FIRST INVESTMENT BANK AD
INDIVIDUAL FINANCIAL STATEMENTS
FOR THE YEAR ENDED 31 DECEMBER 2023
WITH INDEPENDENT AUDITORS' REPORT THEREON
1
Individual statement of profit or loss and of other comprehensive income for the year ended
31 December 2023
in thousands of BGN Note 2023 2022
Interest income 404,711 310,785
Interest expense (34,809) (40,045)
Net interest income 6 369,902 270,740
Fee and commission income 192,605 172,990
Fee and commission expense (41,056) (33,475)
Net fee and commission income 7 151,549 139,515
Net trading income 8 23,295 19,717
Other net operating income 9 (27,192) 14,195
TOTAL INCOME FROM BANKING OPERATIONS 517,554 444,167
Administrative expenses 10 (210,667) (205,113)
Other income/(expenses), net 12 (18,902) (12,960)
Profit before impairment 287,985 226,094
Allowance for impairment 11 (137,168) (135,349)
PROFIT BEFORE TAX 150,817 90,745
Income tax expense 13 (15,776) (9,540)
NET PROFIT 135,041 81,205
Other comprehensive income for the period
Items which should or may be reclassified as profit or loss
Revaluation reserve of investments in securities 9,676 (21,860)
Total other comprehensive income 9,676 (21,860)
TOTAL COMPREHENSIVE INCOME 144,717 59,345
The statement of profit or loss and of comprehensive income is to be read in conjunction with the notes to and
forming part of the financial statements set out on pages 5 to 75.
The financial statements were approved by the Management Board on 12 March 2024 and signed on its behalf
by:
Nikola Bakalov
Chief Executive Officer
Chavdar Zlatev
Executive Director
Svetozar Popov
Executive Director
Ralitsa Bogoeva
Executive Director
Ianko Karakolev
Chief Financial Officer
Audited as per the auditors' report dated 08/03/2024:
Athanasios Petropoulos
Procurator
Mazars OOD
Iva Slavkova
Registered auditor
responsible for the audit
George Trenchev, Manager
Registered auditor responsible for the
audit
ECOVIS AUDIT BULGARIA
OOD
2
Individual statement of financial position as at 31 December 2023
The statement of the financial position is to be read in conjunction with the notes to and forming part of the financial
statements set out on pages 5 to 75.
The financial statements were approved by the Management Board on 12 March 2024 and signed on its behalf by:
Nikola Bakalov
Chief Executive Officer
Chavdar Zlatev
Executive Director
Svetozar Popov
Executive Director
Ralitsa Bogoeva
Executive Director
Ianko Karakolev
Chief Financial Officer
Audited as per the auditors' report dated 08/03/2024:
Athanasios Petropoulos
Procurator
Mazars OOD
Iva Slavkova
Registered auditor
responsible for the audit
George Trenchev, Manager
Registered auditor responsible for the audit
ECOVIS AUDIT BULGARIA OOD
in BGN ‘000 Note 2023 2022
ASSETS
Cash and balances with Central Banks 14
2,325,807 1,911,371
Investments in securities 15 2,583,949 2,598,137
Loans and advances to banks and other financial institutions 16 259,718 264,984
Loans and advances to customers 17 7,158,309 6,384,541
Property and equipment 18 99,517 98,240
Intangible assets 19 23,007 14,925
Derivatives held for risk management 1,765 1,609
Repossessed assets 21 403,523 412,996
Investment Property 22 756,767 750,324
Investments in subsidiaries 23 34,579 38,526
Rights of use assets 24 121,410 124,159
Other assets 25 120,177 114,246
TOTAL ASSETS 13,888,528 12,714,058
LIABILITIES AND CAPITAL
Due to banks 26 54,326 45,703
Due to other customers 27 11,494,164 10,798,450
Liabilities evidenced by paper 28 439,634 116,487
Financial liabilities at fair value through profit and loss 3,165 8,488
Hybrid debt 29 257,871 256,861
Deferred tax liabilities 20 27,604 27,823
Current tax liabilities 2,028 398
Lease liabilities 24 121,503 124,240
Other liabilities 30 15,307 7,399
TOTAL LIABILITIES 12,415,602 11,385,849
Issued share capital 31 149,085 149,085
Share premium 31 250,017 250,017
Statutory reserve 31 39,861 39,861
Revaluation reserve of investments in securities (5,639) (15,315)
Revaluation reserve on property 4,500 4,500
Other reserves and retained earnings 31 1,035,102 900,061
TOTAL SHAREHOLDERS’ EQUITY
1,472,926 1,328,209
TOTAL LIABILITIES AND GROUP EQUITY
13,888,528 12,714,058
3
Individual statement of cash flows for the year ended 31 December 2023
in BGN ‘000
2023 2022
Net cash flow from operating activities
Net profit
135,041 81,205
Adjustment for non-cash items
Allowance for impairment
137,168 135,349
Net interest income
(369,902) (270,740)
Depreciation and amortization
12,969 12,060
Tax expense
15,776 9,540
(Profit)/loss from sale and write-off of tangible and intangible fixed assets, net
33 (5)
(Profit) from sale of other assets, net
(6,668) 1,134
(Positive) revaluation of investment property
- (14,769)
(75,583) (46,226)
Change in operating assets
Decrease in financial assets at fair value through profit or loss
33,063 (2,859)
Decrease/(increase) in financial assets at fair value in other comprehensive income
(598,563) 406,355
Decrease in loans and advances to banks and financial institutions
8,973 2,869
(Increase) in loans to customers
(1,028,541) (297,535)
(Increase) in other assets
(3,337) (43,499)
(1,588,405) 65,331
Change in operating liabilities
Increase in due to banks
8,621 15,823
Increase in amounts owed to other depositors
696,357 1,375,988
Net increase in other liabilities
5,465 42,896
710,443 1,434,707
Interest received
485,822 395,403
Interest paid
(33,450) (49,705)
Dividends received
2,348 578
Tax on profit, paid
(14,945)
(5,528)
NET CASH FLOW FROM OPERATING ACTIVITIES
(513,770) 1,794,560
Cash flow from investing activities
(Purchase) of tangible and intangible fixed assets
(27,070) (35,523)
Sale of tangible and intangible fixed assets
231 15
Sale of other assets
38,338 44,708
(Increase)/decrease of investments
602,654 (1,540,427)
NET CASH FLOW FROM INVESTING ACTIVITIES
614,153 (1,531,227)
Financing activities
Increase in borrowings
315,806 16,679
Increase/(decrease) in subordinated liabilities
1,028 (57,275)
NET CASH FLOW FROM FINANCING ACTIVITIES
316,834 (40,596)
NET INCREASE IN CASH AND CASH EQUIVALENTS
417,217 222,737
CASH AND CASH EQUIVALENTS AT THE BEGINNING OF PERIOD
2,138,377 1,915,640
CASH AND CASH EQUIVALENTS AT THE END OF PERIOD
2,555,594 2,138,377
The cash flow statement is to be read in conjunction with the notes to and forming part of the financial
statements set out on pages 5 to 75.
The financial statements were approved by the Management Board on 12 March 2024 and signed on its behalf
by:
Nikola Bakalov
Chief Executive Officer
Chavdar Zlatev
Executive Director
Svetozar Popov
Executive Director
Ralitsa Bogoeva
Executive Director
Ianko Karakolev
Chief Financial Officer
Audited as per the auditors' report dated 08/03/2024:
Athanasios Petropoulos
procurator
Mazars OOD
Iva Slavkova
Registered auditor
responsible for the audit
George Trenchev, Manager
Registered auditor responsible for the
audit
ECOVIS AUDIT BULGARIA OOD
4
Individual statement of shareholders’ equity for the year ended 31 December 2023
in BGN ‘000
Issued
share
capital
Share
premium
Other
reserves and
retained
earnings
Revaluation
reserve of
investments in
securities
Revaluation
reserve on
property
Statutory
reserve
Total
Balance at 01 January 2022 149,085 250,017 818,856 6,545 4,500 39,861 1,268,864
Total comprehensive income for the
period
Net profit for the year ended 31 December
2022 - 81,205 - - - 81,205
Other comprehensive income for the
period
Revaluation reserve of investments in
securities - - - (21,860) - - (21,860)
Balance as at 31 December 2022 149,085 250,017 900,061 (15,315) 4,500 39,861 1,328,209
Total comprehensive income for the
period
Net profit for the year ended 31 December
2022 - - 135,041 - - - 135,041
Other comprehensive income for the
period
Revaluation reserve of investments in
securities - - - 9,676 - - 9,676
Balance as at 31 December 2023 149,085 250,017 1,035,102 (5,639) 4,500 39,861 1,472,926
The statement of changes in equity is to be read in conjunction with the notes to and forming part of the financial statements
set out on pages 5 to 75.
The financial statements were approved by the Management Board on 12 March 2024 and signed on its behalf by:
Nikola Bakalov
Chief Executive Officer
Chavdar Zlatev
Executive Director
Svetozar Popov
Executive Director
Ralitsa Bogoeva
Executive Director
Ianko Karakolev
Chief Financial Officer
Audited as per the auditors' report dated 08/03/2024:
Athanasios Petropoulos
Procurator
Mazars OOD
Iva Slavkova
Registered auditor
responsible for the audit
George Trenchev, Manager
Registered auditor responsible for the
audit
ECOVIS AUDIT BULGARIA
OOD
Notes to the financial statements
5
1. Basis of preparation
(a) Statute
First Investment Bank AD (the Bank) was incorporated in 1993 in the Republic of Bulgaria and has its
registered office in Sofia, at 111P Tsarigradsko Chaussee Blvd.
The Bank has a general banking license issued by the Bulgarian National Bank (BNB) according to
which it is allowed to conduct all banking transactions permitted by Bulgarian legislation.
The Bank has foreign operations in Cyprus - a branch.
Following the successful Initial Public Offering of new shares at the Bulgarian Stock Exchange – Sofia,
on June 13th 2007 the Bank was registered as a public company in the Register of the Financial
Supervision Commission pursuant to the provisions of the Law on the Public Offering of Securities.
The Bank’s management has a dual board structure, with the Managing Board and the Supervisory
Board having the following members:
Managing Board
o Mr Nikola Bakalov – Chief Executive Officer
o Mr Svetozar Popov – Executive Director
o Mr Chavdar Zlatev – Executive Director
o Ms Ralitsa Bogoeva – Executive Director
o Mr Ianko Karakolev – Managing Board member
o Ms Nadya Koshinska – Managing Board member
Supervisory Board
o Mr Evgeni Lukanov – Supervisory Board chairperson
o Mr Jordan Skortchev – Supervisory Board member
o Ms Radka Mineva – Supervisory Board member
o Ms Maya Georgieva – Supervisory Board member
o Mr Jyrki Koskelo – Supervisory Board member
At 31 December 2023 the total number of employees was 2,408 (31 December 2022: 2,454).
The Bank’s beneficial owners are disclosed in Note 31 below.
(b) Statement of compliance
The separate financial statements were drawn up in accordance with the International Financial
Reporting Standards (IFRS) endorsed by the European Commission.
The preparation of financial statements in conformity with IFRS requires the use of certain critical
accounting estimates. It also requires management to exercise its judgement in the process of applying
the Bank’s accounting policies. The areas involving a higher degree of judgement or complexity, or
areas where assumptions and estimates are significant to the financial statements, are disclosed in Note
2 (p).
(c) Presentation
The financial statements are presented in Bulgarian Leva (BGN) rounded to the nearest thousand.
The financial statements are prepared in accordance with the fair value principle of derivative financial
instruments, financial instruments recognised at fair value in profit or loss, investment properties, as well
as assets recognised at fair value in other comprehensive income. Other financial assets and liabilities
and non-financial assets and liabilities are stated at amortised cost or historical cost convention.
Notes to the financial statements
6
The present financial statements of the Bank are not consolidated. These individual financial statements
form an integral part of the consolidated financial statements. Information about the basic earnings per
share is given in the consolidated financial statements.
(d) New standards, amendments and interpretations effective as of 01 January 2023
The following amendments to the existing standards issued by the International Accounting Standards
Board and adopted by the EU are effective for the current period:
IFRS 17 establishes the principles for the recognition, measurement, presentation and disclosure of
insurance contracts and supersedes IFRS 4 Insurance Contracts. IFRS 17 outlines a general model
which is modified for insurance contracts with direct participation features, described as the variable fee
approach. The general model is simplified if certain criteria are met by measuring the liability for
remaining coverage using the premium allocation approach. The general model uses current
assumptions to estimate the amount, timing and uncertainty of future cash flows and it explicitly
measures the cost of that uncertainty. It takes into account market interest rates and the impact of
policyholders’ options and guarantees.
The Company does not have any contracts that meet the definition of an insurance contract under IFRS
17.
IAS 1 - the amendments change the requirements in IAS 1 with regard to disclosure of accounting
policies. The amendments replace all instances of the term ‘significant accounting policies’ with ‘material
accounting policy information’. Accounting policy information is material if, when considered together
with other information included in an entity’s financial statements, it can reasonably be expected to
influence decisions that the primary users of general-purpose financial statements make on the basis of
those financial statements.
The supporting paragraphs in IAS 1 are also amended to clarify that accounting policy information that
relates to immaterial transactions, other events or conditions is immaterial and need not be disclosed.
Accounting policy information may be material because of the nature of the related transactions, other
events or conditions, even if the amounts are immaterial. However, not all accounting policy information
relating to material transactions, other events or conditions is itself material.
IAS 8 Accounting policies, Changes in Accounting Estimates and Errors - the amendments replace the
definition of a change in accounting estimates with a definition of accounting estimates.
Under the new definition, accounting estimates are “monetary amounts in financial statements that are
subject to measurement uncertainty”. The definition of a change in accounting estimates was deleted.
IAS 12 Income taxes: the amendments introduce a further exception from the initial recognition
exemption. Under the amendments, an entity does not apply the initial recognition exemption for
transactions that give rise to equal taxable and deductible temporary differences. Depending on the
applicable tax law, equal taxable and deductible temporary differences may arise on initial recognition
of an asset and liability in a transaction that is not a business combination and affects neither accounting
nor taxable profit. For example, this may occur after the recognition of a lease liability and the respective
right-of-use asset upon the application of IFRS 16 on the lease commencement date.
Following the amendments to IAS 12, an entity is required to recognise the related deferred tax asset
and liability, with the recognition of any deferred tax asset being subject to the recoverability criteria in
IAS 12.
The IASB amends the scope of IAS 12 to clarify that the Standard applies to income taxes arising from
tax law enacted or substantively enacted to implement the Pillar Two model rules published by the
OECD, including tax law that implements qualified domestic minimum top-up taxes described in those
rules.
The amendments introduce a temporary exception to the accounting requirements for deferred taxes in
IAS 12, so that an entity would neither recognise nor disclose information about deferred tax assets and
liabilities related to Pillar Two income taxes.
Following the amendments, the Company is required to disclose that it has applied the exception and
to disclose separately its current tax expense (income) related to Pillar Two income taxes.
The adoption of these amendments to the existing standards has not led to any changes in the Bank’s
accounting policies.
Notes to the financial statements
7
(e) Standards, amendments and interpretations to existing standards that are not yet effective and
have not been adopted early by the Bank
The following standards, amendments and interpretations, which have also been issued but are not yet
effective, are not expected to have a material impact on the Bank’s financial statements.
IAS 1 Presentation of Financial Statements: Classification of Liabilities as Current or Non-current,
effective as of 01 January 2024, adopted by the EU.
The amendments to IAS 1 affect only the presentation of liabilities as current or non-current in the
statement of financial position and not the amount or timing of recognition of any asset, liability, income
or expenses, or the information disclosed about those items, adopted by the EU on 19 December 2023,
published in the Official Journal on 20 December 2023
The amendments clarify that the classification of liabilities as current or non-current is based on rights
that are in existence at the end of the reporting period, specify that classification is unaffected by
expectations about whether an entity will exercise its right to defer settlement of a liability, explain that
rights are in existence if covenants are complied with at the end of the reporting period, and introduce a
definition of ‘settlement’ to make clear that settlement refers to the transfer to the counterparty of cash,
equity instruments, other assets or services.
IFRS 16 Leases: Lease Liability in a Sale and Leaseback, effective as of 1 January 2024.
The amendments require a seller-lessee to subsequently measure lease liabilities arising from a
leaseback in a way that it does not recognise any amount of the gain or loss that relates to the right of
use it retains.
The new requirements do not prevent a seller-lessee from recognising in profit or loss any gain or loss
relating to the partial or full termination of a lease.
A seller-lessee applies the amendments retrospectively in accordance with IAS 8 Accounting Policies,
Changes in Accounting Estimates and Errors to sale and leaseback transactions entered into after the
date of initial application.
Amendments to IAS 21 The Effects of Changes in Foreign Exchange Rates: Lack of Exchangeability,
effective 1 January 2025
The amendments:
Specify when a currency is exchangeable into another currency and when it is not a currency is
exchangeable when an entity is able to exchange that currency for the other currency through markets
or exchange mechanisms that create enforceable rights and obligations without undue delay at the
measurement date and for a specified purpose; a currency is not exchangeable into the other currency
if an entity can only obtain an insignificant amount of the other currency.
Specify how an entity determines the exchange rate to apply when a currency is not exchangeable
when a currency is not exchangeable at the measurement date, an entity estimates the spot exchange
rate as the rate that would have applied to an orderly transaction between market participants at the
measurement date and that would faithfully reflect the economic conditions prevailing.
Require the disclosure of additional information when a currency is not exchangeable when a
currency is not exchangeable an entity discloses information that would enable users of its financial
statements to evaluate how a currency’s lack of exchangeability affects, or is expected to affect, its
financial performance, financial position and cash flows.
The amendments also extend to conforming amendments to IFRS 1 which previously referred to, but
did not define, exchangeability.
The amendments also extend to conforming amendments to IFRS 1 which previously referred to, but
did not define, exchangeability.
Amendments to IAS 7 Statement of Cash Flows and IFRS 7 Financial Instruments: Disclosures: Supplier
Finance Arrangements, effective 1 January 2024.
The amendments add a disclosure objective to IAS 7 stating that an entity is required to disclose
information about its supplier finance arrangements that enables users of financial statements to assess
the effects of those arrangements on the entity’s liabilities and cash flows. In addition, IFRS 7 was
amended to add supplier finance arrangements as an example within the requirements to disclose
information about an entity’s exposure to concentration of liquidity risk.
To meet the disclosure objective, an entity will be required to disclose in aggregate for its supplier finance
arrangements:
Notes to the financial statements
8
The terms and conditions of the arrangements
The carrying amount, and associated line items presented in the entity’s statement of financial
position, of the liabilities that are part of the arrangements
The carrying amount, and associated line items for which the suppliers have already received
payment from the finance providers
Ranges of payment due dates for both those financial liabilities that are part of a supplier finance
arrangement and comparable trade payables that are not part of a supplier finance arrangement
Liquidity risk information
2. Significant accounting policies
(a) Income recognition
(i) Interest income
Interest income and expense is recognised in the profit or loss as it accrues, taking into account the
effective yield of the asset (liability) or an applicable floating rate. The effective interest rate is the rate
that exactly discounts the estimated future cash payments and receipts through the expected life of the
financial asset or liability to the carrying amount of the financial asset or liability. When calculating the
effective interest rate, the Bank estimates future cash flows considering all contractual terms of the
financial instrument but not future credit losses.
The calculation of the effective interest rate includes all fees paid or received as well as discount and
premiums which are an integral part of the effective interest rate. Transaction costs include incremental
costs that are directly attributable to the acquisition or issue of a financial asset or liability.
Interest income is calculated by applying the effective interest rate on the gross value of the financial
asset, except for impaired assets for which the effective interest rate is applied to the amortised cost of
the financial asset.
(ii) Fees and Commissions
Fee and commission income arises on financial services provided by the Bank and is recognised in
profit or loss when the corresponding service is provided.
(iii) Net trading income
Net gains (losses) on financial assets and liabilities held for trading includes those gains and losses
arising from disposals and changes in the fair value of financial assets and liabilities held for trading as
well as trading income in dealing with foreign currencies and exchange differences from daily revaluation
of the net open foreign currency position of the Bank.
(iv) Dividend income
Dividend income is recognised when the right to receive income is established. Usually this is the ex-
dividend date for equity securities.
(b) Basis of consolidation of subsidiaries
Investments in subsidiaries are stated at cost, minus the accrued impairment.
(c) Foreign currency transactions
(i) Functional and presentation currency
The financial statements are presented in Bulgarian leva, which is the Bank’s functional and presentation
currency.
