1 Month to 3 Months3 Months to 1 Year

1 Year to5 YearsOver 5 Years

Total

Cash, cash balances at central banks, and other demand deposits at banks5,005,052----5,005,052

Financial assets held for trading7,678----7,678

Non-trading financial assets mandatorily at fair value through profit or loss6,739-9213,34010,16121,161

Financial assets measured at fair value through other comprehensive income401,080163,233400,5881,888,222608,7373,461,860

Financial assets measured at amortised cost

- debt securities38,31719,107124,948783,028752,2261,717,626

- loans and advances to banks119,93016,8272,3741,552-140,683

- loans and advances to customers466,930547,2381,912,0384,519,7263,141,18910,587,121

- other financial assets92,5053,30977325,538104122,229

Derivatives - hedge accounting568----568

Fair value changes of hedged items in portfolio hedge of interest rate risk---1,3305,7527,082

Non-current assets held for sale--7,051--7,051

Property and equipment---89,813157,201247,014

Investment property---43,6933,93147,624

Intangible assets---29,25929,81759,076

Investments in associates and joint ventures----11,52511,525

Current income tax assets--3,948--3,948

Deferred income tax assets--

620

31,9346,42338,977

Other assets23,9839,65519,85937,56316191,221

Total assets6,162,782759,3692,473,1207,454,9984,727,22721,577,496

Financial liabilities held for trading7,585----7,585

Derivatives - hedge accounting35,377----35,377

Financial liabilities measured at amortised cost

- deposits from banks and central banks56,053-52115,254-71,828

- borrowings from banks and central banks889442751,77399,4186,009858,531

- due to customers15,771,461268,484852,576727,30820,98017,640,809

- borrowings from other customers5351,7706,18627,07438,48674,051

- subordinated liabilities-3,6891,759-283,071288,519

- other financial liabilities120,18210,65513,81737,643257182,554

- lease liabilities5121,0234,04917,6781,06224,324

Provisions7,3141,18339,91469,8631,130119,404

Current income tax liabilities2,7223,156---5,878

Deferred income tax liabilities---3,045-3,045

Other liabilities36,495

748

5,7494,8671,60949,468

Total liabilities16,039,125291,1501,676,3441,002,150352,60419,361,373

Credit risk related commitments578,233166,473838,890470,308407,4992,461,403

Non-financial guarantees30,42672,983195,917342,42661,349703,101

Total liabilities and credit-related commitments16,647,784530,6062,711,1511,814,884821,45222,525,877

f) An analysis of the statement of financial position by residual contractual maturity

![]()

311

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

in EUR thousands

NLB Group

31 Dec 2020Up to 1 Month1 Month to 3 Months3 Months to 1 Year

1 Year to5 YearsOver 5 Years

Total

Cash, cash balances at central banks, and other demand deposits at banks3,961,812----3,961,812

Financial assets held for trading16,04615,173147,2236,41284,855

Non-trading financial assets mandatorily at fair value through profit or loss6,06712024,9541,17110,08142,393

Financial assets measured at fair value through other comprehensive income352,47457,055337,2981,960,192807,2713,514,290

Financial assets measured at amortised cost

- debt securities74,54047,08776,672695,030609,7581,503,087

- loans and advances to banks154,68636,7064,3751,238-197,005

- loans and advances to customers538,078421,6651,733,2514,252,9682,673,8989,619,860

- other financial assets80,6928,3193,38020,597150113,138

Fair value changes of hedged items in portfolio hedge of interest rate risk---88512,95913,844

Non-current assets held for sale--8,658--8,658

Property and equipment---78,847170,270249,117

Investment property---41,50113,34154,842

Intangible assets---32,27429,39461,668

Investments in associates and joint ventures----7,9887,988

Current income tax assets1,656222,691--4,369

Deferred income tax assets327--28,7592,70331,789

Other assets24,5489,10954,9928,33715497,140

Total assets5,210,926595,2562,246,2727,169,0224,344,37919,565,855

Financial liabilities held for trading15,485----15,485

Derivatives - hedge accounting61,161----61,161

Financial liabilities measured at amortised cost

- deposits from banks and central banks52,43419,813163223-72,633

- borrowings from banks and central banks65871717,468129,21510,167158,225

- due to customers14,109,959375,7511,069,785825,07616,59616,397,167

- borrowings from other customers9772,7319,12041,07237,66091,560

- subordinated liabilities-3,6901,759-282,872288,321

- other financial liabilities111,1667,7039,55225,9701,345155,736

- lease liabilities1,0921,0594,85016,9472,41126,359

Provisions8,5071,18332,78579,1593,425125,059

Current income tax liabilities644358---1,002

Deferred income tax liabilities

763

--3,3014114,475

Other liabilities31,9144124,5052,4646,33745,632

Total liabilities14,394,760413,4171,149,9871,123,427361,22417,442,815

Credit risk related commitments563,821226,551703,691408,880424,6812,327,624

Non-financial guarantees25,17767,127154,766334,07866,198647,346

Total liabilities and credit-related commitments14,983,758707,0952,008,4441,866,385852,10320,417,785

![]()

312

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

in EUR thousands

NLB

31 Dec 2021Up to 1 Month1 Month to 3 Months3 Months to 1 Year

1 Year to5 YearsOver 5 Years

Total

Cash, cash balances at central banks, and other demand deposits at banks3,250,437----3,250,437

Financial assets held for trading7,682----7,682

Non-trading financial assets mandatorily at fair value through profit or loss614293066,9394,47212,360

Financial assets measured at fair value through other comprehensive income24,77357,473141,428918,421443,6561,585,751

Financial assets measured at amortised cost

- debt securities2,82518,18290,276608,223716,9181,436,424

- loans and advances to banks91640,46350,12932,06675,713199,287

- loans and advances to customers317,315171,605676,9382,183,2391,796,0565,145,153

- other financial assets66,4546583,10022,192-92,404

Derivatives - hedge accounting568----568

Fair value changes of hedged items in portfolio hedge of interest rate risk---1,3305,7527,082

Non-current assets held for sale--4,089--4,089

Property and equipment---19,30466,81886,122

Investment property---9,181-9,181

Intangible assets---14,25515,19829,453

Investments in subsidiaries, associates and joint ventures--24,28237,984723,757786,023

Current income tax assets--3,761--3,761

Deferred income tax assets---31,902-31,902

Other assets6,984-4,869--11,853

Total assets3,678,568288,410999,1783,885,0363,848,34012,699,532

Financial liabilities held for trading7,602----7,602

Financial liabilities measured at fair value through profit or loss---352-352

Derivatives - hedge accounting35,377----35,377

Financial liabilities measured at amortised cost

- deposits from banks and central banks94,326--15,003-109,329

- borrowings from banks and central banks44,569-746,02882,882-873,479

- due to customers9,303,75565,612125,287156,3228,6299,659,605

- borrowings from other customers---406-406

- subordinated liabilities-3,6891,759-283,071288,519

- other financial liabilities71,8663,895223,4951399,271

- lease liabilities

76

1466142,0064143,256

Provisions544

672

18,50129,646-49,363

Other liabilities14,2161661,4423,6831,53221,039

Total liabilities9,572,33174,180893,633313,795293,65911,147,598

Credit risk related commitments503,49296,524451,614280,201220,5801,552,411

Non-financial guarantees16,71445,786100,102240,76133,803437,166

Total liabilities and credit-related commitments10,092,537216,4901,445,349834,757548,04213,137,175

![]()

313

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

in EUR thousands

NLB

31 Dec 2020Up to 1 Month1 Month to 3 Months3 Months to 1 Year

1 Year to5 YearsOver 5 Years

Total

Cash, cash balances at central banks, and other demand deposits at banks2,261,533----2,261,533

Financial assets held for trading16,381-12,449-18,831

Non-trading financial assets mandatorily at fair value through profit or loss52615826,0843,8854,45335,106

Financial assets measured at fair value through other comprehensive income91,31219,936185,583867,674551,8461,716,351

Financial assets measured at amortised cost

- debt securities66,89313,79241,502556,444599,2491,277,880

- loans and advances to banks39222,82450,27428,99055,840158,320

- loans and advances to customers322,669141,946609,4042,029,7911,460,3684,564,178

- other financial assets33,6612184020,584-54,503

Fair value changes of hedged items in portfolio hedge of interest rate risk---88512,95913,844

Non-current assets held for sale--4,454--4,454

Property and equipment---22,17369,50291,675

Investment property---8,300-8,300

Intangible assets---13,05815,04728,105

Investments in subsidiaries, associates and joint ventures--1,71965,140683,863750,722

Current income tax assets--1,923--1,923

Deferred income tax assets---29,214-29,214

Other assets6,558-5,106--11,664

Total assets2,799,925198,874926,0903,648,5873,453,12711,026,603

Financial liabilities held for trading15,500----15,500

Derivatives - hedge accounting61,161----61,161

Financial liabilities measured at amortised cost

- deposits from banks and central banks41,635----41,635

- borrowings from banks and central banks8570412,948120,2609,467143,464

- due to customers8,412,510108,772183,709141,0774,6878,850,755

- borrowings from other customers--13--13

- subordinated liabilities-3,6901,759-282,870288,319

- other financial liabilities57,8406,006-21,8991285,757

- lease liabilities731285821,9145153,212

Provisions495

669

19,46341,5331,63063,790

Other liabilities14,610

94

2,2362,4302,63122,001

Total liabilities8,603,909120,063220,710329,113301,8129,575,607

Credit risk related commitments478,872143,562418,866261,282270,3331,572,915

Non-financial guarantees18,20341,59990,299245,15836,406431,665

Total liabilities and credit-related commitments9,100,984305,224729,875835,553608,55111,580,187

![]()

314

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

g) Derivative cash flows

The table below illustrates cash flows from derivatives,

broken down into the relevant maturity buckets based on

in EUR thousands

NLB Group

31 Dec 2021Up to 1 Month1 Month to 3 Months3 Months to 1Year

1 Year to5 YearsOver 5 Years

Total

Foreign exchange derivatives

- Forwards

- Outflow(26,202)(10,460)(16,853)(12,180)-(65,695)

- Inflow26,21410,46516,86512,199-65,743

- Swaps

- Outflow(96,742)(2,362)(17,335)--(116,439)

- Inflow96,4832,36417,346--116,193

Interest rate derivatives

- Interest rate swaps and cross-currency swaps

- Outflow(1,116)(2,107)(10,153)(26,901)(12,053)(52,330)

- Inflow342373,3217,1797,28718,058

- Caps and floors

- Outflow--(1)(51)-(52)

- Inflow--252-54

Total outflow(124,060)(14,929)(44,342)(39,132)(12,053)(234,516)

Total inflow122,73113,06637,53419,4307,287200,048

residual maturities. The amounts disclosed in the table are the

contractual undiscounted cash flows prepared on the basis of

spot rates on the reporting date.

in EUR thousands

NLB Group

31 Dec 2020Up to 1 Month1 Month to 3 Months3 Months to 1 Year

1 Year to 5 YearsOver5 Years

Total

Foreign exchange derivatives

- Forwards

- Outflow(24,456)(28,334)(65,976)(13,817)-(132,583)

- Inflow24,49428,36866,04113,828-132,731

- Swaps

- Outflow(20,709)(49,105)(36,055)--(105,869)

- Inflow20,29749,11236,034--105,443

Interest rate derivatives

- Interest rate swaps and cross-currency swaps

- Outflow(692)(2,962)(11,378)(42,239)(18,643)(75,914)

- Inflow737184,3948,7772,34816,310

Total outflow(45,857)(80,401)(113,409)(56,056)(18,643)(314,366)

Total inflow44,86478,198106,46922,6052,348254,484

![]()

315

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

in EUR thousands

NLB

31 Dec 2021Up to 1 Month1 Month to 3 Months3 Months to 1 Year

1 Year to 5 YearsOver 5 Years

Total

Foreign exchange derivatives

- Forwards

- Outflow(24,891)(10,460)(16,853)(12,180)-(64,384)

- Inflow24,90210,46516,86512,199-64,431

- Swaps

- Outflow(102,036)(6,875)(17,335)--(126,246)

- Inflow101,7726,86417,346--125,982

Interest rate derivatives

- Interest rate swaps and cross-currency swaps

- Outflow(1,116)(2,107)(10,153)(26,901)(12,053)(52,330)

- Inflow342373,3217,1797,28718,058

- Caps and floors

- Outflow--(1)(51)-(52)

- Inflow--252-54

Total outflow(128,043)(19,442)(44,342)(39,132)(12,053)(243,012)

Total inflow126,70817,56637,53419,4307,287208,525

in EUR thousands

NLB

31 Dec 2020Up to 1 Month1 Month to 3 Months3 Months to 1 Year

1 Year to 5 YearsOver 5 Years

Total

Foreign exchange derivatives

- Forwards

- Outflow(23,685)(31,650)(65,976)(13,817)-(135,128)

- Inflow23,71531,68566,04113,828-135,269

- Swaps

- Outflow(24,874)(53,580)(6,063)--(84,517)

- Inflow24,82153,5926,068--84,481

Interest rate derivatives

- Interest rate swaps and cross-currency swaps

- Outflow(692)(2,962)(11,378)(42,239)(18,643)(75,914)

- Inflow737184,3948,7772,34816,310

Total outflow(49,251)(88,192)(83,417)(56,056)(18,643)(295,559)

Total inflow48,60985,99576,50322,6052,348236,060

![]()

316

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

6.4.