(ii) Transactions and balances
Transactions in foreign currencies are translated into the respective functional currencies of the
operations at the spot exchange rates at the dates of the transactions. Monetary assets and liabilities
denominated in foreign currencies at the reporting date are translated into the functional currency at the
spot exchange rate at that date. Foreign currency differences arising on translation are difference
Notes to the financial statements
9
between amortised cost in functional currency in the beginning of period, adjusted with effective interest
and received payments during the period, and amortised cost in foreign currency at the spot exchange
rate at the reporting date.
Non-monetary assets and liabilities denominated in foreign currencies that are measured at fair value
are retranslated into the functional currency at the spot exchange rate at the date that the fair value was
determined.
(iii) Foreign operations
The functional currency of the foreign operations in Cyprus is determined by the management to be the
Euro. In determining the functional currency of the foreign operations, the Bank takes into account the
fact that they are carried out as an extension of the reporting entity.
(d) Financial assets
(i) Recognition
The Bank recognizes a financial asset when it becomes a party to the contractual provisions of the
instrument. The Bank initially recognizes trade and other receivables on the date of transaction.
Advances to customers are recognised when cash is advanced to the borrowers. At initial recognition,
the Bank measures all financial assets at fair value plus, in the case of financial asset not measured at
fair value through profit or loss, transaction costs that are directly attributable to the acquisition of the
financial asset.
The Bank classifies financial assets in the following categories: financial assets measured at amortized
cost, financial assets measured at fair value through other comprehensive income, or financial assets
measured at fair value through profit or loss. Management determines the classification of investments
at initial recognition according to the business model for management of the specific class of financial
assets and the contractual features of the cash flows associated with that financial asset.
(ii) Financial assets at amortised cost
Debt instruments held within the Bank’s business model whose objective is to hold assets in order to
collect contractual cash flows and where the contractual cash flows give rise only to principal and interest
payments are recognised at amortised cost. After the initial recognition assets are booked at amortised
cost.
Recognition at amortised cost requires application of the effective interest rate method. The amortised
cost of a financial asset is the value at which the financial asset was initially recognised, minus the
principal repayments plus or minus the amortisation accrued by using the effective interest rate method
for each difference between the initial value and the value at the maturity date and minus impairment.
(iii) Financial assets at fair value through other comprehensive income
Debt instruments held within the Bank’s business model whose objective is to hold assets in order to
collect contractual cash flows or to sell the asset and where the contractual cash flows give rise only to
principal and interest payments are recognised at fair value in other comprehensive income. After initial
recognition, the asset is measured at fair value with changes in fair value in revaluation reserve of
investments in securities (other comprehensive income). When the debt instrument is written off, the
profit or loss accrued and recognised in other comprehensive income is transferred to profit or loss.
The position contains two categories: financial assets held for trading and financial assets not classified
in the above two categories. A financial asset is classified in this category if it was acquired for the
purpose of short-term sale or if its contractual characteristics do not meet the requirement for generating
payments of only principal and interest. Derivatives are also categorised as held for trading unless they
are designated as hedges.
Notes to the financial statements
10
(iv) Financial assets at fair value through profit or loss
The position contains two categories: financial assets held for trading and financial assets not classified
in the above two categories. A financial asset is classified in this category if it was acquired for the
purpose of short-term sale or if its contractual characteristics do not meet the requirement for generating
payments of only principal and interest. Derivatives are also categorised as held for trading unless they
are designated as hedges.
The Bank does not designate any debt instrument as at fair value through profit or loss to remove or
significantly reduce an accounting mismatch.
(v) Capital instruments at fair value through other comprehensive income
The Bank may make an irrevocable election to recognize changes in fair value of investments in equity
instruments through other comprehensive income, not through profit or loss. A gain or loss from fair
value changes will be shown in other comprehensive income and will not be reclassified subsequently
to profit or loss. When the equity instrument is written off, the profit or loss accrued and recognised in
other comprehensive income is directly transferred to other reserves and retained earnings.
(vi) Reclassification
If the Bank reclassifies a financial asset out of the fair value through profit or loss measurement category
and into the fair value through other comprehensive income measurement category, the financial asset
shall continue to be measured at fair value. The revaluation reserve for the instrument shall be formed
from changes to fair value after the reclassification date.
If the Bank reclassifies a financial asset out of the amortized cost measurement category and into the
fair value through profit or loss measurement category, its fair value shall be measured at the
reclassification date. Any gain or loss arising from a difference between the previous amortized cost of
the financial asset and fair value is recognized in profit or loss.
If the Bank reclassifies a financial asset out of the fair value through profit or loss measurement category
and into the amortized cost measurement category, its fair value at the reclassification date shall become
its new gross carrying amount.
If the Bank reclassifies a financial asset out of the amortized cost measurement category and into the
fair value through other comprehensive income measurement category, its fair value shall be measured
at the reclassification date. Any revaluation difference shall be recognized in other comprehensive
income. The effective interest rate and the measurement of expected credit losses shall not be adjusted
as a result of the reclassification.
If the Bank reclassifies a financial asset from the ‘measured at fair value through other comprehensive
income’ category to the ‘measured at amortized cost’ category, the entire value of the accumulated
revaluation reserve at the date of reclassification is offset against the fair value of the financial asset.
Thus, in practice, it turns out that at the date of reclassification the financial asset is measured as if it
had always been measured at amortized cost. The effective interest rate and the measurement of
expected credit losses shall not be adjusted as a result of the reclassification.
Such reclassification is only possible after a change in the business model by which financial assets are
managed.
Notes to the financial statements
11
In case of a change of the business model from “hold to collect and sell” to “hold to collect”, the Bank
reclassifies the financial assets concerned. To this end, it periodically reviews its business model
historically and analyses the extent to which the purpose of holding financial assets meets the ‘hold to
collect’ business model as opposed to the ‘hold to collect and sell’ business model. In this analysis, the
following criteria may serve as indication for change in the business model: government securities with
sufficiently long residual term that have not been traded since their acquisition; or privately placed
securities without an active market where Fibank holds a significant part of the issue. In case of a
significant predominance of the 'hold to collect' business model, the Bank needs to consider whether to
reclassify the financial assets from the 'Measured at fair value through other comprehensive income'
category to the 'Measured at amortized cost' category, continuing to manage financial assets in such a
way as to generate cash flows only from collecting contractual payments.
If the Bank reclassifies a financial asset out of the fair value through other comprehensive income
measurement category and into the fair value through profit or loss measurement category, the financial
asset shall continue to be measured at fair value. The cumulative revaluation reserve at the
reclassification date shall be reclassified to profit or loss.
The Bank shall not reclassify any financial liability.
(vii) Fair value measurement principles
Fair value is the price that would be received to sell an asset or paid to transfer a liability in an orderly
transaction between market participants at the measurement date in the principal, or in its absence, the
most advantageous market to which the Bank has access at that date. The fair value of a liability reflects
its non-performance risk.
When applicable, the Bank measures the fair value of an instrument using the quoted price in an active
market for that instrument. A market is regarded as active if transactions for the asset or liability take
place with sufficient frequency and volume to provide pricing information on an ongoing basis.
When there is no quoted price in an active market, the Bank uses valuation techniques that maximise
the use of relevant observable inputs and minimise the use of unobservable inputs. The chosen
valuation technique incorporates all the factors that market participants would take into account in pricing
a transaction. The best evidence of the fair value of a financial instrument at initial recognition is normally
the transaction price i.e. the fair value of the consideration given or received. If the Bank determines
that the fair value at initial recognition differs from the transaction price and the fair value is evidenced
neither by a quoted price in an active market for an identical asset or liability nor based on a valuation
technique that uses only data from observable markets, the financial instrument is initially measured at
fair value, adjusted to defer the difference between the fair value at initial recognition and the transaction
price. Subsequently, that difference is recognised in profit or loss on an appropriate basis over the life
of the instrument but no later than when the valuation is supported wholly by observable market data or
the transaction is closed out.
If an asset or a liability measured at fair value has a bid price and an ask price, the Bank measures
assets and long positions at a bid price and liabilities and short positions at an ask price. The Bank
which holds portfolios of financial assets and financial liabilities is are exposed to market risk and credit
risk. If the Bank manages these portfolios on the basis of its net exposure either to market risk or credit
risk, the fair value is measured on the basis of a price that would be received to sell a net long position
or paid to transfer a net short position for a particular risk exposure. Those portfolio-level adjustments
are allocated to the individual assets and liabilities on the b
asis of the relative risk adjustment of each of
the individual instruments in the portfolio.
The Bank recognises transfers between levels of the fair value hierarchy as of the end of the reporting
period during which the change has occurred.
(viii) Derecognition
The Bank derecognises a financial asset when the contractual rights to the cash flows from the financial
asset expire, or when the Bank transfers these rights in a transaction in which substantially all the risks
and rewards of ownership of the financial assets are transferred to the buyer. Any interest in transferred
Notes to the financial statements
12
financial assets that is created or retained by the Bank is recognised as a separate asset or liability.
The Bank derecognises a financial liability when its contractual obligations are discharged or cancelled
or expire.
The Bank enters into transactions whereby it transfers financial assets recognised in its statement of
financial position, but retains either all or substantially all risks and rewards of the transferred asset. If
all or substantially all risks and rewards are retained, then the transferred assets are not derecognised
in the statement of financial position (an example of such transactions are repo deals).
In transactions in which the Bank neither retains nor transfers substantially all the risks and rewards of
ownership of a financial asset, it derecognises the asset if it does not retain control over the asset. The
rights and obligations retained in the transfer are recognised separately as assets and liabilities as
appropriate.
In transfers in which, control over the asset is retained, the Bank continues to recognise the asset to the
extent of its continuing involvement, determined by the extent to which it is exposed to changes in the
value of the transferred asset.
(e) Cash and cash equivalents
Cash and cash equivalents comprise cash balances on hand, cash deposited with central banks and
short-term highly liquid accounts and advances to banks with original maturity of up to three months.
(f) Investments
Investments in debt instruments held by the Bank as part of a business model for the purpose of
collecting contractual cash flows are classified as financial assets at amortised cost. Investments in debt
instruments held by the Bank as part of a business model for the purpose of collecting contractual cash
flows and sale are classified as financial assets at fair value in other comprehensive income. All other
investments, including those whose contractual terms do not meet the requirement for generation of
only principal and interest payments are classified as recognised at fair value in profit or loss.
(g) Securities borrowing and lending business and repurchase transactions
(i) Securities borrowing and lending
Investments lent under securities lending arrangements continue to be recognised in the statement of
financial position and are measured in accordance with the accounting policy applicable for assets at
fair value in profit or loss or at fair value in other comprehensive income. Cash collateral received in
respect of securities lent is recognised as liabilities to either banks or customers. Investments borrowed
under securities borrowing agreements are not recognised. Cash collateral placements in respect of
securities borrowed are recognised under loans and advances to either banks or customers. Income
and expenses arising from the securities borrowing and lending business are recognised on an accrual
basis over the period of the transactions and are included in interest income or expense.
(ii) Repurchase agreements
The Bank enters into purchases (sales) of investments under agreements to resell (repurchase)
substantially identical investments at a certain date in the future at a fixed price. Investments purchased
subject to commitments to resell them at future dates are not recognised. The amounts paid are
recognised in loans to either banks or customers. The receivables are shown as collateralised by the
underlying security. Investments sold under repurchase agreements continue to be recognised in the
statement of financial position and are measured in accordance with the accounting policy for either
assets held for trading or available-for-sale as appropriate. The proceeds from the sale are reported as
liabilities to either banks or other customers.
The difference between the purchase (sale) and resell (repurchase) considerations is recognised on an
accrual basis over the period of the transaction and is included in interest income (expenses).
Notes to the financial statements
13
(h) Borrowings
Borrowings are recognised initially at ‘cost’, being their issue proceeds (fair value of consideration
received) net of transaction costs incurred.
Borrowings are subsequently stated at amortised cost and any difference between net proceeds and
the redemption value is recognized in profit or loss over the period of the borrowings using the effective
yield method. If the Bank purchases its own debt, it is removed from the statement of financial position
and the difference between the carrying amount of a liability and the consideration paid is included in
other operating income.
(i) Offsetting
Financial assets and liabilities are offset and the net amount is reported in the statement of financial
position when the Bank has a legally enforceable right to set off the recognised amounts and the
transactions are intended to be settled on a net basis.
(j) Impairment of financial assets
The Bank recognizes 12-month expected credit loss as loss allowance when there is no significant
increase in the credit risk since the initial recognition of the financial asset. When there is a significant
increase in credit risk since initial recognition, expected credit losses for the whole life of the financial
assets are recognized as loss allowance.
Whether credit risk is significantly increased or not is determined based on the following factors and
events for the debtor or the exposure:
Internal behavioural scoring of natural persons, companies and institutions whose exposures
are above the threshold for significance;
Decrease in credit rating (internal or external) by a given number of notches for companies and
institutions whose exposures are above the threshold for significance.
Delinquencies;
Other factors.
(k) Property and equipment
Land and buildings are presented in the statement of financial position at their revalued amount which
is the fair value of the asset as at the date of revaluation less any subsequent amortisation and
depreciation and accumulated impairment losses. All others classes of items of property, plant and
equipment are stated in the statement of financial position at their acquisition cost less accumulated
depreciation and allowance for impairment.
Depreciation is calculated on a straight-line basis at prescribed rates designed to decrease the cost or
valuation of fixed assets over their expected useful lives. The annual rates of amortisation are as follows:
A
ssets %
Buildings 3 - 10
Equipment 10 - 50
Fixtures and fittings 10 - 15
Motor vehicles 20
Leasehold Improvements 2 - 50
Assets are not depreciated until they are brought into use and transferred from assets in the course of
construction into the relevant asset category.
Notes to the financial statements
14
2. Significant accounting policies, continued
(l) Intangible assets
Intangible assets acquired by the Bank are stated at cost, less accumulated amortisation and any
impairment losses.
Amortisation is calculated on a straight-line basis over the expected useful life of the asset. The annual
rates of amortisation are as follows:
A
ssets %
Licenses and trademarks 10 - 14
Software and licences 10 - 50
(m) Investment Property
Investment property is property (land or a building or part of a building or both) held to earn rentals or
for capital appreciation or both. The Bank has chosen for its accounting policy to account for investment
property using the fair value model and applies this to all its investment property. Investment properties
are initially measured at cost and are subsequently measured using the fair value model, and the
revaluation income and expense is recognised in the profit for period in which they occurred.
The reclassification of repossessed assets reported as inventories into investment properties is possible
only where a contract to rent out the respective property has been signed. The reclassification of assets
reported under IAS 16 Property and equipment into investment properties is carried out upon termination
of the use of the relevant asset by the Bank. The fair value of assets constituting investment property
was determined by independent property assessors holding recognised professional qualification and
recent experience in assessing property with similar location and category, using reliable techniques for
determining fair values.
(n) Provisions
A provision is recognised in the statement of financial position when the Bank has a legal or constructive
obligation as a result of a past event, it is probable that an outflow of economic benefits will be required
to settle the obligation and a reliable assessment of the amount due can be made. If the effect is
material, provisions are determined by discounting the expected future cash flows at a pre-tax rate that
reflects current market assessments of the time value of money and, where appropriate, the risks
specific to the liability.
(o) Acceptances
An acceptance is created when the Bank agrees to pay, at a stipulated future date, a draft drawn on it
for a specified amount. The Bank’s acceptances primarily arise from documentary credits stipulating
payment to be made a certain number of days after receipt of required documents. The Bank negotiates
most acceptances to be settled at a later date following the reimbursement from the customers.
Acceptances are accounted for as liabilities evidenced by paper.
(p) Off-balance sheet commitments
In the ordinary course of its business, the Bank enters into off-statement of financial position
commitments such as guarantees and letters of credit. The Bank recognizes provision for off-statement
of financial position commitments when it has a present obligation as a result of a past event, when it is
probable that an outflow of resources embodying economic benefit will be required to settle the
obligation, and when a reliable estimate can be made of the obligation.
(q) Taxation
Tax on the profit for the year comprises current tax and the change in deferred tax. Current tax
comprises tax payable calculated on the basis of the expected taxable income for the year, using the
tax rates enacted by the statement of financial position date, and any adjustment of tax payable for
previous years.
Deferred tax is provided using the balance sheet liability method on all temporary differences between
the carrying amounts for financial reporting purposes and the amounts used for taxation purposes.
Notes to the financial statements
15
Deferred tax is calculated on the basis of the tax rates that are expected to apply to the period when the
asset is realised or the liability is settled.
The effect on deferred tax of any changes in tax rates is charged to profit or loss, except to the extent
that it relates to items previously recognised either in other comprehensive income or directly in equity.
A deferred tax asset is recognised only to the extent that it is probable that future taxable profits will be
available against which the unused tax losses and credits can be utilised. Deferred tax assets are
reduced to the extent that it is no longer probable that the related tax benefit will be realised.
(r) Critical accounting estimates and judgements in applying accounting policies
The Bank makes estimates and assumptions that affect the reported amounts of assets and liabilities
within the next financial year. Estimates and judgements are continually evaluated and are based on
historical experience and other factors, including expectations of future events that are believed to be
reasonable under the circumstances.
The actual results may differ from the Management’s assumptions, estimates and judgements and in
rare cases correspond fully to the preliminary result estimates.
In preparing the present individual financial statements the Management’s estimates in applying the
Bank’s accounting policies and the main sources of uncertainty of the approximate accounting
valuations do not differ from those disclosed in the individual financial statement for the previous year.
Information on the valuations and the valuation uncertainty, for which there is a significant risk of change
as of 31 December 2022 are stated below and are related to the impairment of financial instruments,
income tax and the following notes related to other elements of the financial statements:
Note 5, 18 - determining of the fair value of the financial instruments, land and buildings through
valuation techniques, in which the input data for the financial assets and liabilities are not based on
the available market information. The Management uses valuation techniques for the fair value of
financial instruments (when there is no quoted price in an active market) and non-financial assets.
In applying the valuation techniques, the Management uses to a maximum degree market data and
assumptions which market participants would take into account in pricing an instrument. When there
is no available market data, the Management uses its best judgement of the assumptions that
market participants would make. These judgements may differ from the actual prices that may be
determined in a fair market transaction between informed and willing parties at the end of the
reporting period.
Notes 11, 15, 17 measuring the expected credit loss credit losses constitute the difference
between all contractual cash flows payable to the Bank and all cash flows which the Bank expects
to receive. Expected credit loss is the probability-weighted estimate of credit losses which require
the Bank’s judgement. Expected credit loss is discounted with the initial effective interest rate (or
with the loan-adjusted effective interest rate for purchased or initially created financial assets with
credit impairment).
Notes 15, 17 – debt instruments at amortised cost the analysis and intentions of the Management
are confirmed by the business model of holding debt instruments that meet the requirements for
receiving only principal and interest payments and holding assets until collecting the contractual
cash flows from the bonds which are classified as debt instruments at amortised cost.
Note 24 – Lease contract term – in determining the lease contract term the Management takes into
consideration all facts and circumstances that create economic incentives for exercising the option
to extend the lease, or not to exercise the option to terminate the lease Extension options (or the
periods after termination options) are included in the lease contract term only if it is reasonably
certain that the lease contract has been extended (or has not been terminated).
Note 30 in accordance with IAS 37 Provisions, Contingent Liabilities and Contingent Assets
and the internal rules for setting aside provisions for pending court cases the bank has recognised
provisions for pending court cases. The Bank is a defendant in pending cases and the outcome of
Notes to the financial statements
16
those cases may lead to liabilities in an amount different from the amount of provisions recognized
in the financial statement.
(s) Assessment of repossessed assets from collaterals
Assets accepted as collateral are recognized at the lower of the cost of acquisition and the net realizable
value. When evaluating the net realizable value of the assets the Bank prepares several models for
appraisal (e.g. discounted cash flows) and makes comparison to available market data (e.g. similar
market transactions, offers from potential buyers).
(t) Income taxes
The Bank is subject to income taxes in numerous jurisdictions. Significant estimates are required in
determining the worldwide provision for income taxes. There are many transactions and calculations for
which the ultimate tax determination is uncertain during the ordinary course of business. The Bank
recognises liabilities for anticipated tax audit issues based on estimates of whether additional taxes will
be due. Where the final tax outcome of these matters is different from the amounts that were initially
recorded, such differences will impact the income tax and deferred tax provisions in the period in which
such determination is made.
(u) Employee benefits
Defined contribution plans
A defined contribution plan is a post-employment benefit plan under which an entity pays fixed
contributions into a separate entity and will have no legal or constructive obligation to pay further
amounts. The Government of Bulgaria is responsible for providing pensions in Bulgaria under a defined
contribution pension plan. The Bank’s contributions to the defined contribution pension plan are
recognised as an employee benefit expense in profit or loss in the periods during which services are
rendered by employees.
Defined benefit plans
A defined benefit plan is a post-employment benefit plan other than a defined contribution plan. The
Bank’s net obligation in respect of defined benefit plans is calculated by estimating the amount of future
benefit that employees have earned in return for their service in the current and prior periods; that benefit
is discounted to determine its present value.
The Bank has an obligation to pay certain amounts to each employee who retires with the Bank in
accordance with Art. 222, § 3 of the Labour Code.
According to these regulations in the LC, when a labour contract of a bank’s employee, who has
acquired a pension right, is ended, the Bank is obliged to pay him compensations amounted to two
gross monthly salaries. Where the employee has been with the same employer for the past 10 years,
this employee is entitled to a compensation amounting to six gross monthly salaries. As at balance sheet
date, the Management of the Bank estimates the approximate amount of the potential expenditures for
every employee using the projected unit credit method.
For the last two years the Bank has prepared estimates for the due provisions for pensions and has not
identified significant liabilities.
Termination benefits
Termination benefits are recognised as an expense when the Bank is committed demonstrably, without
realistic possibility of withdrawal, to a formal detailed plan to either terminate employment before the
normal retirement date, or to provide termination benefits as a result of an offer made to encourage
voluntary redundancy. Termination benefits for voluntary redundancies are recognised as an expense
if the Bank has made an offer of voluntary redundancy, it is probable that the offer will be accepted, and
the number of acceptances can be estimated reliably. If benefits are payable more than 12 months after
the reporting period, then they are discounted to their present value.
Short-term employee benefits
Short-term employee benefit obligations are measured on an undiscounted basis and are expensed as
Notes to the financial statements
17
the related service is provided.
A liability is recognised for the amount expected to be paid under short-term cash bonus or profit-sharing
plans if the Bank has a present legal or constructive obligation to pay this amount as a result of past
service provided by the employee, and the obligation can be estimated reliably. The Bank recognises
as a liability the undiscounted amount of the estimated costs related to annual leave expected to be
paid in exchange for the employee’s service for the period completed.
(v) Leases
(i) The Company as lessee
For new contracts concluded on or after 1 January 2019 the Bank assess whether the contract is, or
contains, a lease. A contract is, or contains, a lease if the contract conveys the right to control the use
of an asset (the identified asset) for a period of time in exchange for consideration. In order to apply this
definition, the Bank assesses three key elements:
Whether the contract refers to an identified asset which is either explicitly specified in a contract, or
implicitly specified at the time that the asset is made available for use;
The Bank has the right to obtain substantially all of the economic benefits from use of the identified
asset throughout the period of use, within the scope of its right of use defined in the contract;
The Bank has the right to direct the use of the identified asset throughout the period of use.
The Bank assesses whether it has the right to direct how and for what purpose the asset will be used
throughout the period of use.
Assessment and recognition of leases by the Bank as lessee
On the commencement date of the lease contract the Bank recognises the right-of-use asset and the
lease liability in the statement of financial position. The right-of-use asset is assessed at cost which
comprises the amount of the initial measurement of the lease liability, any initial direct costs incurred by
the Bank, an estimate of costs to be incurred by the lessee in dismantling and removing the underlying
asset at the end of the lease contract, and any lease payments made at or before the commencement
date (less any lease incentives received).
The Bank depreciates the right-of-use asset using the linear method from the commencement date to
the earlier of the end of the useful life of the right-of-use asset or the end of the lease term. The Bank
also reviews the right-of-use assets for impairment, where such indicators exist.
On the commencement date of the lease contract the Bank measures the lease liability at the present
value of the remaining lease payments at that date, discounted using the borrowing rate stipulated in
the lease contract, if that rate can be readily determined, or the company’s incremental borrowing rate.
As of 01.01.2019 the Bank applies IFRS 16 Leases. To this end, an analysis was made of the
requirements of this Standard, and the following key elements were identified:
IFRS 16 Leases introduces new rules for reporting lease agreements. First of all, the standard requires
that an analysis be made of whether and which agreements with or without the legal form of lease
constitute a lease or contain lease components in accordance with the definition of lease contained in
IFRS 16, paragraph 9. According to Paragraph 9, a contract is, or contains, a lease if:
- there is an identified asset, and
- the contract conveys the right to control the use of the identified asset for a period of time in exchange
for consideration.
In the general case, the lessee is required recognise a right-of-use asset and a lease liability at the
commencement date.
Also, instead of applying the requirements for recognition of a right-of-use asset in return for
consideration under a lease contract, the lessee may choose to report lease contracts as an expense
under the linear method for the duration of the lease in the following types of contracts:
- ending within 12 months of the date of initial application of IFRS 16
Notes to the financial statements
18
- lease of low-value assets
In the process of assessing the effects of application of this Standard, the Bank did the following:
-Full review of all agreements was made in order to establish whether it may be necessary to consider
additional agreements as lease agreements according to the new IFRS 16 definition;
- A decision was made for partial retrospective application (which means that the comparative
information will not be changed). Under the modified approach it is possible not to assess whether
existing agreements contain leases and other relief. Under the modified approach it is possible not to
assess whether existing agreements contain leases and other relief.
The Management analysed the effect of application of the Standard for contracts expected to last up to
five years because a big part of the rental agreements to which the Bank is a party as a tenant, the Bank
can terminate after a three- or six-months’ notice without owing an indemnity. Even in the other contracts
this possibility is available in accordance with the law.
This reflects on the expected actual duration of the lease because the contract term depends on the
probability that the Bank would exercise that option. With relation to this the Bank considers that a
duration of five years is indicative of the maximum duration of the lease term, irrespective of whether
contracts of longer duration exist or not.
In order to determine the incremental borrowing rate, the Bank uses an interest rate consisting of the
risk-free interest rate and a surcharge reflecting the credit risk related to the Bank and additionally
adjusted for the specific conditions of the lease contract, including term, country, currency, and
collateral.
Lease payments included in measuring the lease liability comprise fixed payments (including in-
substance fixed payments), variable lease payments that depend on an index or a rate, amounts
expected to be payable by the lessee under residual value guarantees, and the exercise price of a
purchase option if the Group is reasonably certain to exercise that option.
After the commencement date, the lease liability shall be decreased with the amount of payments made
and shall be increased with the amount of the interest. The lease liability is remeasured to reflect any
reassessment or lease modifications, or to reflect revised in-substance fixed lease payments.
When the lease liability is remeasured, the amount of the remeasurement is recognised in the right-of-
use asset or in profit or loss, if the carrying amount of the right-of-use asset is already reduced to zero.
The Bank has chosen to report short-term leases and leases of low-value assets by using practical
expedients envisaged in the standard. Instead of recognising right-of-use assets and lease liabilities,
the Bank recognizes the payments related to them as an expense in profit or loss using the linear method
during the lease term.
In the statement of financial position, right-of-use assets are presented on a separate row “Right-of-use
assets”, and the liabilities under lease contracts are also presented on a separate row - “Lease
liabilities”.
Extension options or termination options are included in a number of the Bank’s property rentals. They
are used to increase the operative flexibility in the management of assets used in its operations.
(ii) The company as lessor
The portion of IFRS 16 which concerns the Bank as lessor no significant changes were found in
comparison to the previous IAS 17. The Bank classifies a lease contract as a finance lease if it has
transferred substantially all risks and rewards related to ownership of the asset subject to the lease. All
other lease contracts are classified as operating. In case of a finance lease, the Bank recognises as
asset a receivable under the contract in an amount equal to the
net investment in the lease.
During the lease term the Bank recognizes interest income on the amount receivable at an interest rate
reflecting the return rate of the net investment in the lease.
In case of operating lease, the Bank recognises lease payments as revenue on a linear basis.
Notes to the financial statements
19
As lessor, the Bank classifies each of its lease contracts as either an operating lease or a finance lease.
A lease is classified as a finance lease if it transfers substantially all the risks and rewards incidental to
ownership of an underlying asset. A lease is classified as an operating lease if it does not transfer
substantially all the risks and rewards incidental to ownership of an underlying asset.
3. Risk management disclosures
A. Trading activities
The Bank maintains active trading positions in a limited number of non-derivative financial instruments.
Most of the Bank’s trading activities are customer driven. In anticipation of customer demand, the Bank
carries an inventory of money market instruments and maintains access to market liquidity by trading
with other market makers. These activities constitute the proprietary trading business and enable the
Bank to provide customers with money market products at competitive prices.
The Bank manages its trading activities by type of risk involved and on the basis of the categories of
trading instruments held.
(i) Credit risk
Credit risk is the total risk of losses from positions in financial instruments as a result of the inability of
one or more parties to the exposure to meet their obligations. Main components of credit risk:
Default risk
The risk that issuers to financial instruments might default on their obligations.
Counterparty credit risk
Counterparty credit risk is the risk that the counterparty to a transaction could default before the final
settlement of the transaction’s cash flows. It occurs under transactions with derivatives, repo deals,
transactions for granting/receiving a loan of securities and goods, margin lending transactions and
extended settlement transactions.
Settlement risk
To the Bank settlement risk is the risk of unsettled transactions with securities, goods or cash. It
occurs both under transactions with settlement of services of the “delivery versus payment” (DvP)
type, and under trade without DvP (“free deliveries”). All instruments exposed to counterparty credit
risk fall within the scope of this type of risk.
Credit risk is monitored on an ongoing basis subject to Bank’s internal risk management procedures and
is controlled through minimum thresholds for the credit quality of the issuer/counterpart and setting limits
on exposure amount according to credit quality.
(ii) Market risk
Market risk is the risk that the fair value or future cash flows of a financial instrument will fluctuate
because of changes in market conditions. The Bank assumes market risk when taking positions in debt
instruments, equities, derivatives and foreign exchange transactions.
These risks are managed by enforcing limits on positions taken and their risk sensitivities as measured
by value-at-risk, duration or other measures appropriate for particular position in view of its sensitivity to
risk factors. The major risk factors that affect Bank’s trading activities are changes of interest rates
(interest rate risk), changes of exchange rates (foreign exchange risk) and changes of equity prices
(price risk).
Exposure to market risk is formally managed in accordance with risk limits set by senior management
and the adopted risk strategy.
The Value at Risk is calculated and monitored on a daily basis as part of the Bank’s ongoing risk
management. Value at risk is calculated using one day horizon and 99 per cent confidence level,
meaning that there is 1% probability that a portfolio will incur a loss in one day greater than its VaR.
Notes to the financial statements
20
Parameters of the VaR model are estimated on the basis of exponentially weighted historical price
changes of risk factors.
The following table summarises the range of interest VaR for all positions in the Bank’s trading portfolio
carried at fair value:
31 Decembe
2023 31 Decembe
in thousands of
BG
N
2023 avera
g
e low hi
g
h 2022
V
aR 1.0 2.1 0.8 15.2 1.4
B. Non-trading activities
Below is a discussion of the various risks the Bank is exposed to as a result of its non-trading activities
and the approach taken to manage those risks.
(i) Liquidity risk
Liquidity risk is the risk that the Bank will encounter difficulty in meeting obligations associated with
financial liabilities. Liquidity risk arises in the general funding of the Bank’s activities and in the
management of positions.
It includes both the risk of being unable to fund assets at appropriate maturity and rates and the risk of
being unable to liquidate an asset at a reasonable price and in an appropriate time frame to meet the
liability obligations.
Funds are raised using a broad range of instruments including deposits, other liabilities evidenced by
paper, subordinated debt instruments and share capital. This enhances funding flexibility, limits
dependence on any one source of funds and generally lowers the cost of funds. The Bank makes its
best efforts to maintain a balance between continuity of funding and flexibility through the use of liabilities
with a range of maturity. The Bank continually assesses liquidity risk by identifying and monitoring
changes in funding required to meet business goals and targets set in terms of the overall Bank strategy.
The body managing liquidity is the Assets, Liability and Liquidity Management Council.
In compliance with the requirements of the Law on Credit Institutions, Ordinance No 7 of BNB for the
organization and management of risks in banks and Directive 2014/59/EU of the European Parliament
and of the Council for establishing a framework for the recovery and resolution of credit institutions and
investment firms transposed in the Law on the Recovery and Restructuring of Credit Institutions and
Investment Intermediaries, First Investment Bank AD prepared a recovery plan if financial difficulties
occur. It includes qualitative and quantitative early warning signals and indicators of recovery such as
capital and liquidity indicators, income indicators, market-oriented indicators upon the occurrence of
which recovery measures are triggered. Liquidity indicators include Liquidity Coverage Ratio (LCR); net
withdrawal of financing; liquid assets to deposits by non-financial customers ratio; Net Stable Funding
Ratio (NSFR). Different stress test scenarios related to idiosyncratic shock, system shock and aggregate
shock have been prepared. In case of liquidity pressure, there are systems in place to ensure prompt
and adequate reaction which include obtaining additional funds from local and international markets
through issuance of appropriate financial instruments depending on the specific case as well as sale of
non-liquid assets. The levels of decision making are clearly determined. In order to reduce the liquidity
risk, preventive measures have been taken aimed to extend the maturity of borrowings from customers,
to encourage long-term relationships with clients and to increase customer satisfaction.
In order to adequately manage liquidity risk, the Bank monitors cash flows on a daily basis.
As part of the liquidity risk management, the Bank keeps available liquid assets. They consist of cash,
cash equivalents and government securities, which could be sold immediately in order to provide
liquidity:
Notes to the financial statements
21
Liquid assets
in BGN ‘000
31 December
2023
31 December
2022
Balances with BNB 1,799,904
1,382,525
Current accounts and amounts with other banks 695,777
698,396
Unencumbered
g
overnment securities 2,009,526
1,884,950
Gold 3,303
2,642
Total liquid assets 4,508,510
3,968,513
Reasonable liquidity management requires avoidance of concentration of the borrowings from large
depositors. Analysis of the significant borrowings in terms of total amount is performed on a daily basis
and the diversity of the total liabilities portfolio is supervised.
As at 31 December 2023 the thirty largest non-bank unguaranteed depositors represent 11.85% of total
deposits from other customers (31 December 2022: 12.43%).
One of the main ratios used by the Bank for managing liquidity risk is the ratio of liquid assets to total
borrowings from other clients.
31 December 202
3
31 December 2022
Ratio of liquid assets to total borrowings from other clients 39.22% 36.75%
3. Risk management disclosures, continued
The following table provides an analysis of the financial assets and liabilities of the Bank into relevant
maturity groupings based on the remaining periods to repayment.
Maturity table as at 31 December 2023
in thousands of BGN
Up to 1
Month
From 1 to
3 Months
From 3
months to 1
yea
r
From 1 to
2 years
More than 2
years
Maturity
not
defined Total
Assets
Cash and balances with
Central Banks 2,325,807 - - - - - 2,325,807
Financial assets at fair value
through profit or loss 218,660 - - - - 24,931 243,591
Financial assets at fair value
through other comprehensive
income 1,077,079 - - - - - 1,077,079
Financial assets at amortised
cost 131,101 242,868 253,329 127,687 508,294 - 1,263,279
Loans and advances to banks
and other financial institutions 235,314 - 322 - 24,082 - 259,718
Loans and advances to
customers 557,602 208,069 949,010 752,040 4,691,588 -
7,158,309
Other trading assets 1,111 654 - - - - 1,765
Total financial assets 4,546,674 451,591 1,202,661 879,727 5,223,964 24,931 12,329,548
Liabilities
Due to banks 54,326
-
-
-
- - 54,326
Due to other customers 7,740,869 1,036,588 2,045,464 382,970 288,273 - 11,494,164
Liabilities evidenced by paper 886 2,182 27,584 104,579 304,403 - 439,634
Financial liabilities at fair value
through profit and loss 967 596 666 936 - - 3,165
Hybrid debt - - - - - 257,871 257,871
Other financial liabilities, net - - - - - - -
Total financial liabilities 7,797,048 1,039,366 2,073,714 488,485 592,676 257,871 12,249,160
Net liquidity gap (3,250,374) (587,775) (871,053) 391,242 4,631,288 (232,940) 80,388
Notes to the financial statements
22
The investments in securities reported in portfolios of financial assets at fair value in profit or loss,
financial assets at fair value in other comprehensive income and financial assets at amortised cost are
mostly investments in government securities from first-class issuers which are highly liquid and with the
most favourable capital treatment.
The bank manages its investments in debt securities in line with the current market expectations and
dynamics. As at 31.12.2023 the modified portfolio duration is 1.7 years, while a year earlier it was 2.2
years.
The table shows investments at fair value through other comprehensive income and fair value through
profit or loss with a maturity of up to 1 month in order to reflect the management’s ability to sell them
within a short-term period, if needed.
The Bank does not recognize as liquidity risk the current undrawn amounts of loans extended because
the management considers that, based on the agreed conditions, the Bank can at any time terminate
the extension of funds to its borrowers in case it is expected that their credit risk will increase.
Loans and advances to customers reflect also financial lease receivables.
Maturity table as at 31 December 2022
in thousands of BGN
Up to 1
Month
From 1 to
3 Months
From 3
months to 1
yea
r
From 1 to
2 years
More than
2 years
Maturity
not
defined Total
Assets
Cash and balances with Central
Banks 1,911,371 - - - - - 1,911,371
Financial assets at fair value
through profit or loss 242,351 - - - - 25,336 267,687
Financial assets at fair value
through other comprehensive
income 468,247 - - - - - 468,247
Financial assets at amortised
cost
-
369,369 913,296
12,120
567,418 - 1,862,203
Loans and advances to banks
and other financial institutions 245,693
554
287
333
18,117 - 264,984
Loans and advances to
customers 667,430 248,440 797,563 822,720 3,848,388 - 6,384,541
Other trading assets 575 1,034 - - - - 1,609
Total financial assets 3,535,667 619,397 1,711,146 835,173 4,433,923 25,336 11,160,642
Liabilities
Due to banks 45,703
45,703
Due to other customers
7,227,207
2,071,969
- 10,798,450
Liabilities evidenced by pape
r
- 15 3,456 21,206 91,810 - 116,487
Financial liabilities at fair value
through profit and loss
-
3,682
893
2,860
1,053 - 8,488
Hybrid debt - - - - - 256,861 256,861
Other financial liabilities, net
-
Total financial liabilities 7,272,910 963,713 2,076,318 358,315 297,872
256,861 11,225,989
Net liquidity gap (3,737,243) (344,316) (365,172) 476,858 4,136,051 (231,525) (65,347)
Notes to the financial statements
23
The following table provides a remaining maturities analysis of the financial assets and liabilities of the
Bank as at 31 December 2023 based on the contractual undiscounted cash flows.
BGN '000
Up to 1
Month
From 1 to 3
Months
From 3
months to 1
yea
r
From 1
to 2 years
More
than 2
years Total
Financial assets
Cash and balances with Central
Banks 2,325,807 - - - - 2,325,807
Financial assets at fair value
through profit or loss 243,591 - - - - 243,591
Financial assets at fair value
through other comprehensive
income 1,077,079 - - - - 1,077,079
Financial assets at amortised cost 131,101 242,868 253,311 128,439 549,327 1,305,046
Loans and advances to banks and
other financial institutions 235,314 - 322 - 24,082 259,718
Loans and advances to customers 557,988 209,887 979,345 811,510 5,912,337 8,471,067
Total financial assets 4,570,880 452,755 1,232,978 939,949 6,485,746 13,682,308
Financial liabilities
Due to banks 54,326 - - - - 54,326
Due to other customers 7,740,879 1,036,602 2,045,570 383,018 288,358 11,494,427
Liabilities evidenced by paper
888 2,194 28,346 110,503 373,487 515,418
Financial liabilities at fair value
through profit and loss
967 596 666 936 - 3,165
Hybrid debt - - - 82,597 261,405 344,002
Total financial liabilities 7,797,060 1,039,392 2,074,582 577,054 923,250 12,411,338
Derivatives held for risk
management
Outgoing cash flow 63 59 - - - 122
Incoming cash flo
w
1,174 713 - - - 1,887
Cash flow from derivatives, net 1,111 654 - - - 1,765
The table shows investments at fair value through other comprehensive income and fair value through
profit or loss with a maturity of up to 1 month in order to reflect the management’s ability to sell them
within a short-term period, if needed.
The following table provides a remaining maturities analysis of the financial assets and liabilities of the
Bank as at 31 December 2022 based on the contractual undiscounted cash flows.