Management of non-financial risks

a) Operational risk

When assuming operational risks, NLB Group follows the

guideline that such risks may not materially impact its

operations and, therefore, the risk appetite for operational

risks is low to moderate. The risk is also gradually decreasing

due to the reduced complexity of operations in NLB Group,

with disinvestment process of non-core activities and

optimisation of internal processes. NLB Group has set up a

system of collecting loss events, identification, assessment,

and management of operational risks, all with the aim of

ensuring quality management of operational risks. This is

particularly validin strategic banking members.

All NLB Group banking members monitor risk appetite limits

for operational risk. The upper tolerance limit is defined as the

limit amount of net loss that an individual member still allows

in its operations. If the sum of net loss exceeds the tolerance

limit, a special treatment of major loss events is required and,

if necessary, takes additional measures for the prevention or

mitigation of the same or similar loss events are taken. The

warning and critical limit of loss events are also defined, which in

case of exceeding require escalation procedures an acceptance

of possible additional risk management measures. In addition,

the Bank does not allow certain risks in its business – for them

a so-called ‘zero tolerance’ was defined. For monitoring some

specific more important key risk indicators, that could show a

possible increase of an operational risk, the Bank developed a

specific methodology as an early warning system. Such risks

are periodically monitored in different business areas, and the

results are discussed at the Operational Risk Committee.The

latter was named as the highest decision-making authority in the

area of operational risk management. Relevant operational risk

committees were also appointed at other NLB Group banks.The

Management Board serves in this role at other subsidiaries. The

main task of the aforementioned bodies is to discuss the most

significant operational risks and loss events, and to monitor and

support the effective management of operational risks including

their mitigation within an individual entity. All NLB Group entities,

which are included in the consolidation, have adopted relevant

documents that are in line with NLB standards. In banking

members, these documents are in line with the development

of operational risk management and regularly updated. The

whole NLB Group uses uniform software support, which is also

regularly upgraded.

In NLB Group, the reported incurred net loss arising from

loss events in 2021 was higher than in the previous year,

mostly due to inclusion of the net losses arising from acquired

Komercijalna banka Group. Nevertheless, the reported

incurred net loss remained within the set tolerance limits for

operational risk.

In general, considerable attention is paid to reporting loss

events, theirmitigationmeasures, and defining operational

risks in all segments. To treat major loss events appropriately

and as soon as possible, the Bank introduced an escalation

scale for reporting bigger or more important loss events to

the top levels of decision-making at NLB and the Supervisory

Board of NLB. Additional attention is paid to the reporting of

potential loss events in order to improve the internal controls,

and thus minimise those and similar events. Furthermore,

the methodology to monitor, analyse, and report key risk

indicators is established, servicing as an early warning

system. The aim is to improve business and supporting

processes, as well enabling prompt response.

Through comprehensive identificationof operational

risks, possible future losses are identified, estimated, and

appropriately managed. Each year, special emphasis is

placed on current risks as a result of risk identification

process, including ESG risks. Additional KRIs have been

addressed for ESG risks, servicing as an early warning

system. The major operational risks are actively managed

with the measures taken to reduce them. An operational

risk profile is prepared once a year on the basis of the

operational risk identification. Special emphasis is put on

the most topical risks, among which in particular are those

with a low probability of occurrence and very high potential

financial influence. For this purpose, the Bank has developed

the methodology of stress-testing for operational risk. The

methodology is a combination of modelling loss event data

and scenario analysis for exceptional, but plausible events.

Scenario analyses are made based on experience and

knowledge of experts from various critical areas.

The capital requirement for operational risk is calculated

using the basic indicator approach at the NLB Group level and

using the standardised approach at the NLB level.

b)Business Continuity Management (BCM)

In NLB Group, business continuity management is carried out

to protect lives, goods, and reputation. Business continuity

plans are prepared to be used in the event of natural

disasters, IT disasters, epidemic/pandemic, and the undesired

effects of the environment to mitigate their consequences.

The concept of the action plan that is prepared each year

is such that the activities contribute to the upgrading or

improvement of the Business Continuity Management System.

In 2021, Business Continuity Management was upgraded

System according to external influence – we added scenarios

for most likely events which could affect the bank (earthquake,

fire, floods, sleet, epidemic, terrorism, IT disaster, cyber-

attack).

The basis for modernising the business continuity plans is the

regular annual Business Impact Analysis (BIA). On its basis,

the adequacy of the plans for office buildings, HR plans and

IT plans is checked. The best indicator of the adequacy of the

business continuity plans is testing. In 2021, only external tests

and an IT test were carried out at NLB (no evacuation and

manual procedures test because of the COVID-19 pandemic).

No major deviations were identified.

In NLB Group, know-how and methodologies are transferred

to the members (except non-core members which are in

the process of liquidation). The members have adopted

appropriate documents which are in line with the standards

of NLB and revised in accordance with the development of

business continuity management. The activity of the members

is monitored throughout the year, and expert assistance is

providedif necessary.

For more efficient functioning of the business continuity

management system in NLB Group, training courses and visits

to individual banking members are also provided. In 2021,

visits of NLB Group banking subsidiaries weresuspended

due to COVID-19 situation, nevertheless all preventive and

response measures with regard to business continuity were

sent to the members with the purpose to help and act in the

uniform way. Besides, workshops were performed to present

development of Business Continuity Management System

to all the NLB Group members to be more resilient in the

epidemic/pandemic circumstances.

With regards to IT failures, the Bank successfully used the IT

plans and instructions for manual procedures, and thus also

ensured business operations in emergency situations.

During COVID-19 pandemic in Slovenia and SEE, NLB Group

has taken measures to protect its customers and employees,

such as (but not limited to) ensuring the relevant safety

conditions and making sure that the services offered by the

Group are provided without any disruption. The NLB Group

![]()

317

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

continuously offered necessary services to clients, especially

through digital channels (mobile banking, video calls and

telebanking), which the NLB Group continues to develop at an

accelerated pace. ACrisis Management Team was activated

in the Bank and other banking members with full engagement

of the Management Board members. Special attention was

paid to continuous provision of services to clients, their

monitoring, health protection measures, and prevention of

cyber fraud.

c)Management of other types of non-financial risks

– capital risk, strategic risks, reputation risk, and

profitabilityrisk

Risks not included in the regulatory capital requirements

(standardised approach) but have or might have an important

influence on the risk profile of NLB Group, are regularly

assessed, monitored, and managed. In addition, they are

integrated into internal capital adequacy assessment process

(ICAAP). NLB Group established internal methodologies for

identifying and assessing specific types of risk, referring to

the Group’s business model or arising from other external

circumstances. If a certain risk is assessed as a materially

important risk, relevantdisposablepreventiveand mitigation

measures are applied, including regular monitoring of their

effectiveness. On this basis, internal capital is considered and

its consumption regularly monitored.

6.5.Fair value hierarchy of financial and

non-financial assets and liabilities

Fair value is the price that would be received when selling an

asset or paid to transfer a liability in an orderly transaction

between market participants at the measurement date. NLB

Group uses various valuation techniques to determine fair

value. IFRS 13 specifies a fair value hierarchy with respect to

the inputs and assumptions used to measure financial and

non-financial assets and liabilities at fair value. Observable

inputs reflect market data obtained from independent

sources, while unobservable inputs reflect the assumptions

of NLB Group. This hierarchy gives the highest priority to

observable market data when available, and the lowest

priority to unobservable market data. NLB Group considers

relevant and observable market prices in its valuations, where

possible. The fair value hierarchy comprises the following

levels:

•Level 1 – Quoted prices (unadjusted) on active markets. This

level includes listed equities, debt instruments, derivatives,

units of investment funds, and other unadjusted market

prices of assets and liabilities. When an asset or liability

may be exchanged in multiple active markets, the principal

market for the asset or liability must be determined. In the

absence of a principal market, the most advantageous

market for the asset or liability must be determined.

•Level 2 – A valuation technique where inputs are

observable, either directly (i.e., prices) or indirectly (i.e.,

derived fromprices). Level 2 includes prices quoted for

similar assets or liabilities in active markets and prices

quoted for identical or similar assets, and liabilities in

markets that are not active. The sources of input parameters

for financial instruments, such as yield curves, credit

spreads, foreign exchange rates, and the volatility of interest

rates and foreign exchange rates, is Bloomberg.

•Level 3 – A valuation technique where inputs are not based

on observable market data. Unobservable inputs are

used to the extent that relevant observable inputs are not

available. Unobservable inputs must reflect the assumptions

that market participants would use when pricing an asset or

liability.This levelincludes non-tradable shares and bonds,

and derivatives associated with these investments and

other assets and liabilities for which fair value cannot be

determined with observable market inputs.

Wherever possible, fair value is determined as an observable

market price in an active market for an identical asset or

liability. An active market is a market in which transactions for

an asset or liability are executed with sufficient frequency and

volume to provide pricing information on an ongoing basis.

Assets and liabilities measured at fair value in active markets

are determined as the market price of a unit (e.g., share) at the

measurement date, multiplied by the quantity of units owned

by NLB Group. The fair value of assets and liabilities whose

market is not active is determined using valuation techniques.

These techniques bear a different intensity level of estimates

and assumptions, depending on the availability of observable

market inputs associated with the asset or liability that is the

subject of the valuation. Unobservable inputs shall reflect the

estimates andassumptionsthat othermarket participants

would use when pricing the asset or liability.

For non-financial assets measured at fair value and not

classified at Level 1, fair value is determined based on valuation

reports provided by certified valuators. Valuations are prepared

in accordance with the International Valuation Standards (IVS).