Notes to the financial statements
24
BGN '000
Up to 1
Month
From 1 to 3
Months
From 3
months to 1
yea
r
From 1
to 2 years
More
than 2
years Total
Financial assets
Cash and balances with Central
Banks 1,911,371 - - - - 1,911,371
Financial assets at fair value
through profit or loss 267,687 - - - - 267,687
Financial assets at fair value
through other comprehensive
income 468,247 - - - - 468,247
Financial assets at amortised cost - 369,369 913,303 12,252 599,736 1,894,660
Loans and advances to banks and
other financial institutions 245,693 554 287 333 18,117 264,984
Loans and advances to customers 667,890 250,310 818,675 878,762 4,699,983 7,315,620
Total financial assets 3,560,888 620,233 1,732,265 891,347 5,317,836 12,122,569
Financial liabilities
Due to banks 45,703 - - - - 45,703
Due to other customers 7,227,216 960,029 2,072,076 334,291 205,069 10,798,681
Liabilities evidenced by paper - 15 3,489 21,515 97,477 122,496
Financial liabilities at fair value
through profit and loss - 3,682 893 2,860 1,053 8,488
Hybrid debt - - 141,211 69,653 92,315 303,179
Total financial liabilities 7,272,919 963,726 2,217,669 428,319 395,914 11,278,547
Derivatives held for risk
management
Outgoing cash flow 170 - - - - 170
Incoming cash flo
w
758 1,021 - - - 1,779
Cash flow from derivatives, net 588 1,021 - - - 1,609
The expected cash flows of the Bank from some financial assets and liabilities are different from the
cash flows as per the loan contract. The main differences are:
There is an expectation that the deposits on demand and term deposits will remain stable and will
increase.
Retail mortgages have original maturity of 18 years on average, but the expected average effective
maturity is 12 years as some clients take advantage of the early repayment possibility.
(ii) Market risk
Interest rate risk
Interest rate risk in the banking book (IRRBB)
Interest rate risk is the risk that the fair value or future cash flows of a financial instrument will fluctuate
because of changes in market interest rates. The Bank’s operations are subject to the risk of interest
rate fluctuations to the extent that interest-earning assets and interest-bearing liabilities mature or
reprice at different times or in differing amounts. In the case of floating rate assets and liabilities the
Bank is also exposed to basis risk, which is the difference in repricing characteristics of the various
Notes to the financial statements
25
floating rate indices, such as the Bulgarian Basic Interest Rate, the LIBOR and EURIBOR, although
these indices tend to move in high correlation. In addition, the actual effect will depend on a number of
other factors, including the extent to which repayments are made earlier or later than the contracted
dates and variations in interest rate sensitivity within repricing periods and among currencies.
In order to quantify the interest rate risk of its non-trading activities, the Bank measures the impact of a
change in the market rates both on net interest income and on the Bank’s economic value defined as
the difference between fair value of assets and fair value of liabilities.
The interest rate risk on the economic value of the Bank following a standardised shock of +100bp/-
100bp as at 31 December 2023 is BGN +35,665/-14,815 thousand.
The interest rate risk on the Bank's net interest income one year forward following a standardised shock
of +100bp/-100bp as at 31 December 2023 is BGN +19,584/-19,987 thousand.
Net interest income Equity
100 bp increase
100 bp
decrease 100 bp increase
100 bp
decrease
Effect in BGN '000
2023
as at 31 December
19,584 (19,987) 35,665 (14,815)
A
vera
g
e for the period 8,062
(
8,726
)
21,878
(
1,759
)
Maximum for the period 19,584
(
1,136
)
38,549 12,788
Minimum for the period 327
(
19,987
)
8,242
(
17,068
)
2022
as at 31 December
(3,003) 2,131 5,033 15,452
Credit Spread Risk in the Banking Book (CSRBB)
It expresses the risk arising from changes in market perception regarding the price of credit risk, the
liquidity premium and other potential components of credit risk instruments that cause fluctuations in the
price of credit risk, the liquidity premium and other potential components, which is not explained by the
interest rate risk in the banking book (IRRBB) or by the expected credit/(jump to-) default risk. Only those
instruments in the bank’s book which are reported at fair value, fall within the scope.
Similar to the interest rate risk arising from non-trading book activities, for credit spread risk the Bank
calculates the risk arising from potential changes in two aspects: how it affects net interest income and
how it affects the Bank’s economic value.
The applicable stress test scenarios were calibrated with 99% confidence level compared to the
historically observed changes. Shocks vary depending on the maturity of cash flows and the issuer’s
credit rating.
The effect on the Bank’s economic value as at 31 December 2023 amounted to BGN -5,945 thousand,
and the effect on the net interest income amounted to BGN 3,164 thousand.
Net interest
income
Equity
Effect in BGN '000
2023
as at 31 December 3,164
(
5,945
)
A
vera
g
e for the period 1,989
(
6,640
)
Maximum for the period 3,309
(
5,275
)
Minimum for the period 492
(
9,636
)
2022
as at 31 December
269 (9,574)
Notes to the financial statements
26
The following table indicates the effective interest rates at 31 December 2023 and the periods in which
financial liabilities and assets reprice.
Fixed rate instruments
in thousands of BG
N
Total
Floating rate
Instruments
Less than
1 month
Between 1
month and
3 months
Between 3
months and
1
y
ea
r
More than
1
y
ea
r
Assets
Cash and balances with Central
Banks
179,460 179,460 - - - -
Financial assets at fair value
throu
g
h profit or loss
104 - 104 - - -
Financial assets at fair value
through other comprehensive
income
1,077,079 - 1,077,079 - - -
Financial assets at amortised
cost
1,263,279 - 131101 242,868 253,329 635,981
Loans and advances to banks
and other financial institutions
97,187 4,596 19,079 19,950 53,562 -
Loans and advances to
customers
6,649,595 6,267,845 1,481 18,078 93,447 268,744
Total interest-bearin
g
assets
9,266,704 6,451,901 1,228,844 280,896 400,338 904,725
Liabilities
Due to banks
54,326 48,773 5553 - - -
Due to other customers
11,423,336 6,450,036 1,186,109 895,557 2,141,544 750,090
Liabilities evidenced b
y
paper
423,366 105,680 393 1848 25,707 289,738
H
y
brid deb
t
257,871 - - - - 257,871
Total interest-bearing
liabilities
12,158,899 6,604,489 1,192,055 897,405 2,167,251 1,297,699
The table shows investments at fair value through other comprehensive income and fair value through
profit or loss with a maturity of up to 1 month in order to reflect the management’s ability to sell them
within a short-term period, if needed.
Notes to the financial statements
27
The following table indicates the effective interest rates at 31 December 2022 and the periods in which
financial liabilities and assets reprice.
Fixed rate instruments
in thousands of BG
N
Total
Floating rate
Instruments
Less than
1 month
Between 1
month and
3 months
Between 3
months and
1
y
ea
r
More
than 1
y
ea
r
Assets
Cash and balances with Central
Banks 489,946 489,946 - - - -
Financial assets at fair value
throu
g
h profit or loss 236,581 - 236,581 - - -
Financial assets at fair value
through other comprehensive
income 468,247 - 468,247 - - -
Financial assets at amortised
cost 1,862,203 - - 369,369 913,296 579,538
Loans and advances to banks
and other financial institutions
119,309 16,136
15,678
11,026 76,469 -
Loans and advances to
customers 5,661,401 5,288,464 1,406 18,486 86,274 266,771
Total interest-bearin
g
assets 8,837,687 5,794,546 721,912 398,881 1,076,039 846,309
Liabilities
Due to banks 45,703 45,703 - - - -
Due to other customers
10,679,282 4,250,411 2,857,628 960,016 2,071,969 539,258
Liabilities evidenced b
y
paper 116,487 56,309 - - 2,833 57,345
H
y
brid deb
t
256,861 - - - - 256,861
Total interest-bearing
liabilities 11,098,333 4,352,423 2,857,628 960,016 2,074,802 853,464
Notes to the financial statements
28
3. Risk management disclosures, continued
B. Non-trading activities, continued
(ii) Market risk, continued
Currency risk
Currency risk is the risk that the fair value or future cash flows of a financial instrument will fluctuate
because of changes in foreign exchange rates. The Bank is exposed to currency risk in performing
transactions in foreign currencies and foreign-currency denominated financial instruments.
As a result of the currency Board in place in Bulgaria, the Bulgarian currency is pegged to the Euro. As
the currency in which the Bank presents it financial statements is the Bulgarian lev, the Bank’s financial
statements are affected by movements in the exchange rates between the Bulgarian lev and currencies
other than the Euro.
The Bank’s transactional exposures give rise to foreign currency gains and losses that are recognised
in profit or loss. These exposures comprise the monetary assets and monetary liabilities of the Bank that
are not denominated in the presentation currency of the Bank. These exposures were as follows:
in thousands of BG
N
2023 2022
Monetar
y
assets
Euro 4,768,618 5,176,973
US dollar 598,005 629,436
Other 159,119 162,075
Gold 3,303 2,642
Monetar
y
liabilities
Euro 4,212,550 3,914,067
US dollar 592,056 632,495
Other 158,312 162,700
Gold 2,327 1,548
Net position
Euro 556,068 1,262,906
US dollar 5,949
(
3,059
)
Other 807
(
625
)
Gold 976 1,094
In respect of monetary assets and liabilities in foreign currencies that are not economically hedged, the
Bank manages foreign currency risk in line with policy that sets limits on currency positions and dealer
limits.
(iii) Credit risk
Credit risk is the risk that a counterparty to a financial instrument will cause a financial loss for the Bank
by failing to discharge an obligation. The Bank is subject to credit risk through its lending activities and
in cases where it acts as an intermediary on behalf of customers or other third parties or issues
guarantees. The management of the credit risk exposures to borrowers is conducted through regular
analysis of the borrowers’ credit worthiness and the assignment of a rating grade. Exposure to credit
risk is also managed in part by obtaining collateral and guarantees.
Notes to the financial statements
29
The table below sets out information about maximum exposure to credit risk:
In thousands
of BG
N
Loans and advances
to other customers
Loans and advances
to banks and
balances with central
banks
Investment in debt
securities
Off balance sheet
commitments
2023 2022 2023 2022 2023 2022 2023 2022
Carrying
amoun
t
7,158,309 6,384,541 2,273,762 1,927,815 2,543,262 2,567,031 - -
Amount
committed/
g
uaranteed - - - - - - 1,186,167 1,026,495
The Bank’s primary exposure to credit risk arises through its loans and advances. The amount of credit
exposure in this regard is represented by the carrying amounts of the assets on the balance sheet.
These exposures are as follows:
31 December 2023
in thousands of BGN
Class of exposure
Gross amount of
loans and advances
to customers
Allowance for
impairment
Carrying amount of
loans and advances to
customers
Performin
g
Collectivel
y
impaired 6,536,073
(
55,663
)
6,480,410
Nonperformin
g
Collectivel
y
impaired 218,657
(
63,422
)
155,235
Individuall
y
impaired 768,466
(
245,802
)
522,664
Total 7,523,196
(
364,887
)
7,158,309
31 December 2022
in thousands of BGN
Class of exposure
Gross amount of
loans and advances
to customers
Allowance for
impairment
Carrying amount of
loans and advances to
customers
Performin
g
Collectivel
y
impaired 5,550,250
(
54,521
)
5,495,729
Nonperformin
g
Collectivel
y
impaired 240,639
(
71,944
)
168,695
Individuall
y
impaired 976,420
(
256,303
)
720,117
Total 6,767,309
(
382,768
)
6,384,541
Notes to the financial statements
30
3. Risk management disclosures, continued
B. Non-trading activities, continued
(iii) Credit risk, continued
Distribution of trade receivables and impairment as adjustment for financial assets (receivables from
customers) according to the requirements of IFRS9:
31/12/2023 31/12/2022
Gross amount of
loans and
advances to
customers
Allowance
for
impairment
Gross amount of
loans and
advances to
customers
Allowance
for
impairment
Exposures without increase of
credit risk after the initial
recognition (phase 1)
5,483,101
(
3,866
)
4,285,771
(
4,227
)
Exposures with significant increase
of credit risk after the initial
recognition (phase 2)
1,052,972
(
51,797
)
1,264,479
(
50,294
)
Non-performing (impaired)
exposures (phase 3)
987,123
(
309,224
)
1,217,059
(
328,247
)
Total
7,523,196
(
364,887
)
6,767,309
(
382,768
)
Exposures classification into risk classes reflects the management’s estimate regarding credit risk and
the loans recoverable amounts.
As at 31 December 2023 the gross amount of overdue loans and advances to customers measured as
exposures 90+ days overdue is BGN 628,420 thousand (2022: BGN 804,062
thousand)
In addition, the Bank is exposed to off-balance sheet credit risk through commitments to extend credits
and issue contingent liabilities (See Note 32).
Concentrations of credit risk (whether on or off balance sheet) that arise from financial instruments exist
for counterparties when they have similar economic characteristics that would cause their ability to meet
contractual obligations to be similarly affected by changes in economic or other conditions.
The major concentrations of credit risk arise by location and type of customer in relation to the Bank’s
investments, loans and advances and off-balance sheet commitments.
Notes to the financial statements
31
3. Risk management disclosures, continued
B. Non-trading activities, continued
(iii) Credit risk, continued
Total economic sector credit risk concentrations in loans and advances to customers are presented in
the table below:
in thousands of BG
N
2023 2022
Trade 1,142,686 691,864
Industr
y
1,246,137 1,263,715
Services 632,773 602,983
Finance 140,139 178,683
Transport, lo
g
istics 179,416 224,795
Communications 77,502 107,859
Construction 413,143 386,055
Ag
riculture 227,553 231,850
Tourist services 388,899 302,557
Infrastructure 419,674 366,385
Private individuals 2,616,194 2,395,978
Other 39,080 14,585
A
llowance for impairment
(
364,887
)
(
382,768
)
Total 7,158,309 6,384,541
The amounts reflected in the tables represent the maximum accounting loss that would be recognised
at the statement of financial position date if counterparts failed completely to perform as contracted and
any collateral or security proved to be of no value. The amounts, therefore, greatly exceed expected
losses, which are included in the allowance for impairment.
The Bank has extended loans to enterprises involved in different types of activities but within the same
economic sector - industry. As such the exposures share a similar industry risk. There are three such
groups of enterprises at 31 December 2023 with total exposures outstanding amounting to BGN 277,095
thousand (2022: BGN 223,479 thousand) - ferrous and non-ferrous metallurgy, BGN 19,813 thousand
(2022: BGN 85,333 thousand) – mining industry and BGN 89,543 thousand (2022: BGN 60,752
thousand) - power engineering.
The Bank has extended loans, confirmed letters of credit and granted guarantees to 5 individual clients
or groups (2022: 7) with each individual exposure exceeding 10% of the capital base of the Bank, based
on the amortised cost of the respective loan facilities and after application of the required regulatory
exemptions and techniques for reducing credit risk. The total amount of these exposures was BGN
1,223,119 thousand, i.e. 79.57% of tier 1 capital (2022: BGN 1,265,514 thousand which represented
83.08% of tier 1 capital).
Notes to the financial statements
32
3. Risk management disclosures, continued
B. Non-trading activities, continued
(iii) Credit risk, continued
As at 31.12.2023 and as at 31.12.2022, there are no loans granted by the branch in Cyprus
The Bank’s policy is to require suitable collateral to be provided by certain customers prior to the
disbursement of approved loans. Guarantees and letters of credit are also subject to strict credit
assessments before being provided. The agreements specify monetary limits to the Bank’s obligations.
Collateral held against different types of assets:
Type of credit
exposure
Main type of collateral Collateral coverage ratio
2023 2022
Repurchase a
g
reements Tradable securities 99% 99%
Loans and advances to
banks None - -
Mort
g
a
g
e loans Real estate 262% 261%
Consumer lendin
g
Mortgage, warrant, financial
and other collateral 13% 14%
Credit cards None - -
Loans to companies
Mortgage, pledge of
enterprise, pledge of long-
term tangible assets, pledge
of goods, pledge of other
short-term tangible assets,
financial and other collateral 808% 649%
The distribution of the loan portfolio is reported according to the Bank’s business segments
The table below shows a breakdown of total gross loans and advances (gross balance sheet value)
extended to customers by the Bank by type of collateral to the amount of the collateral, excluding credit
cards in the amount of BGN 130,515 thousand. (2022: BGN 138,855 thousand).
in BGN ‘000 2023 2022
Mort
g
a
g
e
1,513,268
1,542,191
Pled
g
e of receivables
1,934,879
1,910,087
Pled
g
e of commercial enterprise
6,715
7,299
Securities
4,084
8,168
Bank
g
uarantees
3,750
3,750
Other
g
uaranties
3,462,847
2,892,788
Pled
g
e of machines
30,892
42,477
Mone
y
deposit
303,959
15,310
Unsecured
132,287
206,384
Total
7,392,681
6,628,454
The distribution of the loan portfolio is reported according to the Bank’s business segments
Other collateral includes insurance policies up to the amount of the insurance cover, future receivables,
remuneration transfers, etc.
Residential mortgage lending
The table below represents credit exposures from housing and mortgage loans to household customers
by ranges of loan-to-value (LTV) ratio. LTV is calculated as the ratio of the gross amount of the loan to
the value of the collateral. The gross amount excludes any impairment allowances. The valuation of the
Notes to the financial statements
33
collateral excludes any adjustments for obtaining and selling the collateral. The value of the collateral
for residential mortgage loans is based on the collateral value at origination updated based on changes
in house price indices.
The table below represents a separation of the gross amount of housing mortgages granted to
households according to the LTV ratio.
The distribution of the loan portfolio is reported according to the Bank’s business segments
Loans to corporate customers
The loans to corporate customers constituting individually significant exposures are subject to individual
credit appraisal and impairment testing. The general creditworthiness of a corporate customer tends to
be the most relevant indicator of credit quality of a loan. However, collateral provides additional security
and the Bank requests corporate borrowers to provide it. The Bank takes collateral in the form of a first
charge over real estate, floating charges over all corporate assets, and other liens and guarantees.
The Bank routinely analyses collateral for possible changes in value due to market conditions, legal
framework or debtor’s actions. Where such changes lead to a breach in the requirements for sufficiency
of collateral, the Bank requires provision of additional collateral within a certain timeframe.
As at 31 December 2023 the net carrying amount of individually impaired loans to corporate customers
amounts to BGN 581,494 thousand (2022: BGN 788,329 thousand) and the value of collateral held
against those loans amounts to BGN 549,859 thousand (2022: BGN 720,462 thousand).
The Bank constantly monitors the risk of default on already given loans and if there is available data for
potential or actual problems, the Bank prepares an action plan and takes measures for managing the
possible unwanted results, including restructuring of the loans
For the purposes of the disclosure in these financial statements “renegotiated loans” are defined as
loans, which have been renegotiated as a result of a change in the market interest rates, repayment
schedule, upon a client request, and others.
Loans renegotiated through the year
in thousands of BGN 2023 2022
Type of renegotiation
Gross amount of
loans and advances
to customers
Allowance
for
impairment
Gross amount of loans
and advances to
customers
Allowance
for
impairment
Loans to individuals 222,089 4,738 165,345 5,200
Change of maturity 120,212 4,001 114,425 4,026
Change in repayment instalments - - - -
Change of interest rate 61,727 - 13,037 -
Change due to customers request 27,301 28 25,224 46
Other reasons 12,849 709 12,659 1,128
Loans to companies 1,730,631 103,891 1,719,079 123,445
Change of maturity 118,429 251 104,789 262
Change in repayment instalments 305,693 359 319,997 691
Change of interest rate 236,611 1,273 109,282 58
Change due to customers request 821,649 54,923 927,801 31,895
Other reasons 248,249 47,085 257,210 90,539
Total: 1,952,720 108,629 1,884,424 128,645
The distribution of the loan portfolio is reported according to the Bank’s business segments
in BGN ‘000 2023 2022
Loan to value (LTV) ratio
Less than 50% 312,211 241,766
51% to 70% 445,553 401,108
71% to 90% 422,870 389,319
91% to 100% 9,448 12,261
More than 100% 87,660 83,962
Total 1,277,742 1,128,416
Notes to the financial statements
34
Structure and organization of credit risk management functions
Credit risk management as a comprehensive process is accomplished under the supervision of the
Management Board of the Bank. The Supervisory Board exercises control over the activities of the
Management Board on the credit risk management either directly or through the Risk Committee, which
supports the Supervisory Board with the extensive supervision over the risk management function in
the Bank, including over the formation of risk exposures.