![]()

318

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

a)Financial and non-financial assets and liabilities measured at fair value in the financial statements

in EUR thousands

31 Dec 2021NLB GroupNLB

Level 1Level 2Level 3Total fair valueLevel 1Level 2Level 3Total fair value

Financial assets

Financial instruments held for trading-7,67717,678-7,68117,682

Derivatives

-7,67717,678-7,68117,682

Derivatives - hedge accounting-568-568-568-568

Financial assets measured at fair value through other comprehensive income2,010,4851,449,8881,4873,461,8601,533,79751,7352191,585,751

Debt instruments

2,009,6991,385,2113513,395,2611,533,7977,245-1,541,042

Equity instruments

786

64,6771,13666,599-44,49021944,709

Non-trading financial assets mandatorily at fair value through profit and loss16,689-4,47221,161-7,8884,47212,360

Debt instruments

4,261--4,261----

Equity instruments

12,428-4,47216,900--4,4724,472

Loans

-----7,888-7,888

Financial liabilities

Financial instruments held for trading-7,585-7,585-7,602-7,602

Derivatives

-7,585-7,585-7,602-7,602

Derivatives - hedge accounting-35,377-35,377-35,377-35,377

Financial liabilities measured at fair value through profit or loss-----352-352

Non-financial assets

Investment properties-19,98227,64247,624-9,181-9,181

Non-current assets held for sale-7,051-7,051-4,089-4,089

Non-financial assets impaired during the year

Recoverable amount of property and equipment--2,9902,990----

Recoverable amount of intangible assets--

872872

----

Recoverable amount of investments in subsidiaries, associates and joint ventures-----2012,6182,819

![]()

319

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

in EUR thousands

31 Dec 2020NLB GroupNLB

Level 1Level 2Level 3Total fair valueLevel 1Level 2Level 3Total fair value

Financial assets

Financial instruments held for trading2,45081,619

786

84,8552,45015,595

786

18,831

Debt instruments

2,45066,356-68,8062,450--2,450

Derivatives

-15,263

786

16,049-15,595

786

16,381

Financial assets measured at fair value through other comprehensive income2,068,3171,444,1461,8273,514,2901,663,61952,458

274

1,716,351

Debt instruments

2,060,3461,385,2459003,446,4911,663,6197,585-1,671,204

Equity instruments

7,97158,90192767,799-44,873

274

45,147

Non-trading financial assets mandatorily at fair value through profit and loss13,146-29,24742,393-7,94727,15935,106

Debt instruments

2,157--2,157----

Equity instruments

10,989-4,17115,160--4,1714,171

Loans

--25,07625,076-7,94722,98830,935

Financial liabilities

Financial instruments held for trading-15,485-15,485-15,500-15,500

Derivatives

-15,485-15,485-15,500-15,500

Derivatives - hedge accounting-61,161-61,161-61,161-61,161

Non-financial assets

Investment properties-22,63232,21054,842-8,300-8,300

Non-current assets held for sale-8,658-8,658-4,454-4,454

Non-financial assets impaired during the year

Recoverable amount of property and equipment--3,8973,897----

Recoverable amount of investments in subsidiaries, associates and joint ventures-----2804,6704,950

![]()

320

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

b)Significant transfers of financial instruments between levels of valuation

NLB Group’s policy of transfers of financial instruments between levels of valuation is illustrated in the table below.

Derivatives

Fair value hierarchyEquitiesEquity stakeFundsDebt securitiesLoansEquitiesCurrencyInterest

1

market value from

exchange market

regular valuation by

fund management

company

market value from

exchange market

2

valuation modelvaluation model

valuation model

(underlying in level 1)

valuation modelvaluation model

3

valuation modelvaluation modelvaluation modelvaluation modelvaluation model

valuation model

(underlying instrument

in level 3)

Transfers

from level 1 to 3from level 1 to 3from level 1 to 2from level 2 to 3from level 2 to 3

equity excluded from

exchange market

fund management

company stops

publishing regular

valuation

debt securities excluded

from exchange market

counterparty

reclassified from

performing to NPL

underlying instrument

excluded from

exchange market

from level 1 to 3from level 3 to 1from level 1 to 2from level 3 to 2from level 3 to 2

companies in

insolvency proceedings

fund management

company starts

publishing regular

valuation

debt securities not

liquid (not trading

for 6 months)

counterparty

reclassified from

NPL to performing

underlying instrument

included in

exchange market

from level 1 to 3

from level 1 to 3

and from 2 to 3

equity not liquid (not

trading for 2 months)

companies in

insolvency proceedings

from level 3 to 1

from level 2 to 1

and from 3 to 1

equity included in

exchange market

start trading with

debt securities on

exchange market

from level 3 to 2

until valuation

parameters are

confirmed on ALCO (at

least on quarterly basis)

For 2021 and 2020, neither NLB Group nor NLB had any

significant transfers between levels ofvaluation of financial

instruments measured at fair value in financial statements.

![]()

321

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

c)Financial and non-financial assets and liabilities at Level 2

regarding the fairvalue hierarchy

Financial instruments on Level 2 of the fair value hierarchy at

NLB Group and NLB include:

•debt securities: mostly bonds not quoted on active markets

and valuated by a valuation model;

•

derivatives: derivatives except forwardderivativesand

options on equity instruments that are not quoted on active

markets;

•performing loans measured at fair value, which according

to IFRS 9 do not pass SPPI test. Fair value is calculated on

the basis of the discounted expected future cash flows with

the required rate of return; and

•

the NationalResolution Fund.

Non-financial assets on Level 2 of the fair value hierarchy at

NLB Group and NLB include investment properties.

When valuing bonds classified on Level 2, NLB Group primarily

uses the income approach based on an estimation of future

cash flows discounted to the present value.

The input parameters used in the income approach are the

risk-free yield curve and the spread over the yield curve

(credit, liquidity, country).

Fair values for derivatives are determined using a discounted

cash flow model based on the risk-free yield curve. Fair values

for options are determined using valuation models for options

(the Garman and Kohlhagen model, binomial model, and

Black-Scholes model).

At least one of the three valuation methods are used for the

valuation of investment property. The majority of investment

property is valued using the income approach where the

present value of future expected returns is assessed. When

valuing an investment property, average rents at similar

locations and capitalisation ratios such as: the risk-free

yield, risk premium, and the risk premium to account for

capital preservation are used. Rents at similar locations are

generated from various sources, like data from lessors and

lessees, web databases, and own databases. NLB Group has

observable data for all investment property at its disposal.

If observable data for similar locations are not available,

NLB Group uses data from wider locations and adjusts it

appropriately.

d) Financial and non-financial assets and liabilities at Level 3

of the fair value hierarchy

Financial instruments on Level 3 of the fair value hierarchy in

NLB Group and NLB include:

•equities: mainly financial equities that are not quoted on

active markets;

•derivative financial instruments: forward derivatives and

options on equity instruments that are not quoted on an

active organised market. Fair values for forward derivatives

are determined using the discounted cash flow model. Fair

values for equity options are determined using valuation

models for options (the Garman and Kohlhagen model,

binomial model, and Black-Scholes model). Unobservable

inputs include the fair values of underlying instruments

determined using valuation models.The source of observable

market inputs is the Bloomberg information system; and

•non-performing loans measured at fair value, which

according to IFRS 9 do not pass SPPI test. Fair value is

calculated on the basis of the discounted expected future

cash flows with the required rate of return. In defining the

expected cash flows for non-performing loans, the value of

collateral and other pay off estimates can be used.

Non-financial assets on Level 3 of the fair value hierarchy at

NLB Groupinclude investment properties.

NLBGroup usesthree valuationmethods for the valuationof

equity financial assets mentioned in first bullet: the income,

market, and cost approaches.

NLB Group selects valuation model and values of

unobservable input data within a reasonable possible range,

but uses model and input data that other market participants

would use.

At least one of the three valuation methods are used for the

valuation of investment property. The majority of investment

property is valued using the income approach where the

present value of future expected returns is assessed. When

valuing an investment property, average rents at similar

locations and capitalisation ratios such as: the risk-free

yield, risk premium and the risk premium to account for

capital preservation are used. Rents at similar locations are

generated from various sources, like data from lessors and

lessees, web databases, and own databases. NLB Group has

observable data for all investment property at its disposal.

If observable data for similar locations are not available,

NLB Group uses data from wider locations and adjusts it

appropriately.

![]()

322

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Movements of financial assets and liabilities at Level 3

in EUR thousands

Financial instruments

held for trading

Financial assets measured

at fair value through OCI

Non-trading financial assets mandatorily

at fair value through profit or loss

Total financial assets

Financial liabilities

measured at fair value

through profit or loss

NLB GroupDerivativesDebt instrumentsEquity instrumentsEquity instruments

Loans and other

financial assets

Loans and other

financial liabilities

Balance as at 1 January 2020

807

-4,1092,71614,96122,5937,998

Effects of translation of foreign

operations to presentation currency

--53--53-

Acquisition of subsidiaries-90085--985

Valuation:

- through profit or loss

(21)--1,642(2,720)(1,099)(8,006)

- recognised in other comprehensive income

--21--21-

Foreign exchange differences---(187)(48)(235)8

Increases----20,39920,399-

Decreases--(3,341)-(7,516)(10,857)-

Balance as at 31 December 2020

786

9009274,17125,07631,860-

Effects of translation of foreign

operations to presentation currency

--(2)--(2)-

Valuation:

- through profit or loss

(785)--(56)15,74714,906-

- recognised in other comprehensive income

--266--266-

Foreign exchange differences3579366-

Increases-63--3,0173,080-

Decreases-(612)(55)-(43,849)(44,516)-

Balance as at 31 December 202113511,1364,472-5,960-

![]()

323

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

in EUR thousands

Financial instruments held

for trading

Financial assets measured

at fair value through OCI

Non-trading financial assets mandatorily

at fair value through profit or loss

Total financial assets

Financial liabilities

measured at fair value

through profit or loss

NLBDerivativesEquity instrumentsEquity instruments

Loans and other

financial assets

Loans and other

financial liabilities

Balance as at 1 January 2020

807

2592,71613,05516,8377,746

Valuation:

- through profit or loss

(21)-1,642(2,831)(1,210)(7,754)

- recognised in other comprehensive income

-15--15-

Foreign exchange differences--(187)(48)(235)8

Increases---19,83319,833-

Decreases---(7,021)(7,021)-

Balance as at 31 December 2020

786

274

4,17122,98828,219-

Valuation:

- through profit or loss

(785)-(56)13,74912,908-

Foreign exchange differences--3579366-

Increases---3,0053,005-

Decreases-(55)-(39,751)(39,806)-

Balance as at 31 December 202112194,472-4,692-

NLB Group and NLB recognise the effects from valuation of

trading instruments in income statement line item ‘Gains less

losses from financial assets and liabilities held for trading,’

effects from valuation of non-trading equity instruments

and loans mandatorily measured at fair value through

profit or loss in income statement line item ‘Gains less losses

from non-trading financial assets mandatorily at fair value

through profit or loss,’ and effects from valuation of financial

assets measured at fair value through other comprehensive

income in the accumulated other comprehensive income line

item ‘Financial assets measured at fair value through other

comprehensive income.’

![]()

324

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

In 2021 and in 2020, NLB Group and NLB recognised the following unrealised gains or losses for financial instruments that were at Level 3 as at 31 December:

in EUR thousands

NLB Group

Financial assets

held for trading

Financial assets measured at

fair value through OCI

Non-trading financial assets mandatorily

at fair value through profit or loss

Financial liabilities

measured at fair value

through profit or loss

2021DerivativesEquity instrumentsEquity instruments

Loans and other

financial assets

Loans and other

financial liabilities

Items of Income statement

Gains less losses from non-trading assets

mandatorily at fair value through profit or loss

--(56)--

Foreign exchange translation gains less losses--357--

Item of Other comprehensive income

Financial assets measured at fair value

through other comprehensive income

-266---

in EUR thousands

NLB Group

Financial assets

held for trading

Financial assets measured at

fair value through OCI

Non-trading financial assets mandatorily

at fair value through profit or loss

Financial liabilities

measured at fair value

through profit or loss

2020DerivativesEquity instrumentsEquity instruments

Loans and other

financial assets

Loans and other

financial liabilities

Items of Income statement

Gains less losses from financial assets

and liabilities held for trading

(21)----

Gains less losses from non-trading assets

mandatorily at fair value through profit or loss

--1,642(2,720)8,006

Foreign exchange translation gains less losses--(187)(48)(8)

Item of Other comprehensive income

Financial assets measured at fair value

through other comprehensive income

-21---

![]()

325

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

in EUR thousands

NLB

Financial assets

held for trading

Financial assets measured at

fair value through OCI

Non-trading financial assets mandatorily at

fair value through profit or loss

Financial liabilities

measured at fair value

through profit or loss

2021DerivativesEquity instrumentsEquity instruments

Loans and other

financial assets

Loans and other

financial liabilities

Items of Income statement

Gains less losses from non-trading assets

mandatorily at fair value through profit or loss

--(56)--

Foreign exchange translation gains less losses--357--

in EUR thousands

NLB

Financial assets

held for trading

Financial assets measured at

fair value through OCI

Non-trading financial assets mandatorily at

fair value through profit or loss

Financial liabilities

measured at fair value

through profit or loss

2020DerivativesEquity instrumentsEquity instruments

Loans and other

financial assets

Loans and other

financial liabilities

Items of Income statement

Gains less losses from financial assets

and liabilities held for trading

(21)----

Gains less losses from non-trading assets

mandatorily at fair value through profit or loss

--1,642(2,831)7,754

Foreign exchange translation gains less losses--(187)(48)(8)

Item of Other comprehensive income

Financial assets measured at fair value

through other comprehensive income

-15---

Movements of non-financial assets at Level 3

in EUR thousands

NLB Group

Investment property20212020

Balance as at 1 January32,21028,933

Effects of translation of foreign operations to presentation currency19(24)

Acquisition of subsidiaries (note 5.12.c)-19,643

Additions-609

Disposals(502)(189)

Transfer from/(to) property and equipment(7,568)(62)

Transfer from/(to) non-current assets held for sale2217

Transfer from/(to) other assets1,260(16,790)

Net valuation to fair value3,41673

Disposal of subsidiary (note 5.12.b)(1,215)-

Balance as at 31 December27,64232,210

![]()

326

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

e) Fair value of financial instruments not measured at fair

value infinancial statements

Financial instruments not measured at fair value in financial

statements are not managed on a fair value basis. For

respective instruments fair values are calculated for

disclosure purposes only and do not impact NLB Group

statement of financial position or income statement.

The table below shows estimated fair values of financial

instruments not measured at fair value in the statement of

financial position.

in EUR thousands

NLB GroupNLB

31 Dec 202131 Dec 202031 Dec 202131 Dec 2020

Carrying valueFair valueCarrying valueFair valueCarrying valueFair valueCarrying valueFair value

Financial assets measured at amortised cost

- debt securities1,717,6261,745,2251,503,0871,563,1031,436,4241,461,1851,277,8801,333,840

- loans and advances to banks140,683140,843197,005197,220199,287204,743158,320165,966

- loans and advances to customers10,587,12110,751,0519,619,8609,873,1375,145,1535,235,8394,564,1784,674,069

- other financial assets122,229122,229113,138113,13892,40492,40454,50354,503

Financial liabilities measured at amortised cost

- deposits from banks and central banks71,82869,72072,63372,648109,329109,52241,63541,635

- borrowings from banks and central banks858,531849,834158,225155,673873,479863,970143,464140,702

- due to customers17,640,80917,658,68616,397,16716,414,3829,659,6059,664,6078,850,7558,860,267

- borrowings from other customers74,05173,74491,56093,0204064061313

- subordinated liabilities288,519292,130288,321281,001288,519292,130288,321281,001

- other financial liabilities206,878206,878182,095182,095102,527102,52788,96988,969

Loans andadvances to banks

The estimated fair value of deposits is based on discounted

cash flows using prevailing market interest rates for

instruments with similar credit risk and residual maturities.

The fair value of overnight deposits equals their carrying

value.

Loans andadvances to customers

The estimated fair value of loans and advances represents the

discounted amount of estimated future cash flows expected

to be received. Expected cash flows are discounted at current

market rates for debts with similar credit risk and residual

maturities to determine their fair value.

Deposits and borrowings

The fair value of sight deposits and overnight deposits equals

their carrying value. However, their actual value for NLB

Group depends on the timing and amounts of cash flows,

current market rates, and the credit risk of the depository

institution itself. A portion of sight deposits is stable, similar to

term deposits. Therefore, their economic value for NLB Group

differs from the carrying amount.

The estimated fair value of other deposits and borrowings

from customers is based on discounted cash flows using

interest rates for new deposits with similar residual maturities.

Other financial assets and liabilities

The carrying amount of other financial assets and liabilities is

a reasonable approximation of their fair value as they mainly

relate toshort-term receivables and payables.

![]()

327

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Fairvalue hierarchyof financial instruments not measured at fair valuein financial statements

in EUR thousands

31 Dec 2021NLB GroupNLB

Level 1Level 2Level 3Total fair valueLevel 1Level 2Level 3Total fair value

Financial assets measured at amortised cost

- debt securities1,434,411303,6477,1671,745,2251,358,293102,892-1,461,185

- loans and advances to banks-140,843-140,843-204,743-204,743

- loans and advances to customers-10,751,051-10,751,051-5,235,839-5,235,839

- other financial assets-122,229-122,229-92,404-92,404

Financial liabilities measured at amortised cost

- deposits from banks and central banks-69,720-69,720-109,522-109,522

- borrowings from banks and central banks-849,834-849,834-863,970-863,970

- due to customers-17,658,686-17,658,686-9,664,607-9,664,607

- borrowings from other customers-73,744-73,744-406-406

- subordinated liabilities245,70046,430-292,130245,70046,430-292,130

- other financial liabilities-206,878-206,878-102,527-102,527

in EUR thousands

31 Dec 2020NLB GroupNLB

Level 1Level 2Level 3Total fair valueLevel 1Level 2Level 3Total fair value

Financial assets measured at amortised cost

- debt securities1,267,437288,4847,1821,563,1031,254,33779,503-1,333,840

- loans and advances to banks-197,220-197,220-165,966-165,966

- loans and advances to customers-9,873,137-9,873,137-4,674,069-4,674,069

- other financial assets-113,138-113,138-54,503-54,503

Financial liabilities measured at amortised cost

- deposits from banks and central banks-72,648-72,648-41,635-41,635

- borrowings from banks and central banks-155,673-155,673-140,702-140,702

- due to customers-16,414,382-16,414,382-8,860,267-8,860,267

- borrowings from other customers-93,020-93,020-13-13

- subordinated liabilities234,62946,372-281,001234,62946,372-281,001

- other financial liabilities-182,095-182,095-88,969-88,969

![]()

328

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

6.6.Offsetting financial assets

and financial liabilities

NLB Group has entered into bilateral foreign exchange netting

arrangements with certain banks and corporates. Cash

flows from such transactions that are due on the same day

in the same currency, are settled on a net basis, i.e., a single

cash flow for each currency. The settlement of all interest

rates derivatives is also carried out by netting of both legs

of transaction. Assets and liabilities related to these netting

arrangements are not presented in a net amount in the

statement of financial position because netting rules apply to

cash flows and not to the entire financial instrument.

In 2013, NLB Group also novated certain standardised

derivatives (some interest rate swaps) to a clearing house or

central counterparty. A system of daily margins assures the

in EUR thousands

NLB Group

31 Dec 2021Amounts not set off in the statement of financial position

Financial assets/liabilities

Gross amounts of recognised

financial assets/liabilities

Impact of master netting agreementsFinancial instruments collateralNet amount

Derivatives - assets8,2399984456,796

Derivatives - liabilities42,96199841,121842

in EUR thousands

NLB Group

31 Dec 2020Amounts not set off in the statement of financial position

Financial assets/liabilities

Gross amounts of recognised

financial assets/liabilities

Impact of master netting agreementsFinancial instruments collateralNet amount

Derivatives - assets15,820608

594

14,618

Derivatives - liabilities76,64660874,8611,177

in EUR thousands

NLB

31 Dec 2021Amounts not set off in the statement of financial position

Financial assets/liabilities

Gross amounts of recognised

financial assets/liabilities

Impact of master netting agreementsFinancial instruments collateralNet amount

Derivatives - assets8,2491,0084456,796

Derivatives - liabilities42,9781,00841,121849

in EUR thousands

NLB

31 Dec 2020Amounts not set off in the statement of financial position

Financial assets/liabilities

Gross amounts of recognised

financial assets/liabilities

Impact of master netting agreementsFinancial instruments collateralNet amount

Derivatives - assets16,189

623

594

14,972

Derivatives - liabilities76,661

623

74,8611,177

mitigation and collateralisation of exposures, as well as the

daily settlement of cash flows for each currency.

All derivatives are conducted under the conditions of signed

Master Agreements (MA), with international banks ISDA MA is

in place along with CSA annex and for corporates domestic

MA is in place, which enable daily evaluation and exchange of

margining.

NLB Group and NLB haveno financial assets/liabilities set off

in the statement of financial position.

![]()

329

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

7.Analysis by segment for NLB Group

a) Segments

in EUR thousands

NLB Group

2021

Retail

Banking

in Slovenia

Corporate and

Investment

Banking

in Slovenia

Strategic

Foreign

Markets

Financial

Markets

in Slovenia

Non-Core

Members

Other activitiesUnallocatedTotal

Total net income171,046101,505361,94524,1077,2236,127-671,953

Net income from external customers

188,629110,588363,452(8,855)7,0146,091-666,919

Intersegment net income

(17,583)(9,083)(1,507)32,96220936-5,034

Net interest income79,53535,714266,80426,3771,331(401)-409,360

Net interest income from external customers

98,89844,481270,839(6,188)1,751(421)-409,360

Intersegment net interest income

(19,363)(8,767)(4,035)32,565(420)20--

Administrative expenses(104,844)(40,829)(198,589)(7,963)(10,534)(10,259)-(373,018)

Depreciation and amortisation(11,659)(4,278)(29,329)(677)(833)(619)-(47,395)

Reportable segment profit/(loss) before

impairment and provision charge

54,54356,398134,02715,467(4,144)(4,751)-251,540

Other net gains/(losses) from equity investments

in subsidiaries, associates and joint ventures

1,108------1,108

Impairment and provisions charge(6,684)30,450(20,779)3295,40339-8,758

Profit/(loss) before income tax48,96786,848113,24815,7961,259(4,712)-261,406

Owners of the parent

48,96786,848101,78415,7961,259(4,712)-249,942

Non-controlling interests

--11,464----11,464

Income tax------(13,538)(13,538)

Profit for the year236,404

Reportable segment assets2,811,2092,333,7699,797,8396,190,19395,905337,056-21,565,971

Investments in associates and joint ventures11,525------11,525

Reportable segment liabilities7,720,6931,966,5308,315,3161,231,6697,749119,416-19,361,373

Additions to non-current assets9,9724,21826,608264(10,036)2,039-33,065

![]()

330

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

in EUR thousands

NLB Group

2020

Retail

Banking

in Slovenia

Corporate and

Investment

Banking

in Slovenia

Strategic

Foreign

Markets

Financial

Markets

in Slovenia

Non-Core

Members

Other activitiesUnallocatedTotal

Total net income170,35875,185209,09139,6335,4457,958-507,670

Net income from external customers

184,75881,124213,88112,7134,5377,472-504,484

Intersegment net income

(14,400)(5,939)(4,790)26,921908486-3,186

Net interest income81,39534,007159,26123,4711,199

240

-299,573

Net interest income from external customers

96,35740,873163,255(3,126)2,012203-299,573

Intersegment net interest income

(14,962)(6,866)(3,994)26,598(813)37--

Administrative expenses(102,089)(37,878)(94,862)(6,972)(11,848)(11,047)-(264,696)

Depreciation and amortisation(12,043)(3,911)(14,162)(619)(1,011)(685)-(32,431)

Reportable segment profit/(loss) before

impairment and provision charge

56,22633,396100,06732,042(7,414)(3,774)-210,543

Other net gains/(losses) from equity investments

in subsidiaries, associates and joint ventures

874

------

874

Negative goodwill--137,858----137,858

Impairment and provisions charge(15,069)8,982(59,084)(1,267)2,854(7,770)-(71,354)

Profit/(loss) before income tax42,03142,378178,84130,775(4,560)(11,544)-277,921

Owners of the parent

42,03142,378175,79230,775(4,560)(11,544)-274,872

Non-controlling interests

--3,049----3,049

Income tax------(5,165)(5,165)

Profit for the year269,707

Reportable segment assets2,545,7142,043,3249,346,2555,218,038131,204273,332-19,557,867

Investments in associates and joint ventures7,988------7,988

Reportable segment liabilities7,367,1451,519,0677,879,089557,4024,571115,540-17,442,815

Additions to non-current assets15,6796,04713,517418

695

2,941-39,298

Segment reporting is presented in accordance with the

strategy on the basis of the organisational structure used in

management reporting of NLB Group’s results. NLB Group’s

segments are business units that focus on different customers

and markets. They are managed separately because each

business unit requires different strategies and service levels.