There are collective bodies in the Bank the function of which is to support the activities of the
Management Board on the credit risk management- Credit Council and Restructuring Committee. The
Credit Council supports the adopted credit risk management and forms an opinion on loans as per its
limits of competence. The Restructuring Committee is a specialized body for supervision of the loan
exposures with indicators for deterioration. In addition to the collective bodies in the Bank, there are
other independent specialized bodies - the Risk Analysis and Control Department and the Credit Risk
Management, Monitoring and Provisioning Department, which fulfil the functions of identification,
evaluation and management of the credit risk, including performing additional second control over the
risk exposures. The realization, coordination and current control over the lending process is organized
from the following departments: Corporate Banking, SME financing, Retail Banking, and Loan
Administration, while the problem assets management is performed by the Impaired Assets Department.
(iv) Government debt exposures
The Bank carefully manages the credit risk associated with government debt.
The table below shows the carrying amount of the government debt portfolio by country issuer. The
assets are presented without any allowance for impairment. The Bank does not recognise allowance for
impairment against the government debt exposures which are measured at amortised cost as at 31
December 2023 and 31 December 2022 as well as those at fair value through other comprehensive
income.
in thousands of BGN
31/12/2023
Country issuer
at fair value through profit
and loss
at fair value through other
comprehensive income at amortised cost Total
Bulgaria
9 127,450 414,874 542,333
Lithuania - - 41,772 41,772
Latvia - 60 - 60
Slovakia - - 1,981 1,981
USA - 130,829 79,428 210,257
Romania 95 41,478 12,161 53,734
Italy - 38,405 1,962 40,367
Spain - 18,981 48,371 67,352
Portugal - - 20,181 20,181
Hungary - - 15,457 15,457
Croatia - 6,981 - 6,981
European Union - 141,883 68,581 210,464
Ireland - - 19,955 19,955
Saudi Arabia - - 9,984 9,984
Belgium - 48,582 95,907 144,489
France 9 95,830 155,510 251,340
Germany - 242,215 144,938 387,153
Great Britain - 33,503 22,455 55,958
Finland - 38,280 - 38,280
Switzerland - - 12,761 12,761
Austria - 48,789 - 48,789
Czechia - 38,360 - 38,360
Israel - 5,521 - 5,521
Total 104 1,057,147 1,166,278 2,223,529
Notes to the financial statements
35
3. Risk management disclosures, continued
B. Non-trading activities, continued
(iv) Government debt exposures, continued
in thousands of BGN
31/12/2022
Country issue
r
at fair value through
profit and loss
at fair value through other
comprehensive income
at amortised
cost Total
Bulgaria 14 159,178 416,480 575,672
Lithuania - 38,399 - 38,399
Latvia - 60 - 60
Slovakia - - 1,981 1,981
USA - 34,553 164,319 198,872
Romania 82 39,947 12,203 52,232
Italy - - 79,482 79,482
Spain - 18,460 126,133 144,593
Portugal - - 20,275 20,275
Hungary - - 15,430 15,430
Croatia - 6,978 - 6,978
European Union - - 233,382 233,382
Ireland - - 20,006 20,006
Saudi Arabia - - 10,044 10,044
Belgium - - 213,018 213,018
France - 48,497 87,114 135,611
Germany - - 234,162 234,162
Great Britain - 11,007 21,701 32,708
Finland - - 125,971 125,971
Switzerland - - 12,120 12,120
Total 96 357,079 1,793,821 2,150,996
Notes to the financial statements
36
3. Risk management disclosures, continued
B. Non-trading activities, continued
(iv) Government debt exposures, continued
Maturity table of government debt securities by country issuer as at 31 December 2023
in thousands of
BGN
Country issue
r
Up to 1
Month
From 1 to 3
Months
From 3
months to 1
yea
r
From 1 to 2
years
From 2 to 5
years Over
5 years Total
Bulgaria - - 27,460 142,216 138,628 234,029 542,333
Lithuania - - - - 41,772 - 41,772
Latvia - - 60 - - - 60
Slovakia - - - - 1,981 - 1,981
USA 79,368 70,249 60,581 - - 59 210,257
Romania - - - - 41,478 12,256 53,734
Italy - - 38,405 - - 1,962 40,367
Spain - - 48,371 - 18,981 - 67,352
Portugal - - - - - 20,181 20,181
Hungary - - - - - 15,457 15,457
Croatia - - - 6,981 - - 6,981
European Union - 67,988 141,882 - - 594 210,464
Ireland - - - - - 19,955 19,955
Saudi Arabia - - - - 9,984 - 9,984
Belgium - 48,582 95,907 - - - 144,489
France 29,278 126,232 95,830 - - - 251,340
Germany 87,890 48,648 250,615 - - - 387,153
Great Britain 22,455 33,503 - - - - 55,958
Finland - - 38,280 - - - 38,280
Switzerland - - 12,761 - - - 12,761
Austria 48,789 - - - - - 48,789
Czechia - - 38,360 - - - 38,360
Israel - - - - 5,521 - 5,521
Total 267,780 395,202 848,512 149,197 258,345 304,493 2,223,529
Notes to the financial statements
37
3. Risk management disclosures, continued
B. Non-trading activities, continued
(iv) Government debt exposures, continued
Maturity table of government debt securities by country issuer as at 31 December 2022
in thousands of
BGN
Country issue
r
Up to 1
Month
From 1 to 3
Months
From 3
months to 1
yea
r
From 1 to 2
years
From 2 to 5
years Over
5 years Total
Bulgaria - 15,060 20,818 26,795 272,059 240,940 575,672
Lithuania - - - - 38,399 - 38,399
Latvia - - - 60 - - 60
Slovakia - - - - 1,981 - 1,981
USA - 164,258 - 34,553 - 61 198,872
Romania - - - - 39,947 12,285 52,232
Italy - - 77,520 - - 1,962 79,482
Spain - 39,064 87,069 - 18,460 - 144,593
Portugal - - - - - 20,275 20,275
Hungary - - - - - 15,430 15,430
Croatia - - - - 6,978 - 6,978
European Union - - 232,788 - - 594 233,382
Ireland - - - - - 20,006 20,006
Saudi Arabia - - - - 10,044 - 10,044
Belgium - 39,047 173,971 - - - 213,018
France - - 135,611 - - - 135,611
Germany - 127,000 107,162 - - - 234,162
Great Britain 11,007 - 21,701 - - - 32,708
Finland - - 125,971 - - - 125,971
Switzerland - - - 12,120 - - 12,120
Total 11,007 384,429 982,611 73,528 387,868 311,553 2,150,996
3. Risk management disclosures
C. Capital adequacy
Since 1 January 2014, the provisions of the CRD IV package have been in force. Through Regulation
(EU) No 575/2013 on prudential requirements for credit institutions and investment firms and Directive
2013/36/EU on access to the activity of credit institutions and the prudential supervision of credit
institutions and investment firms, CRD IV package transposes into European law the provisions of the
new capital standards for banks – Basel III.
Regulatory capital
The equity capital of the Bank for regulatory purposes consists of the following elements:
Common Equity Tier 1 capital
a) issued and paid up capital instruments (ordinary shares);
b) share premium from issuance of ordinary shares;
c) audited retained earnings;
d) accumulated other comprehensive income, including revaluation reserves;
Notes to the financial statements
38
e) other reserves;
Deductions from components of the Common Equity Tier 1 capital include intangible assets, as well as
value adjustments due to the requirements for prudential assessments and other deductions.
The increase of CET1 includes the adjustments related to the transitional treatment of the effect from the
initial application of IFRS 9.
Additional Tier 1 capital
The instruments of Additional Tier 1 capital include hybrid debt (see note 29).
Tier 2 Capital
As at 31 December 2023 the Bank has no instruments classified as Tier 2 Capital.
Total own funds
2023 2022
In thousands of BG
N
Common Equit
y
Tier 1 capital
Paid up capital instruments 149,085 149,085
(-) Indirect shareholding in Common Equity Tier 1
capital instruments -
(
38
)
Premium reserves 250,017 250,017
Other reserves 939,921 858,717
A
ccumulated other comprehensive income
(
1,139
)
(
10,815
)
Ad
j
ustments of Common Equit
y
Tier 1 capital
(
-
)
Intan
g
ible assets
(
23,007
)
(
14,925
)
Transitional adjustments of Common Equity Tier 1
capital - 62,273
(
-
)
Other deductions
(
32,015
)
(
25,273
)
Common Equit
y
Tier 1 capital 1,282,862 1,269,041
Additional Tier 1 capital instruments
H
y
brid deb
t
254,258 254,258
Tier 1 Capital 1,537,120 1,523,299
Tier 2 Capital - -
Total own funds 1,537,120 1,523,299
Notes to the financial statements
39
3. Risk management disclosures, continued
С. Capital adequacy, continued
The Bank calculates the following ratios:
а) the Common Equity Tier 1 capital ratio is the Common Equity Tier 1 capital of the institution expressed
as a percentage of the total risk exposure amount;
b) the Tier 1 capital ratio is the Tier 1 capital of the institution expressed as a percentage of the total risk
exposure amount;
c) the total capital ratio is the own funds of the institution expressed as a percentage of the total risk
exposure amount.
The total risk exposure is calculated as the total of the risk weighted assets for credit, market and
operational risk.
The Bank calculates the requirements for credit risk for its exposures in banking and trading portfolios
based on a standardised approach. Exposures are taken into account using their balance sheet amount.
Off-balance-sheet credit-related commitments are taken into account by applying different categories of
conversion factors designed to convert these items into balance sheet equivalents. The resulting
equivalent amounts are then weighted for risk using different percentages depending on the class of
exposure and its credit rating assessment. Various credit risk mitigation techniques are used, for example
collateralised transactions and guarantees. Forwards and options based derivative instruments are
weighted for counterparty credit risk.
The Bank calculates also capital requirements for market risk for foreign currency and commodity
instruments in trading book and banking book.
The Bank calculates capital requirements for operational risk by application of the standardized approach.
In this approach the Bank distributes the net income from banking operations (called the relevant indicator)
over the last three years for the respective business lines. Next, the distributed amount from the relevant
indicator is multiplied by its corresponding percentage (beta factor) to obtain the annual capital requirement
for each business line. The Bank calculates the capital requirement for operational risk as the average
value for the three-year period of the sum of the annual capital requirements for all business lines. The
respective risk exposure is calculated by further multiplication of the capital requirement by 12.5.
The Bank has complied with the regulatory capital requirements throughout the period.
Capital adequacy level is as follows:
Notes to the financial statements
40
3. Risk management disclosures, continued
С. Capital adequacy, continued
BGN '000
Balance sheet/notional amount
Risk exposures
2023 2022 2023 2022
Risk weighted exposures for credit risk
Balance sheet assets
Exposure class
Central governments or central banks
4,110,854 3,636,457 73,763 2,009
Multilateral development banks
15 18 - -
International organizations
894 624 - -
Institutions
477,219 451,715 171,328 186,203
Corporates
2,925,782 2,435,831 2,318,383 2,046,646
Retail
1,646,175 1,531,781 1,103,871 1,024,212
Secured by mortgages on immovable property
2,140,151 1,842,333 803,006 683,701
Exposures in default
671,215 887,513 723,806 960,277
Collective investments undertakings
9,494 4,090 9,494 4,090
Equity
65,772 65,504 73,896 73,628
Other items
1,672,562 1,764,711 1,363,433 1,428,197
Total
13,720,133 12,620,577 6,640,980 6,408,963
Off balance sheet items
Exposure class
Institutions
- -
47 57
Corporates
648,425 545,383
47,008 40,086
Retail
508,173 459,869
4,602 4,631
Secured by mortgages on immovable property
29,206 20,091
5,661 3,883
Other items
- -
102 47
Total
1,185,804 1,025,343
57,420 48,704
Derivatives
Exposure class
Central governments or central banks
- - - -
Institutions
114 2,618 57 1,309
Corporates
1,829 1,953 1,829 1,953
Other items
2,327 1,548 2,327 1,548
Total
4,270 6,119 4,213 4,810
Total risk
-
weighted exposures for credit risk 6,702,613 6,462,477
Total amount of exposures to market risk
4,413 4,350
Amount of exposures for deferred risk
582,100 540,238
Total amount of risk exposures
7,289,126 7,007,065
Capital adequacy ratios Equity Capital ratios %
2023 2022 2023 2022
Common Equity Tier 1 capital
1,282,862 1,269,041
17.60% 18.11%
Tier 1 Capital
1,537,120 1,523,299
21.09% 21.74%
Total own funds
1,537,120 1,523,299
21.09% 21.74%
Notes to the financial statements
41
3. Risk management disclosures, continued
D. Other risks - war in Ukraine
On 24 February 2022 Russia began large-scale military action against Ukraine. In response to the Russian
actions against Ukraine, the EU member states and the USA imposed wide-ranging sanctions against
Russia and Belarus, including but not limited to, large Russian banks, some other companies, members of
the Russian parliament and some representatives of the Russian elite and their families, and also banned
primary/secondary trade in government bonds and other select securities. Secondary effects, such as the
increasing prices and the sufficiency of energy supply in Europe, as well as the economic impact of various
scenarios, are difficult to forecast and may have significant effects on the EU economy. The crisis has the
potential to exacerbate further the already tense situation with energy prices in Europe, which may lead to
slowing of the economy and to higher losses, including higher impairment.
The disruptions caused by the war have both direct and indirect impacts on the economy of EU countries,
leading to slower growth and higher inflation. The rapid rise in energy and food prices is feeding the global
inflation pressure and causing a swifter monetary policy response than earlier expected.
The risks to future development include the potential impacts on the business model of macroeconomic
and global geopolitical insecurity related to the Russian actions against Ukraine. Customers’ activities may
also be affected by the higher prices of energy and the disruption of supply chains.
The Bank monitors the situation closely, and carries out additional stress tests under different scenarios.
The Bank’s exposure to counterparties from Russia, Ukraine and Belarus is insignificant.
According to the Bank’s initial estimates, these events did not have direct significant impact on its
operations. In addition, the Management does not expect that as a whole the crisis would have immediate
significant impacts on the Bank’s operations.
Notes to the financial statements
42
4. Segment Reporting
Segment information is presented in respect of the Bank’s geographical segments. The primary format,
geographical segments, is based on the Bank’s management and internal reporting structure.
Reporting and measurement of segment assets and liabilities and segment revenues and results is based
on the accounting policies set out in the accounting policy notes.
Transactions between segments are conducted on an arm’s length basis.
The Bank operates principally in Bulgaria, but also has operations in Cyprus.
In presenting information on the basis of geographical segments, revenue and operating income is
allocated after interbranch eliminations based on the location of the Bank branch that generated the
revenue. Segment assets and liabilities are allocated after interbranch eliminations based on their
geographical location.
in BGN ‘000
Bulgarian operations Foreign operations Total
2023 2022 2023 2022 2023 2022
Interest income
391,224 310,748 13,487 37 404,711 310,785
Interest expense
(34,809) (37,726) 0 (2,319) (34,809) (40,045)
Net interest income
356,415 273,022 13,487 (2,282) 369,902 270,740
Fee and commission
income
181,797 159,085 10,808 13,905 192,605 172,990
Fee and commission
expense
(39,786) (32,087) (1,270) (1,388) (41,056) (33,475)
Net fee and
commission income
142,011 126,998 9,538 12,517 151,549 139,515
Net tradin
g
income
21,489 17,373 1,806 2,344 23,295 19,717
Administrative
expenses
(207,761) (202,013) (2,906) (3,100) (210,667) (205,113)
31.12.2023
31.12.2022
31.12.2023
31.12.2022
31.12.2023
31.12.2022
Assets
13,175,064 12,456,007 713,464 258,051 13,888,528 12,714,058
Liabilities
11,788,780 10,655,814 626,822 730,035 12,415,602 11,385,849
Notes to the financial statements
43
4. Segment Reporting, continued
The table below shows assets and liabilities and income and expense by business segments as at 31
December 2023.
in thousands of
BG
N
Business
Assets Liabilities
Net interest
income
Net fee and
commission
income
Net trading
income
Other net
operating
income
Lar
g
e enterprises 2,452,320 1,846,937 89,590 38,273 - 195
Medium enterprises 988,307 399,330 39,494 11,048 - 285
Small business 1,013,144 945,892 44,945 29,780 - 1,619
Retail Bankin
g
2,704,538 8,710,231 148,284 80,663 - 1,546
Treasur
y
5,171,239 54,326 74,274
(
2,712
)
23,295
(
39,344
)
Other 1,558,980 458,886
(
26,685
)
(
5,503
)
- 8,507
Total 13,888,528 12,415,602 369,902 151,549 23,295
(
27,192
)
5. Financial assets and liabilities
Accounting classification and fair values
The Bank’s accounting policy on fair value measurements is set out in Note 2(d)(vii).
The Bank measures fair values using the following fair value hierarchy that reflects the significance of the
inputs used in making the measurements:
Level 1: inputs that are quoted market prices (unadjusted) in active markets for identical instruments.
Level 2: inputs other than quoted prices included within Level 1 that are observable either directly (i.e. as
prices) or indirectly (i.e. derived from prices). This category includes instruments valued using: quoted
market prices in active markets for similar instruments; quoted prices for identical or similar instruments
in markets that are considered less than active; or other valuation techniques where all significant inputs
are directly or indirectly observable from market data.
Level 3: inputs are observable date for a given asset or liability. This category includes all instruments
where the valuation technique includes inputs not based on observable data and the unobservable inputs
have a significant effect on the instrument’s valuation. This category includes instruments that are valued
based on quoted prices for similar instruments where significant unobservable adjustments or
assumptions are required to reflect differences between the instruments.
Notes to the financial statements
44
5. Financial assets and liabilities, continued
Accounting classification and fair values, continued
Fair values of financial assets and financial liabilities that are traded in active markets are based on quoted
market prices or dealer price quotations. For all other financial instruments, the Bank determines fair
values using other valuation techniques.
Other valuation techniques include net present value and discounted cash flow models, comparison to
similar instruments for which market observable prices exist, option pricing models and other valuation
models. Assumptions and inputs used in valuation techniques include risk-free and benchmark interest
rates, credit spreads and other premia used in estimating discount rates, bond and equity prices, foreign
currency exchange rates, equity and equity index prices and expected price volatilities and correlations.
The objective of valuation techniques is to arrive at a fair value measurement that reflects the price that
would be received to sell the asset or paid to transfer the liability in an orderly transaction between market
participants at the measurement date.
The Bank uses widely recognised valuation models for determining the fair value of common and more
simple financial instruments, like interest rate and currency swaps that use only observable market data
and require little management judgement and estimation. Observable prices and model inputs are usually
available in the market for listed debt and equity securities, exchange traded derivatives and simple over
the counter derivatives like interest rate swaps. Availability of observable market prices and model inputs
reduces the need for management judgement and estimation and also reduces the uncertainty associated
with determination of fair values. Availability of observable market prices and inputs varies depending on
the products and markets and is prone to changes based on specific events and general conditions in the
financial markets.
However, where the Bank measures portfolios of financial assets and financial liabilities on the basis of
net exposures, it applies judgement in determining appropriate portfolio level adjustments such as bid-
ask spread.
Such adjustments are derived from observable bid-ask spreads for similar instruments and adjusted for
factors specific to the portfolio.
For more complex instruments, the Bank uses proprietary valuation models, which usually are developed
from recognised valuation models. Some or all of the significant inputs into these models may not be
observable in the market, and are derived from market prices or rates or are estimated based on
assumptions. Example of instruments involving significant unobservable inputs include certain over the
counter derivatives, certain loans and securities for which there is no active market and retained interests
in securitisations. Valuation models that employ significant unobservable inputs require a higher degree
of management judgement and estimation in the determination of fair value. Management judgement and
estimation are usually required for selection of the appropriate valuation model to be used, determination
of expected future cash flows on the financial instrument being valued, determination of probability of
counterparty default and prepayments and selection of appropriate discount rates.
The Bank has an established control framework with respect to the measurement of fair values. This
framework includes a Risk Management function, which is independent of Treasury division and reports
to management, and which has overall responsibility for independently verifying the results of trading and
investment operations and all significant fair value measurements. Specific controls include:
verification of observable pricing;
proposal of new models and changes to existing models is made by the Risk Analysis and Control
Division and approved by the Management Board;
calibration of models against observed market transactions;
analysis and investigation of significant daily valuation movements;
Notes to the financial statements
45
review of significant unobservable inputs, valuation adjustments and significant changes to the fair
value measurement of Level 3 instruments compared to previous month, by Risk Analysis and Control
division.