The business activities of NLB are divided into several

segments. Interest income and expenses are allocated between

segments on the basis of fund transfer prices (FTP). Other NLB

Group members are, based on their business activity, included

in only one segment except NLB Lease&Go which is according

to its business activities divided into two segments.

The segments of NLB Group are divided into core and non-

core segments.

The core segments are the following:

•Retail Banking in Slovenia, which includes banking with

individuals and asset management (NLB Skladi), and part of

new subsidiary NLB Lease&Go that includes operations with

retail clients, as well as the contribution to the result of the

associated company Bankart.

•Corporate and Investment Banking in Slovenia, which

includes banking with Key Corporate Clients, SMEs, Cross-

border corporate financing, Investment Banking and

Custody, Restructuring and Workout, and part of the new

subsidiary NLB Lease&Go that includes operations with

corporate clients.

![]()

331

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

•Strategic Foreign Markets, which consist of the operations

of strategic Group banks in the strategic markets (North

Macedonia, Bosnia and Herzegovina, Kosovo, Montenegro,

and Serbia). As a result of the acquisition of Komercijalna

banka Beograd at the end of the year 2020, NLB Group

acquired three banks: Komercijalna banka Beograd,

Komercijalna banka Podgorica, and Komercijalna banka

Banja Luka, as well as an investment fund company

KomBank Invest Beograd. In November 2021, the merger of

NLB Banka Podgorica and Komercijalna banka Podgorica

was finalized. Komercijalna banka Banja Luka was sold

outside the NLB Group on 9 December 2021, so it is included

in the result of the segment for 2021 with its operations until

the specified date.

•Financial Markets in Slovenia include treasury activities and

trading in financial instruments, while they also present the

results of asset and liabilities management (ALM).

•Other accounts for the Bank’s categories whose operating

results cannot be allocated to specific segments as well as

subsidiary NLB Cultural Heritage Management Institute.

Non-Core Members include the operations of non-core Group

members, namely REAM and leasing entities (except NLB

Lease&Go), NLB Srbija, and NLB Crna Gora. NLB Leasing

Ljubljana was sold to the strategic company Lease&Go within

the NLB Group in 2021. Despite the change in ownership, its

operations continue to be monitored within the segment of

non-core members.

NLB Group is primarily a financial group, and net interest

income represents the majority of its net revenues. NLB

Group’s main indicator of a segment’s efficiency is net profit

before tax.

No revenues were generated from transactions with a single

external customer that would amount to 10% or more of

Group’s revenues.

b)Geographical information

Geographical analysis includes a breakdown of items with

respect to the country in which individual NLB Group entities

are located.

in EUR thousands

RevenuesNet incomeProfit/(loss) before income taxIncome tax

NLB Group20212020202120202021202020212020

Slovenia352,053322,128301,021290,376137,85793,362(5,043)(1,154)

South East Europe458,571265,600365,649214,486121,301184,266(8,462)(3,963)

North Macedonia

87,93681,71070,15764,46643,27721,008(4,054)(1,566)

Serbia

192,04835,240165,19928,04629,405130,9122,0771,323

Montenegro

43,98331,29134,75625,0336,5082,741(1,484)(426)

Croatia

542

207

454(181)(1,019)(1)(12)

Bosnia and Herzegovina

83,08769,61652,73557,07915,23615,776(2,213)(1,572)

Kosovo

51,51247,70142,59539,40827,05614,848(2,787)(1,710)

Western Europe173

249

(378)2,248293(33)(48)

Germany

1249980488(433)--

Switzerland

161(250)(458)1,760726(33)(48)

Total810,641587,731666,919504,484261,406277,921(13,538)(5,165)

The column ‘Revenues’ includes interest and similar income,

dividend income, and fee and commission income.

The column ‘Net Income’ includes net interest income,

dividend income, net fee and commission income, the net

effect of financial instruments, foreign exchange translation,

the effect on the derecognition of assets, net operating

income, and gain less losses from non-current assets held

forsale.

![]()

332

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

in EUR thousands

Non-current assetsTotal assetsNumber of employees

NLB Group31 Dec 202131 Dec 202031 Dec 202131 Dec 202031 Dec 202131 Dec 2020

Slovenia150,829153,67111,716,27010,142,6752,6192,691

South East Europe214,380219,8869,845,1289,411,6715,5636,098

North Macedonia

37,38437,1811,758,2691,576,941

877877

Serbia

108,515109,1674,780,8434,587,6002,9013,198

Montenegro

18,32817,934775,238709,797

374

467

Croatia

3833814,0254,39067

Bosnia and Herzegovina

34,78239,5761,596,3701,654,026

942

1,086

Kosovo

14,98815,647930,383878,917463463

Western Europe305816,09811,50933

Germany

30589711,64811

Switzerland

--15,1279,86122

Total365,239373,61521,577,49619,565,8558,1858,792

in EUR thousands

RevenuesNet income

Profit/(loss) before

income tax

Income tax

NLB Group20212020202120202021202020212020

Slovenia448,559341,092387,692328,302225,706120,806(5,252)(1,221)

South East Europe459,405265,889374,776211,337146,49644,271(8,940)(3,949)

North Macedonia

87,86481,67368,42962,65843,05420,788(4,054)(1,566)

Serbia

192,77635,318161,01728,38637,536(6,761)1,5991,337

Montenegro

43,97831,37635,41724,3567,969

187

(1,484)(426)

Croatia

3145

274

468(181)(1,019)(1)(12)

Bosnia and Herzegovina

83,27569,67867,80656,79130,89516,032(2,213)(1,572)

Kosovo

51,50947,69941,83338,67827,22315,044(2,787)(1,710)

Western Europe1933586(144)2,247588(33)(34)

Germany

1249381489(432)--

Switzerland

18333(407)(225)1,7581,020(33)(34)

Total907,983607,316762,554539,495374,449165,665(14,225)(5,204)

The table below presents data on NLB Group members before intercompany eliminations and consolidation journals.

![]()

333

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

8.

Related-party transactions

A related party is a person or entity that is related to

NLB Group in such a manner that it has control or joint

control, has a significant influence, or is a member of

the key management personnel of the reporting entity.

Related parties of NLB Group and NLB include: key

management personnel (Management Board, other key

management personnel and their family members); the

Supervisory Board; companies in which members of

the Management Board, key management personnel,

or their family members have control, joint control, or a

significant influence; a major shareholder of NLB with

significant influence, subsidiaries, associates and joint

ventures.

in EUR thousands

NLB Group and NLB

Management Board and other

Key management personnel

Family members of the

Management Board and other

key management personnel

Companies in which members

of the Management Board,

key management personnel

or their family members have

control, joint control or a

significant influence

Supervisory Board

20212020202120202021202020212020

Loans issued

Balance at 1January2,2842,119444520-130305

248

Increase1,0411,4762281848919055109

Decrease(1,228)(1,311)(257)(260)(359)(220)(300)(52)

Balance at 31 December2,0972,284415444532-60305

Interest income3940786147

Deposits received

Balance at 1January1,6101,579956

871

136193323198

Increase2,0481,3925958261,625

207

321277

Decrease(1,488)(1,361)(833)(741)(1,171)(264)(139)(152)

Balance at 31 December2,1701,610718956590136505323

Interest expenses(4)(4)----(1)-

Other financial assets-2------

Other financial liabilities2,2682,7591-148--

Guarantees issued and

loan commitments

215

242

72

78

194

62333

Fee income1215678310121

Other income1316------

Other expenses-(11)--(78)(76)--

Related-party transactions with Management Board and

other key management personnel, their family members

and companies these related parties have control, joint

control, or significant influence

A number of banking transactions are entered into with

related parties within regular course of business. The volume

of related-party transactions and the outstanding balances

are as follows:

![]()

334

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Key management compensation

The remuneration for the members of the Supervisory

Board of NLB d.d. and the Management Board of NLB d.d.

is regulated in Remuneration Policy for the Members of

the Supervisory Board of NLB d.d. and the Members of the

Management Board of NLB d.d. The remuneration for the

identified employees and other employees is regulated in

Remuneration Policy for employees of NLB d.d. and NLB

Group.

In 2021, NLB d.d. in accordance with the Companies Act (ZGD-

1) and the Banking Act (ZBan-3), adopted a new Remuneration

Policy for members of the Supervisory Board of NLB d.d.

and members of the Management Board of NLB d.d., which

was adopted by the Supervisory Board of NLB d.d. and then

submitted to the General Meeting of Shareholders of NLB d.d.,

where it was voted in December 2021. Pursuant to Article 294.a

of the Companies Act (ZGD-1), the Bank must in case of every

significant change submit the Remuneration Policy to the

General Meeting of Shareholders for voting, and in any case at

least every four years.

In the Remuneration Policy and based thereon, the Bank

designates identified employees. In designating identified

employees, the internal organisation and the nature, scope

and complexity of the Bank’s activities are taken into account.

The criteria fully take into account the risks that the Bank or

the NLB Group is or could be exposed to its given risk profile

and risk appetite. The Remuneration Policy includes members

of the Supervisory Board, members of the Management

Board, senior management and other identified employees

who are included in the Policy on the basis of the Bank’s self-

assessment.

Members of the Supervisory Board may, in relation to their

function of a member of the Supervisory Board, only receive

remuneration that is compliant with therelevant resolutionsof

the Bank’s General Meeting.

The Supervisory Board members are entitled to a

remuneration for performing their function and/or attendance

fees for their membership in the Supervisory Board of the

Bank and the committees of the Supervisory Board of the

Bank, which are determined in accordance with respective

applicable resolution by the General Meeting of the Bank,

and to reimbursement of travel expenses, daily allowances,

and accommodation costs up to the amount provided by the

regulations governing reimbursement of costs related to work

and other income not included in the tax base.

The Bank’s General Meeting may determine and change

the remuneration of the members of the Supervisory Board

independently from the Remuneration Policy, and may

change, repeal, or replace any of its resolutions in relation to

the remuneration of the Supervisory Board members at any

time, or adopt a new resolution in relation to the remuneration

of the Supervisory Board members.

The performance of key management is defined by financial

and non-financial criteria. In addition to the salary determined

in their employment contract, they are entitled to the annual

variable part of the salary based on their achievement of

the financial and non-financial performance criteria, which

encompass the goals of NLB Group or NLB, the goals of the

organisational unit, and the personal goals of the employee

performing special work.

The objectives and criteria of each member of the Management

Board shall be determined each year by the Supervisory Board

NLB d.d. at the time of adoption of the Bank’s annual business

plan. The objectives and criteria for the identified employees

are determined by the Management Board.

The variable portion of receipts for a given financial year

may not exceed eight salaries for the period including 5 July

2021, while for the period as of 6 July 2021 onwards it shall

be seven salaries of a member of the Management Board in

the financial year. Other identified employees are entitled to

a variable part of remuneration according to the category

of employee in the maximum amount of three to six salaries.

Key management shall be entitled to a variable part of the

performance benefit only in proportional part to the actual

period of employment (duration of the term of office) of the

Bank during the period to which the variable part of the

performance benefit relates.

The non-deferred part of variable remuneration is paid no

later than three months after the adoption of the Annual

Report of NLB Group for the business year to which the

variable remuneration relates. Variable remuneration part

of payment of an identified employee is awarded and paid

in cash, provided that the amount does not exceed EUR 50

thousand or/and is higher than one-third of his/her total

remuneration for each financial year, and if this is permissible

in accordance with the relevant regulation.

If the variable remuneration part of payment of an identified

employee exceeds EUR 50 thousand or/and is higher than

one-third of his/her total remuneration for each financial

year and if this is permissible in accordance with the relevant

regulation, then at least 50% of the variable remuneration must

consist of instruments. The part of the variable remuneration

of an identified employee consisting of instruments shall be

awarded and paid, under the terms and conditions in the valid

Remuneration Policy, in instruments whose value is based on

the value of the share of NLB d.d. (with these instruments not

giving any dividends or other yields).

The deferred part of the variable part of the salary must be

deferred for a period of at least five years of the day on which

the non-deferred part of such variable remuneration is paid

and it is paid in proportional shares, according to the relevant

legislation.

in EUR thousands

NLB Group and NLB

Management

Board

Other key management

personnel

Supervisory

Board

202120202021202020212020

Short-term benefits1,5891,4015,4805,501705649

Cost refunds4483952634

Long-term bonuses:

- severance pay3852595108--

- other benefits547049--

- variable part of payments

394

-2,898---

Total2,3771,6688,5365,753731683

The table below shows payments in presented periods.