Where third-party information, such as broker quotes or pricing services, are used to measure fair value,
Risk Management division assesses and documents the evidence obtained from the third parties to
support the conclusion that such valuations meet the requirements of IFRS. This includes:
verifying that the broker or pricing service is approved by the Bank for use in pricing the relevant type
of financial instrument;
understanding how the fair value has been arrived at and the extent to which it represents actual
market transactions;
when prices for similar instruments are used to measure fair value, how these prices have been
adjusted to reflect the characteristics of the instrument subject to measurement;
where a number of quotes for the same financial instrument have been obtained, how fair value has
been determined using those quotes.
The tables below set out analysis of financial instruments measured at fair value at the end of the reporting
period classified by fair value hierarchy level framework categorising fair value measurement. The
amounts are based on the amounts in the statement of financial position.
in thousands of BGN
31 December 2023 Level 1 Level 2 Level 3 Total
Financial assets at fair value through profit or loss 11,958 231,548 85 243,591
Financial assets at fair value through other comprehensive
income
1,057,508 19,571 - 1,077,079
Derivatives held for risk management, net 1,079 686 - 1,765
Total 1,070,545 251,805 85 1,322,435
Financial liabilities at fair value through profit and loss - 3,165 - 3,165
in BGN ‘000
31 December 2022 Level 1 Level 2 Level 3 Total
Financial assets at fair value through profit or loss 5,862 261,740 85 267,687
Financial assets at fair value through other comprehensive
income 357,422 110,825 - 468,247
Derivatives held for risk management, net 718 891 - 1,609
Total 364,002 373,456 85 737,543
Financial liabilities at fair value through profit and loss - 8,488 - 8,488
The investments in securities reported in portfolios of financial assets at fair value in profit or loss, financial
assets at fair value in other comprehensive income and financial assets at amortised cost are mostly
investments in government securities from first-class issuers which are highly liquid and with the most
favourable capital treatment.
The bank manages its investments in debt securities in line with the current market expectations and
dynamics. As at 31.12.2023 the modified portfolio duration is 1.7 years, while a year earlier it was 2.2
years.
Notes to the financial statements
46
5. Financial assets and liabilities, continued
Accounting classification and fair values, continued
The tables below set out analysis of the fair values of financial instruments not recognised at fair value,
classified by fair value hierarchy level framework categorising fair value measurement
in thousands of BGN
31 December 2023 Level 1 Level 2 Level 3
Total fair
values
Total
balance
sheet value
Assets
Cash and balances with Central
Banks
- 2,325,807 - 2,325,807 2,325,807
Financial assets at amortised cos
t
1,171,101 - - 1,171,101 1,263,279
Loans and advances to banks
and other financial institutions
- 259,718 - 259,718 259,718
Loans and advances to
- 677,899 6,485,961 7,163,860 7,158,309
Total
1,171,101 3,263,424 6,485,961 10,920,486 11,007,113
Liabilities
Due to banks
- 54,326 - 54,326 54,326
Due to other customers
- 7,740,869 3,739,555 11,480,424 11,494,164
Liabilities evidenced b
y
paper
- 435,606 - 435,606 439,634
H
y
brid deb
t
- 257,871 - 257,871 257,871
Total
- 8,488,672 3,739,555 12,228,227 12,245,995
in BGN ‘000
31 December 2022 Level 1 Level 2 Level 3
Total fair
values
Total
balance
sheet value
Assets
Cash and balances with Central
Banks
- 1,911,371 - 1,911,371 1,911,371
Financial assets at amortised cos
t
1,743,044 - - 1,743,044 1,862,203
Loans and advances to banks
and other financial institutions
- 264,984 - 264,984 264,984
Loans and advances to
t
888,812 5,533,182 6,421,994 6,384,541
Total
1,743,044 3,065,167 5,533,182 10,341,393 10,423,099
Liabilities
Due to banks
- 45,703 - 45,703 45,703
Due to other customers
- 7,227,207 3,544,287 10,771,494 10,798,450
Liabilities evidenced b
y
paper
- 116,442 - 116,442 116,487
H
y
brid deb
t
- 256,861 - 256,861 256,861
Total
- 7,646,213 3,544,287 11,190,500 11,217,501
Notes to the financial statements
47
5. Financial assets and liabilities, continued
Accounting classification and fair values, continued
Where available, the fair value of loans and advances is based on observable market transactions. Where
observable market transactions are not available, fair value is estimated using valuation models, such as
discounted cash flow techniques. Input into the valuation techniques includes expected lifetime credit
losses, interest rates, prepayment rates. For collateral-dependent impaired loans, the fair value is
measured based on the value of the underlying collateral. To improve the accuracy of the valuation
estimate for retail and smaller commercial loans, homogeneous loans are grouped into portfolios with
similar characteristics such as product and borrower type, maturity, currency, collateral type.
The fair value of deposits from banks and customers is estimated using discounted cash flow techniques,
applying the rates that are offered for deposits of similar maturities and terms. The fair value of deposits
payable on demand is the amount payable at the reporting date.
6. Net interest income
in thousands of BG
N
2023 2022
Interest income
Accounts with and placements to banks and financial
institutions 4,836 1,505
Revenue from interest on liabilities - 5
Lar
g
e enterprise 93,147 77,063
Medium enterprise 39,934 32,358
Small business 45,626 37,200
Micro enterprise 9,397 7,427
Households 140,711 129,095
Debt instruments 71,060 24,520
Other interest income - 1,612
404,711 310,785
Interest expense
Deposits from banks
(
865
)
(
135
)
Deposits from other customers
(
1,043
)
(
1,567
)
Liabilities evidenced b
y
paper
(
7,041
)
(
533
)
H
y
brid deb
t
(
25,753
)
(
33,488
)
Interest expense on assets
(
19
)
(
4,285
)
Lease a
g
reements and other
(
88
)
(
37
)
(
34,809
)
(
40,045
)
Net interest income 369,902 270,740
For 2023 he recognized interest income from individually impaired financial assets (loans to customers)
amounted to BGN 28,605 thousand (2022: BGN 24,847 thousand).
The distribution of the loan portfolio is reported according to the Bank’s business segments
Notes to the financial statements
48
7. Net fee and commission income
in thousands of BG
N
Fee and commission income 2023 2022
Letters of credit and
g
uarantees 3,653 3,559
Pa
y
ment operations 31,075 28,421
Customer accounts
39,508 48,927
Card services
53,406 46,547
Other
64,963 45,536
192,605 172,990
Fee and commission expense
Letters of credit and
g
uarantees
(
967
)
(
640
)
Pa
y
ment s
y
stems
(
4,791
)
(
4,407
)
Card services
(
25,350
)
(
20,598
)
Other
(
9,948
)
(
7,830
)
(
41,056
)
(
33,475
)
Net fee and commission income 151,549 139,515
8. Net trading income
in thousands of BG
N
2023 2022
Net tradin
g
income arises from:
- Debt instruments 60 114
- Equities 1,087
(
656
)
- Forei
g
n exchan
g
e rate fluctuations 22,148 20,259
Net tradin
g
income 23,295 19,717
9. Other net operating income
in BGN ‘000 2023 2022
Other net operatin
g
income arisin
g
from:
-net income from transactions and revaluation of gold and
precious metals 1,570 2,068
Rental income 6,937 5,579
- Debt instruments
(
44,993
)
827
- Equities 5,649
(
303
)
- income from mana
g
ement of assi
g
ned receivables 3,282 5,620
- Gain on administration of loans acquired through business
combination 363 404
Other net operatin
g
income
(
27,192
)
14,195
Notes to the financial statements
49
10. Administrative expenses
in thousands of BG
N
2023 2022
General and administrative expenses comprise:
- Personnel cos
t
85,816 74,545
A
mortization of equipment and tan
g
ible fixed assets
12,969 12,060
Ri
g
hts of use assets
32,195 40,021
-
A
dvertisin
g
10,176 8,455
-Telecommunication, software and other computer
maintenance
15,351 13,753
- Other expenses for external services
54,160 56,279
Administrative expenses
210,667 205,113
Personnel costs include salaries, social and health security contributions under the provisions of the local
legislation. At 31 December 2023 the total number of employees was 2,408 (31 December 2022: 2,454).
The amounts accrued in 2023 for services provided by the registered auditors for independent financial audit
amounted to BGN 772 thousand. The amounts accrued in 2022 for services provided by the registered
auditors for independent financial audit amounted to BGN 1.064 thousand. In 2023 the amounts for other
services unrelated to audit provided by the registered auditors amounted to BGN 46 thousand. There are no
amounts accrued in 2022 for other services unrelated to audit and provided by the registered auditors.
11. Allowance for impairment
in thousands of BG
N
2023 2022
Write-downs
Loans and advances to customers
(
232,980
)
(
208,469
)
Off balance sheet commitments
(
243
)
(
625
)
Reversal of write-downs
Loans and advances to customers 95,022 72,929
Off balance sheet commitments 1,033 816
Impairment cost, net
(
137,168
)
(
135,349
)
The expense for impairment in 2023 and 2022 is due to additional allowances resulting from the
development of credit risk in a period of challenging economic environment and the conservative approach
applied by the Bank in recognising the risk of loss for certain individually impaired exposures.
12. Other income/(expenses), net
in thousands of BG
N
2023 2022
Proceeds/loss from the sale and write-off of assets acquired as
collateral
5,013 2,608
Revaluation of investment propert
y
- 14,769
Profit/
(
Loss
)
from sale and write-offs of investment propert
y
1,622
(
3,221
)
Dividend income 2,348 578
Cost of
g
uarantee schemes
(
23,838
)
(
24,534
)
Income for provisions for pendin
g
court cases
(
595
)
83
Other
(
expenses
)
/income, net
(
3,452
)
(
3,243
)
Total
(
18,902
)
(
12,960
)
Notes to the financial statements
50
13. Income tax expense
in BGN ‘000 2023 2022
Current taxes
(
15,996
)
(
8,325
)
Deferred taxes
(
See Note 20
)
220
(
1,215
)
Income tax expense
(
15,776
)
(
9,540
)
Reconciliation between tax expense and the accountin
g
profit is as follows:
in thousands of BG
N
2023 2022
Accountin
g
profit before taxation 150,816 90,745
Corporate tax at applicable tax rate (10% for 2023 and 10% for
2022
)
15,082 9,075
Effect of tax rates of forei
g
n subsidiaries and branches 415 195
Tax effect of permanent tax differences 279 270
Other differences - -
Income tax expense 15,776 9,540
Effective tax rate 10.46% 10.51%
14. Cash and balances with Central Banks
in thousands of BG
N
2023 2022
Cash on hand
- in BGN 242,301 184,774
- in forei
g
n currenc
y
69,462 63,766
Balances with Central Banks 1,844,620 1,427,241
Current accounts and amounts with forei
g
n banks 169,424 235,590
Total 2,325,807 1,911,371
15. Investments in securities
In thousands of BG
N
2023 2022
Bonds and notes issued b
y
:
Bul
g
arian Government
- denominated in BGN 428,625 446,417
- denominated in forei
g
n currencies 113,709 129,255
Forei
g
n
g
overnments 1,681,195 1,575,324
Corporates 280,619 405,558
Banks 39,114 10,477
Other issuers
equit
y
instruments 40,687 31,106
Total 2,583,949 2,598,137
Of which financial assets:
at fair value throu
g
h other comprehensive income 1,077,079 468,247
at amortised cost 1,263,279 1,862,203
at fair value throu
g
h profit and loss 243,591 267,687
Total 2,583,949 2,598,137
As at the end of 2023 there were not foreign government bonds subject to total return swap agreements.
As at the end of 2022 these amounted to BGN 37,831 thousand.
At the end of 2023, as at the end of 2022, no securities were subject to repurchase agreements.
The investments in securities reported in portfolios of financial assets at fair value in profit or loss, financial
assets at fair value in other comprehensive income and financial assets at amortised cost are mostly
Notes to the financial statements
51
investments in government securities from first-class issuers which are highly liquid and with the most
favourable capital treatment.
The bank manages its investments in debt securities in line with the current market expectations and
dynamics. As at 31.12.2023 the modified portfolio duration is 1.7 years, while a year earlier it was 2.2
years.
16. Loans and advances to banks and other financial institutions
(a) Analysis by type
in thousands of BG
N
2023 2022
Placements with banks 121,591 140,685
Other 138,127 124,299
Total 259,718 264,984
(b) Geographical analysis
in thousands of BG
N
2023 2022
Domestic banks and financial institutions 117,483 105,262
Forei
g
n banks and other financial institutions 142,235 159,722
Total 259,718 264,984
17. Loans and advances to customers
in thousands of BG
N
31/12/2023
Gross value
Allowance
for
impairment Amortised cost
Lar
g
e enterprise 2,557,431
(
105,111
)
2,452,320
Medium enterprise 1,179,493
(
191,186
)
988,307
Small business 1,021,711
(
8,565
)
1,013,146
Micro enterprise 216,593
(
1,142
)
215,451
Retail Bankin
g
- Consumer loans 1,139,711
(
38,521
)
1,101,190
- Mort
g
a
g
e loans 1,277,742
(
7,587
)
1,270,155
- Credit cards 130,515
(
12,775
)
117,740
- Other pro
g
rammes and collateralised financin
g
- - -
Total 7,523,196
(
364,887
)
7,158,309
in BGN ‘000
31/12/2022
Gross value
Allowance
for
impairment Amortised cost
Lar
g
e enterprise 2,270,652
(
119,107
)
2,151,545
Medium enterprise 1,085,974
(
186,337
)
899,637
Small business 878,135
(
10,929
)
867,206
Micro enterprise 198,538
(
2,019
)
196,519
Retail Bankin
g
- Consumer loans 1,063,724
(
41,873
)
1,021,851
- Mort
g
a
g
e loans 1,128,416
(
11,167
)
1,117,249
- Credit cards 138,855
(
11,336
)
127,519
- Other pro
g
rammes and collateralised financin
g
3,015 - 3,015
Total 6,767,309
(
382,768
)
6,384,541
The distribution of the loan portfolio is reported according to the Bank’s business segments
Notes to the financial statements
52
(a) Movement in impairment allowances
in thousands of BG
N
Balance as at 01 Januar
y
2023 382,768
A
dditional allowances 232,980
A
mounts released
(
95,022
)
Write-offs
(
225,693
)
Recovered a
g
ainst impairment 70,268
Other
(
414
)
Balance as at 31 December 2023 364,887
18. Property and equipment
in thousands of BGN
Land and
Buildings
Fixtures and
fittings
Motor
vehicles
Assets
under
Construction
Leasehold
Improvements Total
Cost
As at 1 January 2022 26,243 133,926 6,632 17,143 59,958 243,902
Additions - 6 - 35,517 - 35,523
Disposals - (6,760) (416) - (183) (7,359)
Transfers - 9,475 - (14,341) 940 (3,926)
As at 31 December 2022 26,243 136,647 6,216 38,319 60,715 268,140
Additions
32 52 26,986 - 27,070
Reclassified to investment
property (5,135) (235) - (48) - (5,418)
Disposals (591) (11,332) (133) (4) (10,463) (22,523)
Transfers 49 14,748 940 (47,902) 20,127 (12,038)
As at 31 December 2023 20,566 139,860 7,075 17,351 70,379 255,231
Amortisation
As at 01 January 2022 6,892 114,974 6,544 - 39,611 168,021
Accrued during the yea
r
969 5,636 57 - 2,566 9,228
On disposals - (6,751) (416) - (182) (7,349)
As at 31 December 2022 7,861 113,859 6,185 - 41,995 169,900
Accrued during the year
940 6,373 97 - 1,603 9,013
Reclassified to investment
property (801) (140) - - (941)
On disposals (331) (11,331) (133)
(10,463) (22,258)
As at 31 December 2023 7,669 108,761 6,149 - 33,135 155,714
Carrying amount
As at 01 January 2022 19,351 18,952 88 17,143 20,347 75,881
As at 31 December 2022 18,382 22,788 31 38,319 18,720 98,240
As at 31 December 2023 12,897 31,099 926 17,351 37,244 99,517
The fair value of assets constituting land and buildings was determined by independent property
assessors holding recognised professional qualification and recent experience in assessing property with
Notes to the financial statements
53
similar location and category. The Bank's policy requires that independent assessors determine the fair
value sufficiently frequently so as to ensure that the balance sheet value does not differ significantly from
the fair value at the end of the reporting period. As at 31 December 2023 the fair value of land and buildings
was not significantly different from their balance sheet value as at that date. The fair value of land and
buildings is categorised as Level 3 fair value on the basis of incoming data on the assessment
methodology used.
Assessment methodolo
gy
Significant unobservable
inputs
Connection between key
unobservable inputs and
fair value
1. Discounted cash flows: this valuation model
takes into account the present value of cash
flows generated by property, taking into account
the expected growth of rental prices, the period
required for cancellation, the level of
occupancy, premiums such as periods in which
no rent is paid and other expenses which are
not paid by tenants. The expected net cash
flows are discounted using discount rates
adjusted for risk. Among other factors, when
determining the discount rate, the quality of the
building and its location are taken into account
(first-rate or second-rate), as well as the
creditworthiness of the tenant and the duration
of the loan a
g
reement.
1. Expected market growth
of rent (4.5-6.8%, weighted
average 5.6%).
2. Period for cancellation (3
months on average after
each rental agreement).
3. Occupancy (90-95%,
weighted average 92.5%).
4. Periods when no rent is
paid (1 year for new rental
agreement).
5. Risk adjusted discount
rate (4-9%, weighted
average 6.5%).
The fair value will increase
(decrease) where:
the expected market growth
of rent is higher (lower);
periods for cancellation are
shorter (longer);
Occupancy is higher
(lower);
the periods when no rent is
paid are shorter (longer); or
the risk adjusted discount
rate is lower (higher).
2. Market approach/Comparative approach.
This method is based on the comparison of the
property being evaluated to other similar
properties which have been sold recently or
which are available for sale. Using this method,
the value of a given property is determined in
direct comparison to other similar properties
which have been sold in a period of time close
to the time when the valuation is made. Based
on detailed research, review and analysis of
data from the property market, the value is
formed and it is the most accurate indicator of
market value.
This method consists of using information about
actual transactions in the real estate market in
the last six months. Successful application of
this method is only possible where a trustworthy
database is available as regards actual
transactions with properties similar to the
property being valued. Information from real
estate sites, local press and other such refers to
future investment intentions of the seller and
cannot be deemed a trustworthy source of
information. When using such sites, the offer
price for each analogous property is discounted
at the valuator’s discretion, but by no less than
5%.
1. Expected market growth
of property (5-8%, weighted
average 6.5%).
2. Time required to effect
the sale (4 months on
average after the offer is
placed).
3. Transaction success rate
(90-96%, weighted average
95%).
4. Location (1.0-1.05,
weighted average 1.025).
5. Property status (1.0-1.1,
weighted average 1.05).
The fair value will increase
(decrease) where:
the expected market growth
of property is higher (lower);
the period of time required
for the sale is shorter (longer);
there is a change in the
technical condition of the
property
Notes to the financial statements
54
19. Intangible assets
in thousands of BG
N
Software and licences Total
Cost
As at 01 Januar
y
2022 47,255 47,255
A
dditions --
Disposals - -
Transfers 3,926 3,926
As at 31 December 2022 51,181 51,181
A
dditions
--
Transfers 12,038 12,038
As at 31 December 2023 63,219 63,219
Amortisation
As at 01 Januar
y
2022 33,424 33,424
A
ccrued durin
g
the
y
ear 2,832 2,832
On disposals - -
As at 31 December 2022 36,256 36,256
A
ccrued durin
g
the
y
ear 3,956 3,956
As at 31 December 2023 40,212 40,212
Carr
y
in
g
amount
As at 01 Januar
y
2022 13,831 13,831
As at 31 December 2022 14,925 14,925
As at 31 December 2023 23,007 23,007
20. Deferred Taxation
Deferred income taxes are calculated on all temporary differences under the liability method using a
principal tax rate of 10%.
Deferred income tax assets and liabilities are attributable to the following items:
in BGN ‘000 Assets Liabilities Net
2023 2022 2023 2022 2023 2022
Propert
y
, equipment and intan
g
ibles - - 3,144 2,852 3,144 2,852
Investment Propert
y
- - 24,368 24,815 24,368 24,815
Other
(
243
)
(
178
)
334 334 91 156
Net tax
(
assets
)
/liabilities
(
243
)
(
178
)
27,846 28,001 27,603 27,823
Movements in temporary differences in 2023 at the amount of BGN (220) thousand are recognised in the
profit for the year.