Short-term benefits include:

•

monetary benefits (gross salaries, supplementary

insurance, holiday allowances and other bonuses);

•non-monetary benefits (company cars, health care,

residential facilities, etc.).

The reimbursement of cost comprises food

allowances, travel expenses, and use of own

resources.

![]()

335

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

in EUR

Member20212020

Blaž BrodnjakShort-term benefits:

01.12.2012- gross salary and holiday allowance441,770384,734

- benefits and other short-term bonuses2,3102,250

Costs refunds1,3021,304

Long-term bonuses:

- other benefits1,410

940

- variable part of payments130,211-

Total577,003389,228

Andreas BurkhardtShort-term benefits:

18.09.2013- gross salary and holiday allowance405,092352,796

- benefits and other short-term bonuses32,67217,861

Costs refunds1,2901,212

Long-term bonuses:

- other benefits1,410

940

- variable part of payments122,919-

Total563,383372,809

Archibald KremserShort-term benefits:

31.07.2013- gross salary and holiday allowance420,809366,484

- benefits and other short-term bonuses34,11724,331

Costs refunds1,2491,248

Long-term bonuses:

- other benefits1,410

940

- variable part of payments126,044-

Total583,629393,003

Petr BrunclíkShort-term benefits:

18.05.2020 - 30.06.2021- gross salary and holiday allowance221,963170,517

- benefits and other short-term bonuses30,09220,647

Costs refunds

476

710

Long-term bonuses:

- severance payments385,000-

- other benefits705705

- variable part of payments14,633-

Total652,869192,579

László PelleShort-term benefits:

26.10.2016 - 31.01.2020- gross salary and holiday allowance-57,624

- benefits and other short-term bonuses-4,343

Costs refunds-129

Long-term bonuses:

- severance payments-258,750

- other benefits-117

- variable part of payments--

Total-320,963

Payments to individual members of the Management Board

![]()

336

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Payments to individual members of the Supervisory Board

in EUR

Member

20212020

Andreas KlingenSession fees--

22.06.2015Annual compensation90,00084,000

Other bonuese - benefit447388

Costs refunds4,9472,690

Primož KarpeSession fees--

11.02.2016Annual compensation96,00089,583

Other bonuese - benefit447388

Costs refunds4,6298,235

David Eric SimonSession fees--

04.08.2016Annual compensation81,00075,000

Other bonuese - benefit447388

Costs refunds5,2516,455

Gregor Rok KastelicSession fees--

10.06.2019Annual compensation81,00070,625

Other bonuese - benefit447388

Costs refunds7584,239

Shrenik Dhirajlal DavdaSession fees--

10.06.2019Annual compensation72,00066,000

Other bonuese - benefit447388

Costs refunds2,3673,917

Mark William Lane RichardsSession fees--

10.06.2019Annual compensation81,00075,000

Other bonuese - benefit447388

Costs refunds2,6433,617

Verica Trstenjak

Session fees--

15.06.2020Annual compensation65,79033,933

Other bonuese - benefit447388

Costs refunds--

Sergeja KočarSession fees--

17.06.2020Annual compensation11,8565,662

Other bonuese - benefit447500

Costs refunds-153

in EUR

Member

20212020

Bojana ŠteblajSession fees--

17.06.2020Annual compensation15,6555,255

Other bonuese - benefit447500

Costs refunds-457

Janja Žabjek DolinšekSession fees--

20.11.2020Annual compensation6,839

169

Other bonuese - benefit447-

Costs refunds--

Islam Osama Bahgat ZekrySession fees--

14.06.2021Annual compensation38,608-

Other bonuese - benefit447-

Costs refunds5,705-

Tadeja Žbontar RemsSession fees--

22.01.2021Annual compensation26,656-

Other bonuese - benefit447-

Costs refunds--

Peter GroznikSession fees--

08.09.2017 - 14.06.2021Annual compensation32,80066,000

Other bonuese - benefit-388

Costs refunds-429

Petra Kakovič BizjakSession fees--

17.06.2020 - 10.09.2020Annual compensation-7,302

Other bonuese - benefit112

Costs refunds-

178

László Zoltan UrbánSession fees--

11.02.2016 - 15.06.2020Annual compensation-31,875

Other bonuese - benefit-

Costs refunds-1,456

Alexander BayrSession fees--

04.08.2016 - 15.06.2020Annual compensation-36,000

Other bonuese - benefit-

Costs refunds-2,799

![]()

337

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Related-party transactions with subsidiaries, associates and joint ventures

in EUR thousands

NLB Group

AssociatesJoint ventures

2021202020212020

Loans issued

Balance at 1January1,1061,0668511,205

Increase89165711

Decrease(184)(125)(657)(365)

Balance at 31 December1,0111,106201851

Interest income3832411

Impairment2627

69

(23)

Deposits received

Balance at 1January3,9738423,4348,455

Effects of translation of foreign operations

to presentation currency

--3(3)

Increase7,6104,4617,70690,966

Decrease(3,616)(1,330)(7,651)(95,984)

Balance at 31 December7,9673,9733,4923,434

Interest expenses--(59)(62)

Other financial assets2019-1

Other financial liabilities1,148

596

1-

Guarantees issued and loan commitments2,03238-21

Fee income38151983

Fee expenses(13,583)(13,977)-(952)

Other income

162

1772144

Other expenses(726)(699)-(37)

![]()

338

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

in EUR thousands

NLB

SubsidiariesAssociatesJoint ventures

202120202021202020212020

Loans issued

Balance at 1January169,176160,6341,1061,0668511,174

Increase170,30898,22189165710

Decrease(89,181)(89,679)(184)(125)(657)(333)

Balance at 31 December250,303169,1761,0111,106201851

Interest income4,9065,0073832410

Impairment1,075(1,835)2627

69

(23)

Deposits

Balance at 1January69,38670,469----

Increase433,380658,253----

Decrease(418,818)(659,336)----

Balance at 31 December83,94869,386----

Interest income321----

Impairment24----

Loans received

Balance at 1January------

Increase44,484-----

Balance at 31 December44,484-----

Interest income1-----

Deposits received

Balance at 1January19,41580,8063,9738422845,418

Increase7,558,1627,934,4537,6104,46121386,850

Decrease(7,509,205)(7,995,844)(3,616)(1,330)(470)(91,984)

Balance at 31 December68,37219,4157,9673,97327284

Interest expenses(2)(21)----

Derivatives

Fair value(7)354----

Contractual amount9,78912,424----

Other financial assets25,491

948

2019-1

Impairment(8)-----

Other financial liabilities1,8608001,001480--

Guarantees issued and loan commitments31,00355,0682,03238-21

Income/(expenses) provisions for

guaranties and commitments

584(53)----

Received loan commitments

and financial guarantees

14,5416,692----

Fee income9,7206,85738151925

Fee expenses(21)(25)(10,782)(11,140)-(332)

Other income1,078

780

162

1772144

Other expenses(2,133)(1,065)(708)(664)-(37)

Gains less losses from financial assets

and liabilities held for trading

(298)1,208----

Gains less losses from non-trading

financial assets mandatorily at fair

value through profit or loss

(558)436----

![]()

339

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Related-party transactions with major shareholder with significant influence

The volumes of related party transactions with major shareholder are as follows:

in EUR thousands

NLB GroupNLB

ShareholderShareholder

2021202020212020

Loans issued

Balance at 1January23,21928,20623,21928,206

Increase13,1991,60713,1991,607

Decrease(15,884)(6,594)(15,884)(6,594)

Balance at 31 December20,53423,21920,53423,219

Interest income713720713720

Investments in securities

Balance at 1January691,868850,965597,123778,088

Increase1,247,211866,414947,581758,140

Decrease(1,392,356)(1,026,883)(1,049,482)(940,974)

Valuation(12,201)1,372(11,566)1,869

Balance at 31 December534,522691,868483,656597,123

Interest income6,0219,0246,3899,486

Interest expenses(652)(805)(652)(805)

Other financial assets659

807

659

807

Other financial liabilities4646

Guarantees issued and loan commitments1,1841,2411,1841,241

Fee income309

194

309

194

Fee expenses(27)(30)(27)(30)

Other income212206212206

Other expenses(5)(6)(5)(6)

Gains less losses from financial assets

and liabilities not measured at fair

value through profit or loss

-14,660-14,660

Gains less losses from financial assets

and liabilities held for trading

(158)43(158)43

NLB Group and NLB disclose all transactions with the major

shareholder with significant influence. For transactions with

othergovernment-related entities, NLB Groupdiscloses

individually significant transactions.

![]()

340

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

in EUR thousands

NLB Group and NLB

Amount of significant

transactions concluded

during the year

Number of significant

transactions concluded

during the year

2021202020212020

Guarantees issued and loan commitments70,000112,50011

in EUR thousands

NLB Group and NLB

Year-end balance of all

significant transactions

Number of significant

transactions at year-end

2021202020212020

Loans507,159516,05876

Debt securities measured at amortised cost72,63376,39611

Borrowings, deposits and business accounts184,26770,00631

Guarantees issued and loan commitments152,500152,50022

in EUR thousands

NLB Group and NLB

Effects in income statement

during the year

20212020

Interest income from loans3,1413,706

Fees and commissions income

241

27

Interest income from debt securities measured at amortised cost and

net valuation effects from hedge accounting

(990)1,166

Interest expenses from borrowings, deposits, and business accounts(213)(290)

![]()

341

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

9.

Events after the reporting date

The Swiss Francs Law

On 2 February 2022, the Slovenian Parliament passed the ‘Law

on limitation and distribution of foreign exchange risk between

creditors and borrowers concerning loan agreements in Swiss

francs’ (here and after the CHF Law).The CHF Law affects all loan

agreements denominated in Swiss francs (regardless of whether the

agreements are still in force) concluded between banks operating

in Slovenia (including NLB) as lenders and individuals as borrowers

in the period from 28 June 2004 to 31 December 2010, and provides

for a cap on the exchange rate between Swiss francs and the Euro

to be set at 10% volatility (the ‘FX cap’) and shall be applied from

the conclusion of any of the affected loan agreements. During the

validity of the FX cap, the value of instalments and other payments

under such loans shall equal the amount at which the FX cap has

been triggered and the lender would be required to repay any

overpayment to the relevant borrower. Further, any overpayment

on such loans by the relevant borrowers shall be subject to default

interest to be paid by the lender.

Since the CHFLaw affects civil law contractual relationships

retroactively, the constitutionality of the Law has been extensively

debated during the legislative process with a number of national

and European authorities considering the Law to violate the

Slovenian Constitution. The shareholders of affected Slovenian

banks (including NLB) submitted a joint letter to several Slovenian

and European authorities expressing great concern regarding

the Law. On 28 February 2022, the banks filed an initiative with

the Constitutional Court of the Republic of Slovenia to initiate

proceedings to assess the constitutionality of the CHF Law and a

proposal for its temporary suspension of enforcement.

The Constitutional Court of the Republic of Slovenia adopted

a decision on 10 March 2022 to suspend in whole the

implementation of the CHF Law.The decision has been adopted

unanimously. The implementation of the law has been suspended

until the final decision of the Constitutional Court on the conformity

of the CHF Law with the Constitution. During this time the

deadlines set for individual liabilities of banks do not apply. Until

the final decision of the Constitutional Court on the constitutionality

of the CHF Law is made, the NLB will act in accordance with the

applicable legislation and courts’ decisions, and will, at the same

time, exercise all legal remedies at its disposal.

Based on the assessment of the CHF Law, NLB estimated that

negative pre-tax effect on the operations of NLB and NLB Group

should not exceed EUR 70 – 75 million. Impact on NLB and NLB

Group is material but manageable given the historically limited

extent to which NLB engaged in Swiss francs lending. NLB

considers this as a non-adjusting event after the reporting period.

Acquisition of Sberbank banka d.d., Ljubljana

On the level of the European Central Bank and the Single

Resolution Board, a decision was made on 28 February 2022 to

suspend the business operations of the banking group Sberbank

Europe AG, which also had a subsidiary bank in Slovenia. At the

same time, a transitional period or short-term moratorium was

adopted, during which a solution for the Slovenian subsidiary,

Sberbank banka d.d., was found with the aim to ensure the

continuity of the business operations for all of its clients. On

1March 2022, in order to maintain financial stability in Slovenia, the

Single Resolution Board, in cooperation with the Bank of Slovenia,

adopted a scheme and resolution plan for Sberbank banka d.d.,

Ljubljana. Based on this resolution, the Bank of Slovenia issued

a decision using the instrument of sale of operation in a way that

all shares are transferred from the shareholders to the transferee.

In the process of finding a new owner of Sberbank banka d.d.,

Ljubljana, a sale agreement was concluded with NLB d.d., which

became an owner of 100% of the bank's shares as at 1 March 2022.

The purchase price for the bank was EUR 5,109 thousand and

was fully paid in cash. There are no contingent consideration

arrangements. Initial accounting for the business combination has

not yet been completed, therefore assets, liabilities, and gain on a

bargain purchase (negative goodwill) recognised as a result of the

acquisition are not disclosed.

Russian-Ukrainian conflict

In February 2022, Russia began a military invasion of Ukraine. The

Russian-Ukrainian conflict has led to quite considerable volatility in

the financial markets, in particular shifts in credit spreads, interest

rates and foreign exchange rates. Special attention is given to the

markets in the Balkans, neighbouring countries to Ukraine and

Russia and international banks with operations in Russia. The NLB

Group is closely monitoring its major bond portfolio positions,

mostly sovereigns, with a stronger connection to the Russian crisis.

Besides, the Group holds EUR 20 million of Russian government

bonds maturing in April 2022 and in September 2023. The fair

value of these securities has decreased by approximately 30% by

31 March 2022. The manner and timing of their settlement in the

given circumstances is not determined yet. Since the beginning

of the crisis, the Bank has observed credit spreads widening from

50 to 200 bps for selected positions (with the exception of Russia

where the escalation is more severe), which is currently impacting

the Bank’s FVOCI positions. Compared to 31 December 2021, the

fair value revaluation reserve has decreased by more than EUR 50

million at the NLB Group level and EUR 40 million at the NLB level

(analysis of debt securities by geographical sectors as at year-

end is disclosed in note 6.1.o). Regarding the Group’s major FX

positions, no material movements were observed so far. Current

developments, market observations and potential mitigations are

discussed at daily monitoring meetings.

Dependence on Russia and Ukraine within the country trade

balance in the NLB Group region is moderate; the highest volume

of trade is done with the EU.

CountryExport to Russia

Import from Russia

Bosnia and

Herzegovina

1.10%2.10%

Montenegro0.00%0.00%

North Macedonia0.91%1.70%

Kosovono data availableno data available

Serbia3.90%5.30%

Slovenia2.60%1.20%

Direct and indirect exposures of NLB toward Russia and Ukraine is

moderate, but on the other hand Russia's invasion of Ukraine has

increased risks globally. Effects on the global economy will occur

through three major channels:

•

commodity price shocks,

•

financial repercussions (new sanctions against Russia and

market risk aversion), and

•

security challenges associated with military conflict or through

cyberattacks.

In particular, commodity prices will have effects on the whole

corporate output leading to an increased inflation rate in NLB

Group markets.

With regards to the credit portfolio, the NLB Group carefully

monitors its clients being present or having direct and indirect

connection with Russia, Ukraine, Belarus or its neighbouring

countries.These clients are closely monitored with the intention

of identifying any significant increase in credit risk at a very early

stage. Corporate clients are still assessing the possible impacts of

this conflict on their business model and financial performance,

however at this stage these effects are not very excessive.

Moreover, the length and intensity of the Russian-Ukrainian

conflict might cause additional spill-over effects in the mid-

term period, such as raising the price of energy sources or their

availability, which may at a later period have some impact also on

other segments of the credit portfolio.

Sberbank d.d. Slovenia with its entire portfolio become a member

of the NLB Group in March 2022. The Bank strategy was focused

on the Slovenian SME segment, so the NLB Group does not expect

major direct exposures toward Russia or Ukraine. All identified

risks will be appropriately considered when assessing fair values

of assets, liabilities and contingent liabilities and final calculation of

gain on a bargain purchase (negative goodwill).

![]()

342

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

Private Banking

Trg republike 2

1000 Ljubljana, Slovenia

Tel: +386 1 476 23 66

Micro Enterprises

Trg republike 2

1000 Ljubljana, Slovenia

Tel: +386 1 476 50 01

Mobile banking

Trg republike 2

1000 Ljubljana, Slovenia

Tel: +386 1 476 44 39

Smalland Mid-corporates

Small Enterprises I

23

Trg republike 2

1000 Ljubljana, Slovenia

Tel.: +386 1 476 49 52

Small Enterprises II

24

Titova cesta 2

2000 Maribor, Slovenia

Tel.: +386 2 234 45 09

Central region

Trg republike 2

1000 Ljubljana, Slovenia

Tel.: +386 1 476 26 11

Northwest region

Ljubljanska cesta 62

1230 Domžale, Slovenia

Tel.: +386 1 724 54 75

Southwest region

Cesta Zore Perello - Godina 7

6000 Koper, Slovenia

Tel.: +386 5 610 30 29

23Until 31 December 2021.

24

Until 31 December 2021.

Nova Ljubljanska banka d.d., Ljubljana

Trg republike 2

1000 Ljubljana, Slovenia

Tel: +386 1 476 39 00, +386 1 477 20 00

E-mail: info@nlb.si

www.nlb.si

Blaž Brodnjak, CEO & CMO

Archibald Kremser, CFO

Andreas Burkhardt, CRO

Petr Brunclík, COO

22

Slovenian network

Ljubljana Area Branch

Trg republike 2

1000 Ljubljana, Slovenia

Tel: +386 1 476 23 30

Northwest and CentralSlovenia Area Branch

Ljubljanska cesta 62

1230 Domžale, Slovenia

Tel: +386 1 724 55 01

Northeast Slovenia Area Branch

Titovacesta 2

2000 Maribor, Slovenia

Tel: +386 2 234 45 04

Southeast Slovenia Area Branch

Seidlova cesta 3

8000 Novo mesto, Slovenia

Tel: +386 7 339 14 56

Southwest Slovenia

Area

Branch

Cesta Zore Perello - Godina 7

6000 Koper, Slovenia

Tel: +386 5 610 30 10

22 Until 30 June 2021.

Podravsko-Pomurskaregion

Titovacesta 2

2000 Maribor, Slovenia

Tel.: +386 2 234 45 00

Savinjsko-Koroška region

Kocenova1

3000 Celje, Slovenia

Tel.: +386 3 424 01 11

CSA & Cross-border Financing

Trg republike 2

1000 Ljubljana, Slovenia

Tel: +386 1 476 26 18

Large corporates

Institutional Investors

Trg republike 2

1000 Ljubljana, Slovenia

Tel: +386 1 476 24 92

Large Corporates

Trg republike 2

1000 Ljubljana, Slovenia

Tel: +386 1 476 26 92

Members ofNLB Group

Komercijalna Bankaa.d. Beograd

Svetog Save 14, 11000 Belgrade, Serbia

Tel: +381 11 20 18 600

Email:kontaktni.centar@kombank.com

www.kombank.com

Vlastimir Vuković, President of the Management Board

Dejan Janjatović, Deputy of the president

of the Management Board

Dragiša Stanojević, Member of the Management Board

Dubravka Djedović Negre Member of the Management Board

NLB GroupDirectory

![]()

343

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

NLB Banka a.d., Beograd

Bulevar Mihajla Pupina 165 v

11070 Belgrade, Serbia

Tel: +381 11 71 51 522

E-mail: info@nlb.rs

www.nlb.rs

Jelena Živković, President of the Management Board

Vladimir Čaprić, Member of the Management Board

NLB Banka AD Skopje

Majka Tereza 1

1000 Skopje, North Macedonia

Tel: +389 2 15 600

E-mail: info@nlb.mk

www.nlb.mk

Antonio Argir, President of the Management Board

25

Günter Friedl, Member of the Management Board

Peter Zelen, Member of the Management Board

Igor Davčevski, Member of the Management Board

NLB Banka a.d. Banja Luka

Milana Tepića 4

78000 Banja Luka, Republic of Srpska,

Bosnia and Herzegovina

Tel: +387 51 248 588

E-mail: helpdesk@nlbbl.com

www.nlb-rs.ba

Goran Babić, President of the Management Board

Marjana Usenik, Member of the Management Board

Dragan Injac, Member of the Management Board

NLB Banka d.d., Sarajevo

Ul. Koševo br. 3, 71000 Sarajevo - Centar

71000 Sarajevo, Bosnia and Herzegovina

Tel: +387 33 720 300

E-mail: info@nlb.ba

www.nlb.ba

Lidija Žigić, President of the Management Board

Denis Hasanić, Member of the Management Board

Jure Peljhan, Member of the Management Board

25Branko Greganović, President of the Management Board from 1 January

2022

NLB Banka sh.a., Prishtina

Rr. Ukshin Hoti nr. 124

10000 Prishtina, Kosovo

Tel: +383 38 744 000

E-mail: info@nlb-kos.com

https://nlb-kos.com/

Albert Lumezi, President of the Management Board

Gem Maloku, Member of the Management Board

Lavdim Koshutova, Member of the Management Board

NLB Banka a.d., Podgorica

Bulevar Stanka Dragojevića46

81000 Podgorica, Montenegro

Tel: +382 20 402 000

E-mail: info@nlb.me

www.nlb.me

Martin Leberle, CEO

26

Marko Popovič, Executive Officer

27

Dino Redžepagić, Executive Officer

28

Lana Đurasović, Executive Officer

29

KomBankInvest a.d. Beograd

Kralja Petra 19, 11000 Belgrade, Serbia

Tel.: +381 11 330 8310

E-mail: vladimir.garic@kombankinvest.com

www.kombankinvest.com

Vladimir Garić, Director

NLB Lease&Go, leasing, d.o.o., Ljubljana

Šlandrova ulica 2, 1231 Ljubljana - Črnuče, Slovenia

Tel: +386 1 586 29 10

E-mail: info@nlbleasego.si

www.nlbleasego.si

Andrej Pucer, Director

AnžePogačnik, Director

Claus-Peter Martin Mueller, Director

NLB Leasing d.o.o., Ljubljana – v likvidaciji

Šlandrova ulica 2

1231 Ljubljana - Črnuče, Slovenia

Tel: +386 1 586 29 10

E-mail: info@nlbleasing.si

Anže Pogačnik, Liquidator

26Martin Leberle is a President of the Management Board from 1 January 2022.

27 Dražen Vujošević is a Member of the Management Board from 1 January

2022.

28Dino Redžepagić is a Member of the Management Board from 1 January

2022.

29Till 31 December 2021.

NLB Leasing d.o.o. Beograd – u likvidaciji

Bulevar Mihajla Pupina 165 v

11070 Belgrade, Serbia

Tel: +381 11 222 01 01

E-mail: info@nlbleasing.rs

Veljko Tanić, Liquidator

Optima Leasing d.o.o. u likvidaciji, Zagreb

Miramarska 24

10000 Zagreb, Croatia

Tel: +385 1 61 77 225

E-mail: info@optima-leasing.hr

Vjekoslav Budimir, Liquidator

Prvi faktor d.o.o., v likvidaciji, Ljubljana

30

Slovenska cesta 17

1000 Ljubljana, Slovenia

E-mail: france.zupan@prvifaktor.si

iztok.zupanc@prvifaktor.si

France Zupan, Liquidator

Iztok Zupanc, Liquidator

Prvi faktor – faktoring d.o.o., Beograd – u likvidaciji

Bulevar Mihajla Pupina 165 v

11070 Beograd, Serbia

Tel: +381 11 222 54 00

E-mail: zeljko.atanaskovic@prvifaktor.rs

Željko Atanasković, Liquidator

Prvi faktor d.o.o. u likvidaciji, Zagreb

31

Miramarska cesta 24

10000 Zagreb, Croatia

Tel: +385 1 6165 000

E-mail: info@prvifaktor.hr

Vjekoslav Budimir, Liquidator

30FranceZupan and Iztok Zupanc areliquidators from

1 March 2021.

31Vjekoslav Budimir is liquidator from 1 March 2021.