21. Repossessed assets
in thousands of BG
N
2023 2022
Land 241,213 245,557
Buildin
g
s 151,735 156,173
Machines, plant and vehicles 9,746 10,425
Fixtures and fittin
g
s 829 841
Total 403,523 412,996
Notes to the financial statements
55
21. Repossessed assets, continued
Repossessed assets acquired as collateral are measured at the lower of cost and net realisable value.
The net realizable value of the lands and buildings is approximately equal to their fair value. The
assessment methodology for land and buildings is given in note 18.
22. Investment Property
in thousands of BGN
Balance as at 01 Januar
y
2023 750,324
A
dditions 147
Costs reco
g
nized in the value of assets 11,351
Transferred from repossessed assets -
Transferred from propert
y
and equipment 4,477
Revaluation of investment propert
y
to the fair value reco
g
nised at transfer -
Write-offs upon sale
(
9,532
)
Balance as at 31 December 2023 756,767
23. Investments in subsidiaries
Investments in subsidiaries (see Note 36) are as follows:
31/12/2023
in thousands o
f
BG
N
Entity: % held Acquisition cost
Allowance
fo
r
impairment
Carrying
amount
Diners Club Bulgaria AD 96.51% 5,743 - 5,743
First Investment Bank − Albania Sh.a. 100% 23,420 - 23,420
Debita OOD 70% 105 (104) 1
Fi Health Insurance AD 59.10% 3,315 - 3,315
Creative Investment EOOD 100% - - -
Lega Solutions EOOD 100% - - -
AMC Imoti EOOD 100% - - -
MyFin EAD 100% 2,000 - 2,000
Incasso Guarant EOOD 100% 100 - 100
Total 34,683 (104) 34,579
31/12/2022
in thousands o
f
BG
N
Entity: % held Acquisition cost
Allowance
fo
r
impairment
Carrying
amount
First Investment Finance B.V., Netherlands 100% 3,947 - 3,947
Diners Club Bulgaria AD 96.51% 5,743 - 5,743
First Investment Bank − Albania Sh.a. 100% 23,420 - 23,420
Debita OOD 70% 105 (104) 1
Fi Health Insurance AD 59.10% 3,315 - 3,315
Creative Investment EOOD 100% - - -
Lega Solutions EOOD 100% - - -
AMC Imoti EOOD 100% - - -
MyFin EAD 100% 2,000 - 2,000
Incasso Guarant EOOD 100% 100 - 100
Total 38,630 (104) 38,526
Notes to the financial statements
56
24. Rights of use assets
in thousands of BG
N
As at 01 Januar
y
2023 124,159
A
mortisation
(
32,195
)
Effect of modification to lease terms and expectations on lease term 29,446
As at 31 December 2023 121,410
Lease liabilities
As at 01 Januar
y
2023 124,240
Lease pa
y
ments
(
32,183
)
Effect of modification to lease terms and expectations on lease term 29,446
As at 31 December 2023 121,503
Right-of-use assets recognised by the Bank are the branches and offices in various towns in Bulgaria and
Cyprus, as well as the buildings in which the Bank's headquarters are located - lines Upon completing the
initial recognition, the Bank analysed and took into account information on the expected duration of the
period in which the Bank will be using the assets. In 2023 some of these expectations changed and as a
result the Bank reviewed its initial assessment and recognized an increase in the right-of-use assets in
the amount of BGN 29,445 thousand, and in lease liabilities in the amount of BGN 29,445 thousand.
In the assessment of right-of-use assets and lease liabilities, the Bank took into consideration the current
level of financing costs in case it plans to finance the purchase of the assets in question, and included
this assumption both in the initial, and in the subsequent valuation of right-of-use assets and of lease
liabilities.
The table below analyses lease liabilities according to the expected residual term of rental agreements:
In BGN '000 Maturity analysis of lease liabilities
To 1
y
ea
r
From 1 to 5
y
ears Total
A
s at 1 Januar
y
2023 29,530 94,710 124,240
A
s at 31 December 2023 28,479 93,024 121,503
25. Other assets
in thousands of BG
N
2023 2022
Deferred expense
13,071 11,338
Gold
3,303 2,642
Other assets
103,803 100,266
Total
120,177 114,246
26. Due to banks
in thousands of BG
N
2023 2022
Term deposits
5,553 3,668
Pa
y
able on demand 48,773
42,035
Total 54,326
45,703
Notes to the financial statements
57
27. Due to other customers
in thousands of BG
N
2023 2022
Retail customers
- current accounts 3,355,008 2,859,322
- term and savin
g
s deposits 4,417,226 4,401,427
Businesses and public institutions
- current accounts 3,165,857 3,157,892
- term deposits 556,073 379,809
Total 11,494,164 10,798,450
28. Other borrowed funds
in thousands of BG
N
2023 2022
Debt related to a
g
reements for full swap of profitabilit
y
- 39,874
Financin
g
from financial institutions
34,574 36,611
Liabilities related to a structured investment produc
t
1,167 6,884
Obli
g
ations under loan a
g
reements
403,893 33,118
Total
439,634 116,487
Financing from financial institutions through extension of loan facilities can be analysed as follows:
in thousands of BGN
Lende
r
Interest rate Maturity
Amortised cost as at
31 December 2023
European Investment Fund – JEREMIE 2 0% - 4.68% 30/09/2025 877
Bulgarian Development Bank AD - program for
promotion of SMEs and micro 0% - 4.85% 15/03/2027 11,260
Bulgarian Development Bank AD - program for
indirect financing of SMEs 0% - 5.68% 30/11/2028 3,071
Fund Manager of financial instruments in Bulgaria -
microcredit program with shared risk 0% - 2.96% 31/12/2033 10,048
Fund Manager of financial instruments in Bulgaria -
rural financing program 0% - 2.96% 31/12/2031 9,318
Total 34,574
in BGN ‘000
Lende
r
Interest rate Maturity
Amortised cost as at 31
December 2022
European Investment Fund – JEREMIE 2 0% - 2.79% 30/09/2025 1,506
Bulgarian Development Bank AD - program for
promotion of SMEs and micro 3.05% 15/03/2027 11,251
Bulgarian Development Bank AD - program for
indirect financing of SMEs 3.85% 30/11/2028 3,680
Fund Manager of financial instruments in Bulgaria
- microcredit program with shared risk 0% 31/12/2033 10,636
Fund Manager of financial instruments in Bulgaria
- rural financing program 0% 31/12/2031 9,538
Total 36,611
Notes to the financial statements
58
29. Hybrid debt
in thousands of BG
N
Principal
amount
Amortised cost as at
31 December 2023
H
y
brid debt with principal EUR 60 mio 117,350 123,821
H
y
brid debt with principal EUR 30 mio 58,675 58,829
H
y
brid debt with principal EUR 30 mio 58,675 55,618
H
y
brid debt with principal EUR 10 mio 19,558 19,603
Total 254,258 257,871
in BGN ‘000
Principal
amount
Amortised cost as at 31
December 2022
H
y
brid debt with principal EUR 60 mio 117,350 123,839
H
y
brid debt with principal EUR 30 mio 58,675 58,829
H
y
brid debt with principal EUR 30 mio 58,675 54,590
H
y
brid debt with principal EUR 10 mio 19,558 19,603
Total 254,258 256,861
In December 2021, the Bank attracted by issuing first and second tranche of the issue ISIN code
XS2419929422 Hybrid Debt Issue total EUR 27,133
In April 2022, the Bank attracted by issuing third tranche of the issue ISIN code XS2419929422 Hybrid
Debt Issue for EUR 2,867
In August 2022, the Bank attracted by issuing first tranche of the issue ISIN code XS2488805461 Hybrid
Debt Issue for EUR 10,000
The bonds under all instruments are registered, dematerialized, interest-bearing, perpetual, unsecured,
freely transferable, non-convertible, deeply subordinated and without incentive to redeem.
All hybrid instruments fully comply with the requirements of Regulation 575/2013 and are included in the
additional tier 1 capital.
30. Other liabilities
in thousands of BG
N
2023 2022
Liabilities to personnel
1,207
1,157
Provisions for pendin
g
court cases
1034
440
Impairment on off balance sheet commitments
363
1,152
Other pa
y
ables
12,703
4,650
Total
15,307
7,399
The provisions for pending court cases were calculated on the basis of the Bank's expectations (using
internal and external experts) regarding the outcome of these court cases.
31. Capital and reserves
(a) Number and face value of registered shares as at 31 December 2023
The subscription for the public offering of shares of First Investment Bank AD was completed successfully
on 3 July 2020. Out of the 40 000 000 ordinary dematerialized shares with nominal value of BGN 1, and
issue value of BGN 5.00 each, a total of 39 084 800 shares were subscribed and paid up.
On 31 July 2020 First Investment Bank’s capital increase was registered in the Commercial Register and
Register of Non-for-profit Legal Entities. This registration was carried out after the subscription for shares
Notes to the financial statements
59
was successfully completed on 03 July 2020 based on the prospectus confirmed by the Financial
Supervision Commission.
Thus, the Bank’s capital was increased to BGN 149 084 800 by issue of 39 084 800 new ordinary,
registered, dematerialized shares, each with one voting right in the general meeting, with nominal value of
BGN 1 and issue value of BGN 5. The amount of the capital after the increase was reflected in the By-
Laws of First Investment Bank AD after approval granted by the Bulgarian National Bank.
With relation to this issue, the Bank’s premium reserve increased by BGN 153,017 thousand, net of the
issue costs, reaching a total amount of BGN 250,017 thousand
(b) Shareholders
The table below shows those shareholders of the Bank holding shares as at 31 December 2023 together
with the number and percentage of total issued shares.
Number of
shares
% of issued share
capital
Mr. Ivailo Dimitrov Mutafchiev 46,750,000 31.36
Mr. Tzeko Todorov Minev 46,750,000 31.36
Bul
g
arian Bank for Development AD 27,350,000 18.35
Valea Foundation 11,734,800 7.87
Other shareholders (shareholders holding shares subject
to free trade on the Bulgarian Stock Exchange – Sofia)
16,500,000 11.06
Total 149,084,800 100.00
(c) Statutory reserve
Statutory reserves include amounts set aside for purposes regulated by local legislation. According to
Bulgarian legislation the Bank is obliged to set aside at least 1/10 of its annual profit as statutory reserve
until the total amount of reserves reaches 1/10 of the Bank’s share capital.
In 2023, as in the previous year, the Bank did not distribute dividends.
32. Commitments and contingent liabilities
Contingent liabilities
The Bank provides financial guarantees and letters of credit to guarantee the performance of customers
to third parties. These agreements have fixed limits and generally extend for a period of up to two years.
The contractual amounts of commitments and contingent liabilities are set out in the following table by
category. The amounts reflected in the table for contingent liabilities represent the maximum accounting
loss that would be recognised in the statement of financial position if counterparts failed completely to
perform as contracted and any collateral or security proved to be of no value.
in thousands of BG
N
2023 2022
Bank
g
uarantees
160,443 157,251
Unused credit lines
992,286 837,477
Letters of credit
33,438 31,767
Total
1,186,167 1,026,495
Impairment on off balance sheet commitments
363 1,152
Notes to the financial statements
60
32. Commitments and contingent liabilities, continued
Contingent liabilities, continued
These commitments and contingent liabilities have off balance-sheet credit risk and only organization
fees and accruals for probable losses are recognised in the statement of financial position until the
commitments are fulfilled or expire. Most of the contingent liabilities and commitments will expire without
being advanced in whole or in part. Therefore, the amounts do not represent expected future cash flows.
The contingent loan is a framework agreement for collateral management under numerous loan
transactions made with one or more clients. The contingent loan does not lead to an obligation of the
Bank to extend specific financial instruments. The conclusion of a specific loan transaction with the Bank
client, e.g. extension of a loan or overdraft, contingent liabilities, such as bank guarantees and letters of
credit, is subject to a separate decision and approval of the Bank.
As at the date of the report there are no other significant contingent liabilities and commitments requiring
additional disclosure.
33. Cash and cash equivalents
For the purposes of the cash flow statement, cash and cash equivalents comprises the following balances
with less than 90 days original maturity:
in BGN ‘000 2023 2022
Cash and balances with Central Banks 2,325,807 1,911,371
Loans and advances to banks and financial institutions with
ori
g
inal maturit
y
less than 3 months 229,787 227,006
Total 2,555,594 2,138,377
34. Average balances
The average carrying amounts of financial assets and liabilities are set out in the table below. The
amounts are calculated by using a simple average of monthly balances for all instruments.
in BGN ‘000 2023 2022
FINANCIAL ASSETS
Cash and balances with Central Banks
1,771,271 2,232,611
Investments in securities
2,808,824 1,655,201
Loans and advances to banks and other financial
institutions
233,999 190,966
Loans and advances to customers
6,700,563 6,300,194
FINANCIAL LIABILITIES
Due to banks
30,748 18,443
Due to other customers
11,019,692 10,056,144
Liabilities evidenced b
y
paper
194,344 97,161
H
y
brid deb
t
261,073 327,160
35. Related party transactions
Parties are considered to be related if one party has the ability to control or exercise significant influence
over the other party on making financial or operational decisions, or both parties are under common
control.
A number of banking transactions are entered into with related parties in the normal course of business.
These include loans, deposits and other transactions. These transactions were carried out on commercial
terms and at market rates. The volume of these transactions and outstanding balances at the end of
respective periods are as follows:
Notes to the financial statements
61
T
y
pe of related part
y
Parties that control or manage
the Bank
Enterprises under common
control
BGN '000 2023 2022 2023 2022
Loans
Loans outstanding at beginning of the
period
2,944 3,515 78,316 83,666
Loans issued/
(
repaid
)
durin
g
the period
(
1,391
)
(
571
)
(
6,957
)
(
5,350
)
Loans outstandin
g
at end of the period 1,553 2,944 71,359 78,316
Deposits and loans received:
A
t be
g
innin
g
of the period 14,195 13,725 115,177 125,350
Received/
(
paid
)
durin
g
the period
1,949 470 (34,426) (10,173)
A
t the end of the period
16,144 14,195 80,751 115,177
Deposits placed
Deposits at be
g
innin
g
of the period - - 92,146 5,868
Deposits placed/
(
matured
)
durin
g
the
y
ear - -
(10,808) 86,278
Deposits at end of the period - - 81,338 92,146
Other receivables
A
t be
g
innin
g
of the period - - 12,467 18,037
Received/
(
paid
)
durin
g
the period - - 2,651
(
5,570
)
A
t the end of the period - - 15,118 12,467
Other borrowin
g
s
A
t be
g
innin
g
of the period - - 150 420
Received/
(
paid
)
durin
g
the period - - 6,184
(
270
)
A
t the end of the period - -
6,334 150
Off-balance sheet commitments issued
b
y
the Bank
A
t be
g
innin
g
of the period 1,023 1,061 2,029 2,792
Issued/
(
expired
)
durin
g
the period 1,077
(
38
)
1,512
(
763
)
A
t the end of the period 2,100 1,023 3,541 2,029
Calculation on leasin
g
obli
g
ations
A
t be
g
innin
g
of the period - - 2,684 1,513
Received/
(
paid
)
durin
g
the period - -
(
15
)
1,171
A
t the end of the period - - 2,669 2,684
Notes to the financial statements
62
35. Related party transactions, continued
The key management personnel received remuneration of BGN 11,288 thousand for 2023 (2022: BGN
12,068 thousand).
36. Subsidiaries
(a) First Investment Finance B.V.
In April 2003 the Bank created a special purpose entity, incorporated in the Netherlands, First Investment
Finance B.V. The company is owned by the Bank. The purpose for creating the entity is to accomplish a
narrow and well-defined objective of receiving loans from foreign financial institutions and attracting
investors by issuing bonds and other financial instruments guaranteed by the Bank. The entity’s issued
and paid up share capital is EUR 18 thousand divided into 180 issued and paid up shares, each with
nominal value of EUR 100.
After completion of winding-up proceedings (between 19.09.2023 and 27.12.2023), on 27.12.2023 the
company was deregistered.
(b) Diners Club Bulgaria AD
In May 2005 the Bank acquired 80% of the share capital of Diners Club Bulgaria AD. The company was
incorporated in 1996 as a franchise and processing agent of Diners Club International. As at 31 December
2023 the share capital of the company is BGN 910 thousand, and the Bank’s shareholding is 96.51%.
(c) First Investment Bank − Albania Sh.a.
In April 2006 the Bank acquired 99.9998% of the capital of First Investment Bank Albania Sh.a. upon
its incorporation. On 27 June 2007 First Investment Bank – Albania was granted a full banking licence by
the Bank of Albania, and on 1 September 2007 it effectively took over the activities of the former branch
FIB – Tirana, assuming all rights and obligations, assets and liabilities.
As at 31 December 2023 the share capital of First Investment Bank Albania Sh.a. was EUR 11,975
thousand, fully paid up, and the Bank’s shareholding is 100%.
(c) Debita OOD
Acting jointly the Bank and First Financial Brokerage House OOD (FFBH) set up two new companies
Debita OOD and Realtor OOD, which were entered in the Commercial Registry in January 2010. The
capital of the two companies is BGN 150,000 each, distributed in shares with value of BGN 100 each, as
follows: Realtor OOD - 70%, i.e. 1.050 shares for the Bank and 30%, i.e. 450 shares for FFBH OOD.
The company was established as a servicing company within the meaning of Article 18 of the Law on
Special Investment Purpose Companies, currently a company within the meaning of Article 27 of the Law
on Special Purpose Investment Companies and Securitisation Companies. The main lines of business
for Debita OOD include acquisition, servicing, management and disposal of receivables and the related
consultancy services
Type of related party
Parties that control or
mana
g
e the Bank
Enterprises under common
control
BGN '000 2023 2022 2023 2022
Interest income 31 35 4,193 3,065
Interest expense 7 8 1,512 231
Fee and commission income 30 27 771 1,769
Fee and commission expense 7 6 6 301
Notes to the financial statements
63
(e) Realtor OOD
Acting jointly the Bank and First Financial Brokerage House OOD (FFBH) set up new company Realtor
OOD, which were entered in the Commercial Registry in January 2010. The capital of the two companies
is BGN 150,000 each, distributed in shares with value of BGN 100 each, as follows: Realtor OOD - in
liquidation - 51%, i.e. 765 shares for the Bank and 49%, i.e. 735 shares for FFBH OOD
The company were established as servicing companies within the meaning of Article 18 of the Law on
Special Investment Purpose Companies. The main lines of business for Realtor OOD include
management, servicing and maintenance of real estate, construction and refurbishment works and
consultancy in the field of real estate.
By the decision of the general meeting of associates held on 14.06.2021 the operations of Realtor OOD
were terminated and winding-up proceedings were initiated, to be completed within six months. The notice
to creditors was published in the Commercial Register and Register of Non-for-Profit Legal Entities on
08.09.2021, and this is the starting date of the period for winding-up.
Realtor OOD has been deregistered from the Commercial Register and Register of Non-Profit Legal
Entities with the Registration Agency as from 20.07.2022.
(f) Fi Health Insurance AD
In the second half of 2010 the Bank acquired a majority stake capital of Health Insurance Fund FI Health
AD (formerly Health Insurance Fund Prime Health AD), a company engaged in voluntary health insurance
as well as acquisition, management and sale of investments in other companies. With a decision of the
Financial Supervision Commission issued in June 2013 the company has been granted a license to
operate as an insurer. The name was changed to FI Health Insurance AD and the principal activity is
insurance Disease and Accident. In June 2018 the company expanded its license with one more
insurance class - "Various financial loss". As at 31 December 2023 the share capital of the company is
BGN 5,000 thousand, and the Bank’s shareholding is 59.10%.
(g) Balkan Financial Services EAD
In February 2011 the Bank acquired 100 shares representing 100% of the capital of Balkan Financial
Services EOOD. The company is engaged in consultancy services related to implementation of financial
information systems and software development. In January 2012 the company was transformed into a
sole-shareholder company. As at 31 December 2021 the share capital of the company is BGN 6,437
thousand, and the Bank’s shareholding is 100%.
On 11.11.2021 the Management Board of First Investment Bank as the sole shareholder of Balkan
Financial Services EOOD decided to terminate the company, announce its liquidation and open winding-
up proceedings; this resolution was approved by the Supervisory Board on 22.12.2021.
Balkan Financial Services EAD has been deregistered from the Commercial Register and Register of
Non-Profit Legal Entities with the Registration Agency as from 09.12.2022.