![]()

344

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

NLB InterFinanz AGin Liquidation, Zürich

Beethovenstrasse 48

8002 Zürich, Switzerland

Tel: +41 44 283 17 15

E-mail: info@nlbinterfinanz.ch

Jean-David Barnezet Llort, Liquidator

Polona Žižmund, Liquidator

NLB InterFinanz d.o.o., Beograd – u likvidaciji

Bulevar Mihajla Pupina 165 v

11070 Belgrade, Serbia

Tel: +381 11 22 25 351

Liljana Zoraja, Liquidator

NLB Skladi, upravljanjepremoženja, d.o.o., Ljubljana

Tivolska cesta 48

1000 Ljubljana, Slovenia

Tel: +386 1 476 52 70

E-mail: info@nlbskladi.si

www.nlbskladi.si

Kruno Abramovič, President of the

Management Board

Blaž Bračič, Member of the

Management Board

Bankart d.o.o., Ljubljana

Celovška cesta 150

1000 Ljubljana, Slovenia

Tel: +386 1 583 42 02

E-mail: info@bankart.si

www.bankart.si

Aleksander Kurtevski, Director

Jure Kvaternik, Director

LHB Aktiengesellschaft, Frankfurt am Main

Große Bockenheimer Str. 33-35

60313 Frankfurt, Germany

Tel: +49 69 21 65 78 20

E-mail: info@lhb.de

Matjaž Jevnišek, President of the Management Board

PRO-REM d.o.o., Ljubljana - v likvidaciji

Čopova 3

1000 Ljubljana, Slovenia

Tel: +386 1 586 29 16

E-mail: info@prorem.si

www.nlbrealestate.com

Jovica Jakovac, Liquidator

Nataša Batagelj, Liquidator

REAM d.o.o., Podgorica

Bul. Džordža Vašingtona br. 102, I. sprat/20,

81000 Podgorica, Montenegro

Tel: +382 20 674 900

E-mail: gligor.bojic@nlb.me

Gligor Bojić, Director

Marko Furlan, Authorised Representative

REAM d.o.o., Zagreb

Miramarska 24/6

10000 Zagreb, Croatia

Tel: +385 1 56 25 914

E-mail: josip.zurga@ream-cro.com

E-mail: julijana.milic@nlb.si

Josip Žurga, Director

Julijana Milić, Director

OL Nekretnine d.o.o. u likvidaciji, Zagreb

Miramarska 24

10000 Zagreb, Croatia

Tel: +385 1 56 25 914

E-mail: vjekoslav.budimir@ream-cro.com

E-mail: ivan.strek@ream-cro.com

Vjekoslav Budimir, Liquidator

Ivan Štrek, Liquidator

REAM d.o.o., Beograd – Novi Beograd

Bulevar Mihaila Pupina 165 v

11070 Belgrade, Serbia

Tel: +381 11 22 25 374

E-mail: vladimir.vasilijevic@ream-srb.com

Vladimir Vasilijević, Director

Veljko Tanić, Director

SPV2 d.o.o., Beograd – Novi Beograd

Bulevar Mihaila Pupina 165 v

11070 Belgrade, Serbia

Tel: +381 11 22 25 374

E-mail: office@ream-srb.com

Vladimir Vasilijević, Director

Tara Hotel d.o.o., Budva

Bulevar Džordža Vašingtona 102, Podgorica

81000 Podgorica, Montenegro

Tel: +:382 20 674 900

E-mail: gligor.bojic@nlb.me

Gligor Bojić, Director

NLB Srbija d.o.o., Beograd

Bulevar Mihajla Pupina 165 v

11070 Belgrade, Serbia

Tel: +381 11 22 25 366

E-mail: office@nlbsrbija.co.rs

www.nlbsrbija.co.rs

Veljko Tanić, Director

NLB Crna Gora d.o.o., Podgorica

Bulevar Džordža Vašingtona 102, I sprat/20

81000 Podgorica, Montenegro

Tel: +382 68 886 441

E-mail: goran.lalicevic@nlb.me

Goran Laličević, Executive Director

BarbaraŠink, Authorised Representative

Marko Čelebić, Authorised Representative

S-REAM d.o.o., Ljubljana

Čopova 3

1000 Ljubljana, Slovenia

Tel: +386 (0)41 307 759

E-mail:info@s-ream.com

www.nlbrealestate.com

Jovica Jakovac, Director

Lamija Hadžiosmanović, Director

Branchesand representative offices

of NLB Group members outside their

country ofresidence

NLB InterFinanz AGin liquidation

Ljubljana Branch in liquidation

Puharjevaulica 3

1000 Ljubljana, Slovenia

Marko Čelebić, Director

Komercijalna banka, branch Kosovska Mitrovica

Čika Jovina 11, 38 220 Kosovska Mitrovica

Goran Dželajlija, Director

![]()

345

Contents

MB Statement

SB Statement

Key Highlights

Strategy

Risk Factors & Outlook

Sustainability

Performance Overview

Risk Management

Events After 2021

Financial Report

EU

European Union

EVE

Economic Value of Equity

EVS

European Valuation Standards

EWS

Early Warning System

FATF

Financial Action Task Force

FTP

Fund Transfer Pricing

FURS

Financial Administration of the Republic of Slovenia

FVOCI

Fair Value Through Other Comprehensive Income

FVTPL

Fair Value Through Profit or Loss

FX

Foreign Exchange

GDP

Gross Domestic Product

GDPR

General Data Protection Regulation

GDR

Global Depositary Receipts

GGB

Government Guaranteed Bonds

GRI GS

Global Reporting Initiative - Global Standards

HHI

Herfindahl-HirschmanIndex

HR

Human Resources

IAS

International Accounting Standard

IASB

International Accounting Standards Board

ICAAP

Internal Capital Adequacy Assessment Process

IFRIC

International Financial Reporting

Interpretations Committee

IFRS

International Financial Reporting Standard

ILAAP

Internal Liquidity Adequacy Assessment Process

IRRBB

Interest Rate Risks for Banking Book

IRS

Interest Rate Swaps

ISDA

International Swaps and Derivatives Association

IVS

International Valuation Standards

JST

Joint Supervisory Team

JV

Joint Venture

KB

Komercijalna Banka

KDD

Central Securities Clearing Corporation

KPI

Key Performance Indicator

KRI

KeyRiskIndicators

LCP

Liquidity Contingency Plan

LCR

Liquidity Coverage Ratio

LECL

Lifetime Expected Credit Losses

LGD

Loss Given Default

LPD

Lifetime Probability of a Default

LRE

Leverage Ratio Exposure

LTD

Loan-to-Deposit Ratio

M&A

Mergers and Acquisitions

MA

Master Agreements

MAR

Market Abuse Regulation

MiFID II

Markets in Financial Instruments Directive

MiFIR

Markets in Financial Instruments Regulation Rules

MIGA

Multilateral Investment Guarantee Agency

(part of the World Bank Group)

MREL

Minimum Requirement of Own

Funds and Eligible Liabilities

NACE

Statistical Classification of Economic

Activities in the European Community

NLB or the Bank

NLB d.d.

NPE

Non-Performing Exposures

NPL

Non-Performing Loans

NPS

Net Promoter Score

NPV

Net Present Value

NSFR

Net stable funding ratio

AC

Amortised Costs

ALCO

Asset and Liability Committee

ALM

Asset and Liability Management

ALMM

Additional Liquidity Monitoring Metrics

AML/CTF

Anti-Money Laundering and Counter-

Terrorism Financing

BARS

The Banking Agency of Republic of Srpska

BCM

Business Continuity Management

BIA

Business Impact Analysis

BiH

Bosnia and Herzegovina

BIS

Bank for International Settlements

BMR

Benchmarks Regulation

BoS

Bank of Slovenia

bps

Basis Points

BPV

Basis Point Value

CAGR

Compound Annual Growth Rate

CB

Central Bank

CBR

Combined Buffer Requirement

CCF

Credit Conversion Factor

CEE

Central Eastern Europe

CEO

Chief Executive Officer

CET1

Common Equity Tier 1

CFO

Chief Financial Officer

CGU

Cash-Generating Units

CIR

Cost-to-Income Ratio

CIRS

Currency Interest Rate Swaps

CISO

Chief Information Security Officer

CMO

Chief Marketing Officer

COO

Chief Operating Officer

CoR

Cost of Risk

COSO

Committee of Sponsoring Organizations

of the Treadway Commission

CRD

Capital Requirements Directive

CRM

Customer Relationship Management

CRO

Chief Risk Officer

CRR

Capital Requirements Regulation

CSA

Credit SupportAnnex

CSD

Central Security Depository

CSI

Customer Satisfaction Index

CSR

Corporate Social Responsibility

CVA

Credit Value Adjustments

DGS

Deposit Guarantee Scheme

DPS

Dividend per Share

DWH

Data Warehouse

EAD

Exposure at Default

EaR

Earnings at Risk

EBA

European Banking Authority

EBRD

European Bank for Reconstruction and Development

ECB

European Central Bank

ECL

Expected Credit Losses

ECRA

Enterprise Compliance Risk Assessment

EEA

European Economic Area

EIB

European Investment Bank

EMIR

European Market Infrastructure Regulation

EPS

Earnings Per Share

ESEF

European Single Electronic Format

ESG

Environmental, Social and Governance

ESMS

Environmental and Social Management System

OBM

Operational Business Margin

OCR

Overall Capital Requirement

OEM

Original Exposure Method

O-SII

Other Systemically Important Institutions

OU

Organisational Units

p.p.

Percentage Point(s)

P1R

Pillar 1 Requirement

P2eM

Person to e-Merchant

P2G

Pillar 2 Guidance

P2M

Person to Merchant

P2P

Person to Person

P2R

Pillar 2 Requirements

PD

Probability of Default

PEPP

Pandemic Emergency Purchase Programme

POCI

Purchased or Originated Credit-Impaired

POS

Point of Sale

PSD2

Payments Services Directive

REAM

Real Estate Asset Management

RFR

Risk-Free Rates

RICS

Royal Institution of Chartered Surveyors

ROA

Return on Assets

ROE

Return on Equity

RoS

Republic of Slovenia

RPA

Robotic Process Automation

RSD

Serbian Dinar

RWA

Risk Weighted Assets

SDG

Sustainable Development Goals

SEE

South Eastern Europe

SICR

Significant Increase of Credit Risk

SLA

Service Level Agreements

SME

Small and Medium-sized Enterprises

SPPI

Solely Payment of Principal and Interest

SRB

Single Resolution Board

SRD II

Shareholders Rights Directive

SREP

Supervisory Review and Evaluation Process

SRF

Single Resolution Fund

SSM

Single Supervisory Mechanism

TCR

Total Capital Ratio

The Group

NLB Group

TLTRO

Targeted Longer-Term Refinancing Operations

TREA

Total Risk Exposure Amount

TSCR

Total SREP Capital Requirement

UN

United Nations

UN SDG

United Nations Sustainable Development Goals

UNEP FI PRB

United Nations Environment Programme Finance

Initiative's Principles for Responsible Banking

VaR

Value-at-Risk

VAT

Value Added Tax

ZBan-3

Slovenian Banking Act

ZGD-1

Companies Act

ZPIZ

Slovenian Pension and Disability Insurance Act

ZTFI-1

Financial Instruments Market Act

ZVKNNLB

Slovenian Act for Value Protection of Republic

of Slovenia’s Capital Investment in Nova

Ljubljanska banka d.d., Ljubljana

ZVOP-2

Slovenian Personal Data Protection Act

Definitions andGlossary of Selected Terms

![]()

NLB d.d., Ljubljana

nlb.si

NLBd.d.

Production: Saatchi & Saatchi Ljubljana

Photographs: Archive NLB, Urša Premik, iStock

Copyright: NLB d.d., Ljubljana

Ljubljana, April 2022