(h) Turnaround Management EOOD - deleted trader, Creative Investment EOOD and Lega Solutions
EOOD
During the first half of 2013 the Bank established as the sole shareholder the companies Turnaround
Management EOOD, Creative Investment EOOD and Lega Solutions EOOD. Each company has the
minimum required capital of BGN 2 and their principal activities include manufacturing and trade in goods
and services in Bulgaria and abroad (Turnaround Management EOOD, Creative Investment EOOD),
acquisition, management and sale of assets, information processing, financial consultations (Lega
Solutions EOOD), etc.
After completion of winding-up proceedings for Turnaround Management EOOD, based on a resolution
of the Management Board of First Investment Bank as the sole shareholder dated 07.01.2021 and
approved by the Bank’s Supervisory Board on 20.01.2021, on 11.01.2022 the company was delisted in
the Commercial Register and Register of Non-for-Profit Legal Entities.
Notes to the financial statements
64
(i) AMC Imoti EOOD
AMC Imoti EOOD was registered in September 2010 and was acquired by the Bank in 2013 through the
purchase of MKB Unionbank EAD as its subsidiary. The scope of operations of the company includes
activities related to acquisition of property rights and their subsequent transfer, as well as research and
evaluation of real estate, property management, consulting and other services. As at 31 December 2023
the capital of the company was BGN 500 thousand, and the Bank was the sole owner.
(j) MyFin EAD
At its meeting held on 21 March 2019 the Bank's Managing Board decided to establish the sole-
shareholder company MyFin EAD to be operating as an issuer of electronic money within the meaning of
Article 34, Para. 2(2) of the Payment Services and Payment Systems Act. The Managing Board decision
was approved by the Supervisory Board on 27 March 2019. On 19 April 2019 the Bank paid up the
company's capital, amounting to BGN 1,000 thousand, as per the decisions of the competent bodies. The
company holds a license to operate as an electronic money institution, and also has the right to carry out
the activities listed in the payment services license, as stated in the company’s scope of operation by
Resolution No. 71 of 27.02.2020 issued by the BNB Governor, under No. BNB-26660/02.03.2020. After
the company obtained its license, it was listed in the Commercial Register and Register of Non-Profit
Legal Entities on 25.03.2020 under listing No. 20200325093135.
The company’s own capital was increased from BGN 1 000 thousand to BGN 2 000 thousand through
the issue and subscription by the Bank as the sole shareholder of 1 000 000 new ordinary registered
dematerialised voting shares, each with a nominal value of BGN 1 (one), for a total value of BGN 1 000
000 (one million). The resolution for the capital increase was made by the Management Board at its
meeting held on 17.06.2021, and then approved by the Bank’s Supervisory Board on 30.06.2021. The
company’s company increase was listed in the Commercial Register and Register of Non-Profit Legal
Entities on 02.09.2021 under listing No. 20210902164014.
(k) Incasso Guarant EOOD
Incasso Guarant EOOD was established by Management Board resolution of 09.08.2022 approved by
the Supervisory Board on 24.08.2022, and listed in the Commercial Register and Register of Non-for-
Profit Legal Entities on 09.09.2022; its field of operation will be: private security services, personal
(professional) security services for individuals, security of valuable shipments and cargo, security of
railway transport, security of property of both individuals and legal entities, of buildings, premises and
business facilities, security with the help of signal-notifying equipment (subject to licensing), development,
design and construction of high-tech systems for security and video surveillance, as well as any
commercial activity not prohibited by law.
As at 31 December 2023 the capital of the company is BGN 100 thousand, and the Bank is the sole
owner.
37. Post balance sheet events
No adjusting and significant non-adjusting events have occurred after the end of the reporting period,
other than those disclosed below:
At the General Meeting of Shareholders of Diners Club Bulgaria AD held on 09.02.2024 a resolution
was made to terminate the operation of Diners Club Bulgaria AD as a payment institution,
respectively - to terminate the company's activities for representation of Diners Club International.
Following a procedure pursuant to the Law on Payment Services and Payment Systems, the
Governing Council of the Bulgarian National Bank issued resolution No. 58 of 15.02.2024 approved
the plan proposed by the company for termination of its activities and revoked its license, as of
15.04.2024.
1
REPORT OF THE INDEPENDENT AUDITOR
To the shareholders of the
First Investment Bank AD
Report on the audit of the individual financial statements
Opinion
We have audited the individual financial statements of First Investment Bank AD (the "Bank"),
which include the individual statement of financial position as at 31 December 2023 and the
individual profit or loss statement and other comprehensive income, the individual statement of
changes in equity and the individual cash flow statement for the year ending that date, as well
as the notes to the individual financial statements, material information about accounting
policies.
In our opinion, the attached individual financial statements present fairly, in all material respects,
the individual financial position of the Bank as at 31 December 2023 and its individual financial
performance and individual cash flows for the year ending that date, in accordance with
International Financial Reporting Standards (IFRS) adopted by the European Union (EU).
Basis for expressing an opinion
We conducted our audit in accordance with International Standards on Auditing (ISAs). Our
responsibilities under these standards are further described in the section of our report "Auditor's
Responsibilities for the Audit of the Individual Financial Statements". We are independent of the
Bank in accordance with the International Code of Ethics for Professional Accountants (including
International Independence Standards) of the International Standards of Ethics for Accountants
Board (the IAMS Code), together with the ethical requirements of the Independent Financial
Audit Act (IFA) applicable to our audit of financial statements in Bulgaria, and we have fulfilled
our other ethical responsibilities in accordance with the requirements of the IFRA and the IASB
Code. We believe that the audit evidence we have obtained is sufficient and appropriate to
provide a basis for our opinion.
Key audit matters
Key audit matters are those matters that, in our professional judgment, were of the greatest
significance in the audit of the current period's financial statements. These matters were
considered as part of our audit of the individual financial statements as a whole and the
formation of our opinion thereon, and we do not provide a separate opinion on these matters.
Impairment of receivables from customers
Key audit question
The impairment of receivables from clients is a significant management judgement on losses
that would be recognised within the Bank's loan portfolio for the relevant reporting period.
The bank assesses the need for credit impairment on an individual and portfolio basis.
2
This process involves various assumptions and measurement of factors, including an analysis
of the financial position of the credited client, estimated future cash flows from its operations,
the value of the collateral on the loan, etc.
As a result of the use of different modelling techniques and assumptions, these may lead to
differences in the measurement of impairment of receivables from customers, respectively to
differences in the loss on loans granted.
The exposures that give rise to the greatest uncertainty in the assessment of receivables from
clients are those where there is a significant risk of cash flow shortages and/or insufficiency of
the loan collateral.
Receivables from customers represent 51.54% of the Bank's total assets. It categorizes its
receivables from customers into 5 business segments: large, medium-sized, small enterprises,
micro enterprises, and retail banking. The share of receivables from large enterprises is the
largest 34.25% of total receivables from customers.
Due to the materiality of receivables from clients, as well as the complexity of the calculations
for determining the impairment of receivables, the many significant judgments and the high
degree of uncertainty in the estimates embedded in the impairment models applied, we have
identified this issue as a key audit issue.
How this key audit question was addressed in our audit
In this area, our audit procedures, among other things, included:
-
Review of the Bank's internal rules related to determining the impairment of clients'
receivables as well as obtaining an understanding of the process for determining the
impairment of receivables from customers, including models for its calculation on an
individual and portfolio basis and the key assumptions and judgements used in
accordance with the requirements of IFRS 9
-
R
eview and measure the adequacy, consistency and relevance of the Bank's
methodology and models to the requirements of IFRS 9
- Gain an understanding of the credit monitoring process and crawl key controls when
determining the impairment amount of a sample of corporate and consumer loans.
- Review of a risk-based sample of loans for which substantive procedures have been
carried out to assess the sufficiency of the impairment recognised and an adjustment of
the impairment value of those loans.
-
For a sample of loans with individual impairment by the Bank, we conducted a specific
analysis of the assumptions and judgements used in determining the amount of
expected future cash flows and for the realization of the collateral provided on these
loans in relation to the available market information.
-
For a sample of loans with portfolio impairment by the Bank, we reviewed the
methodology, analysis,
and assessment of the adequacy of the main assumptions
applied by the management in the context of the specifics of the individual portfolios of
3
loans of the Bank and the availability of internal historical information, as well as data
on future development of the parameters for them.
- For selected NPLs, we have evaluated management's forecast for cash flow generation,
collateral valuations and other repayment sources. In addition, we have tested a sample
of performing loans for which financial indicators have been assessed for weaknesses
and other risks that may jeopardise the possibility of repayment of exposures.
- Review of subsequent events occurring after the reporting date and aimed at tracking
the servicing of loans and receivables from customers in the specified risk-based
sample in order to assess the consistency of the Bank's assumptions about expected
future cash flows.
- Assessment of the adequacy, completeness and relevance of the Bank's disclosures
relating to impairment losses of receivables from customers.
Corresponding references in the individual financial statement Notes 17 and 17a
Note 2 (j)
Note 3 B (iii)
Assets acquired as collateral
Key audit question
The assets acquired as collateral amounting to BGN 403,523 thousand at the end of 2023 are
disclosed in the individual financial statements under relevant subgroups.
The Buildings group contains assets with varying degrees of completion at the date of their
acquisition, which is relevant for their subsequent realization, as well as for their ongoing
measurement, for which appropriate valuation methods are used.
During the year, sales of assets amounting to BGN 32,934
thousand were made. The Bank has
disclosed in Note 12 a profit of BGN 5,013
thousand from the sale of assets acquired as
collateral.
The
bank, like any other banking institution, is exposed to a significant risk regarding the
realisation of assets acquired as collateral.
The ongoing valuation
of these assets involves the use of significant assumptions and
assumptions by the Bank's management that involve a high degree of uncertainty, which is why
we have identified these issues as a key audit issue.
How this key audit question was addressed in our audit
- In this area, our audit procedures, among other things, included: Analysis and
evaluation of the valuation methods and techniques applied, including assumptions and
other key indicators, and comparing them with available real estate market and other
external information, as well as with the requirements of applicable accounting
standards.
-
Review the Bank's internal rules relating to the valuation of assets acquired as collateral,
as well as obtaining an understanding of the control over information (including key data
4
Key audit question
and assumptions) in the process of valuing these assets, as well as carrying out tests
on the effectiveness of these controls.
- Review of the documentation of a sample of newly acquired collateral assets during the
year, as well as review and analysis of the reports determining their value at the date of
acquisition, as well as a restatement of this value.
-
Review and assess the adequacy, completeness and relevance of disclosures in
relation to Assets acquired as coll
ateral in the individual financial statements in
accordance with IFRS requirements adopted by the EU.
Corresponding references in the individual financial statement
Note 12
Note 21
Litigation and provisions
Key audit question
The bank, like any other banking institution, is exposed to significant risk of litigation and
regulatory scrutiny. The degree of impact cannot always be predicted, but may result in
provisions for contingent and other liabilities depending on the relevant fa
cts and
circumstances. The amount of provisions is related to material assumptions and judgments of
management, usually based on the opinion of the legal consultants involved.
As of December 31, 2023, the Bank has recognized in its individual financial statements
provisions for litigation amounting to BGN 1,034 thousand.
In connection with issued bank guarantees, the bank has blocked funds amounting to BGN
43,094 thousand, which are disclosed in Note 25 of the individual financial statements (included
in the Other Assets subgroup).
Due to the significant uncertainty about the duration and outcome of the respective claims in
legal disputes with the Bank, the management's assessments used in these cases are
significant estimates, which is why we have determined this issue as a key audit question.
How this key audit question was addressed in our audit
- In this area, our audit procedures, among others, included: Review of the Bank's internal
rules related to provisioning litigation, as well as obtaining an understanding of the
process of collecting, analysing, and evaluating information about the relevant legal
dispute.
- Receiving and analysing information from external legal consultants on cases filed in
foreign jurisdictions, with forecasts of their outcome.
- Conducting an interview with the management, as well as receiving information from
the internal legal department of the Bank about legal disputes with the Bank filed on the
territory of the country, as well as with forecasts of their outcome.
-
Checking the timeliness and completeness of information on a sample of legal cases
by using information from independent court registers and systems in the country and
abroad.
5
Key audit question
- Follow-up of subsequent events regarding the receipt of new information on the sample
of legal disputes in order to monitor the adequacy and relevance of the assumptions
used by the Bank's legal advisers as well as its management.
-
Review and assess the adequacy, completeness,
and relevance of disclosures in
relation to the Litigation Provisions in the individual financial statements, as required by
applicable accounting standards.
Corresponding references in the individual financial statement
Note 25
Note 30
Other questions
When determining risk-weighted exposures in Explanatory Note No 3 Risk Management, C.
Capital Adequacy, the Bank's management has excluded Right-of-Use Assets under IFRS 16
"Leasing" in the amount of BGN 121,410 thousand.
Other information different from the financial statement and the auditor's report thereon
Management is responsible for other information. The other information consists of a
management report (on an individual basis), including a corporate governance statement (on
an individual basis), a report on the implementation of the remuneration policy and a non-
financial statement (on an individual basis) prepared by management under Chapter Seven of
the Accounting Act, but excluding the individual financial statements and our auditor’s report
thereon, which we received prior to the date of our auditor's report.
Our opinion on the individual financial statement does not extend to the other information and
we do not express any form of assurance conclusion about it, unless and to the extent expressly
stated in our report.
In connection with our audit of the individual financial statements, our responsibility lies in
reading the other information and thus assessing whether that other information is materially
inconsistent with the individual financial statements or with our knowledge obtained during the
audit or otherwise manner appears to contain material misreporting.
In the event that, based on the work we have performed, we conclude that there is a material
misstatement in that other information, we are required to report that fact.
We have nothing to report in this regard.
6
Responsibilities of management and individuals charged with general management of
the financial statement
Management is responsible for the preparation and fair presentation of these individual financial
statements in accordance with IFRSs applicable in the EU and for such internal control system
as management determines is necessary to ensure the preparation of financial statements that
are free from material misstatements, whether due to fraud or error.
In preparing the financial statements, management is responsible for evaluating the Bank's
ability to continue operating as a going concern, disclosing, where applicable, matters related
to the going concern assumption and using the going concern basis of accounting, unless
management does not intend to liquidate the Bank or cease its operations, or if the management
has no practical alternative but to do so.
Those charged with governance are responsible for the supervision of the Bank's financial
reporting process.
Responsibilities of auditors for the audit of individual financial statements
Our objectives are to obtain a reasonable assurance about whether the individual financial
statements taken as a whole are free from material misstatement, whether due to fraud or error,
and to issue an auditor’s report that includes our auditor’s opinion. A reasonable degree of
assurance is a high degree of assurance, but it is not a guarantee that an audit performed in
accordance with ISAs will always detect a material misstatement where it exists. Misstatements
may arise as a result of fraud or error and are considered material if they could reasonably be
expected, individually or in the aggregate, to influence the economic decisions of users made
on the basis of that financial report.
As part of an audit in accordance with ISAs, we use professional judgment and maintain
professional skepticism throughout the audit. We also:
identify and assess the risks of material misstatement of the financial statements, whether
due to fraud or error, design and perform audit procedures responsive to those risks, and
obtain audit evidence that is sufficient and appropriate to provide a basis for our opinion. The
risk of not detecting a material misstatement resulting from fraud is higher than the risk of a
material misstatement resulting from error because fraud may involve collusion, forgery,
intentional omissions, input statements misleading the auditor, as well as ignoring or
circumventing internal control.
obtain an understanding of internal control relevant to the audit in order to develop audit
procedures that are appropriate in the particular circumstances, but not for the purpose of
expressing an opinion on the effectiveness of the Bank's internal control.
we evaluate the appropriateness of accounting policies used and the reasonableness of
accounting estimates and related disclosures made by management.
reach a conclusion about the appropriateness of management's use of the going concern
basis of accounting and, based on the audit evidence obtained, whether a material
uncertainty exists relating to events or conditions that could give rise to significant doubts
7
about the Bank's ability to continue as a going concern. If we conclude that a material
uncertainty exists, we are required to draw attention in our auditor's report to the financial
statement disclosures related to that uncertainty or, if those disclosures are inadequate, to
modify our opinion. Our conclusions are based on the audit evidence obtained up to the date
of our auditor's report. However, future events or conditions may cause the Bank to cease
functioning as a going concern.
we evaluate the overall presentation, structure and content of the individual financial
statements, including disclosures, and whether the individual financial statements present
underlying transactions and events in a manner that achieves fair presentation.
We communicate with those charged with governance, among other matters, the planned scope
and timing of the audit and significant audit findings, including material deficiencies in internal
control, that we identify during our audit.
We also provide those charged with governance with a statement that we have met applicable
ethical requirements regarding independence and that we will communicate with them any
relationship and other matters that could reasonably be considered relevant to our
independence and, where applicable, related safeguards.
Among the matters communicated with those charged with governance, we identify those
matters that were of greatest significance in the audit of the current period's financial statements
and are therefore key audit matters. We describe these matters in our auditor's report, except
where law or regulation prevents the public disclosure of information about that matter or when,
in extremely rare cases, we determine that a matter should not be communicated in our report.
as it could reasonably be expected that the adverse consequences of such action would
outweigh the public interest benefits of such communication.
We are jointly and severally responsible for the performance of our audit and for the auditor's
opinion expressed by us, in accordance with the requirements of the Law on Independent
Financial Audit applicable in Bulgaria. When undertaking and implementing the engagement for
a joint audit, in connection with which we report, we were also guided by the Guidelines for the
implementation of a joint audit, issued on 13.06.2017 by the Institute of Certified Public
Accountants in Bulgaria and by the Commission for Public supervision of registered auditors in
Bulgaria.
8
Report on other legal and regulatory requirements
Additional Questions Raised for Reporting the Accountancy Act and the Public Offering
of Securities Act
In addition to our responsibilities and reporting under the IAS described above in the section
"Other information other than the financial statement and the auditor's report thereon" with
respect to the activity report, the corporate governance statement and the non-financial
statement, we have also performed the procedures, added to those required under the IAS,
according to the "Instructions on new and expanded audit reports and communication by the
auditor" of the professional organization of registered auditors in Bulgaria, the Institute of
Certified Public Accountants (ICPA). These procedures concern checks for the presence, as
well as inspections of the form and content of this other information in order to assist us in
forming an opinion on whether the other information includes the disclosures and reports
provided for in Chapter Seven of the Law on Accounting and in the Law on the Public Offering
of Securities, (art . 100n, paragraph 10 of the Law on Public Offering of Securities in connection
with Article 100n, paragraph 8, items 3 and 4 of the Law on the Public Offering of Securities),
applicable in Bulgaria.
Opinion in relation to art. 37, para. 6 of the Law on Accounting
Based on the procedures conducted, our opinion is that:
а) The information included in the individual management report for the financial year for which
the individual financial statements are prepared corresponds to the individual financial
statements;
b) The individual activity report has been prepared in accordance with the requirements of
Chapter Seven of the Accountancy Act and Art. 100(n), para. 7 of the Public Offering of
Securities Act;
(c) The individual corporate governance statement for the financial year for which the individual
financial statement has been prepared presents the information required under Chapter
Seven of the Accountancy Act and Art. 100n, para. 8 of the Public Offering of Securities Act
information;
(d) The non-financial statement (on an individual basis) for the financial year for which the
individual financial statement has been prepared is provided and prepared in accordance
with the requirements of Chapter Seven of the Accountancy Act;
(e) The report on the implementation of the remuneration policy for the financial year for which
the individual financial statement has been prepared is provided and meets the requirements
set out in the Ordinance under Art. 116c, para. 1 of the Public Offering of Securities Act.
Opinion in relation to Art. 100(n), para. 10 in conjunction with Art. 100 n, para. 8, items 3
and 4 of the Public Offering of Securities Act
9
Based on the procedures performed and the knowledge and understanding of the enterprise's
activities and the environment in which it operates, in our opinion, the description of the main
characteristics
of the enterprise's internal control and risk management systems in relation to
the financial reporting process, which is part of the management report (as an element of the
content of the corporate governance statement) and the information under art. Article 10(1)(c),
(d), (f), (h) and (i) of Directive 2004/25/EC of the European Parliament and of the Council of 21
April 2004 on takeover proposals do not contain cases of material misreporting.
Additional reporting on the audit of the individual financial statements in relation to art.
100(n), para. 4, item 3 of the Public Offering of Securities Act
Statement in relation to art. 100(n), para. 4, item 3, letter "b" of the Public Offering of Securities
Act
Information about related party transactions is disclosed in Note 35 to the individual financial
statements. Based on our audit procedures on related party transactions as part of our audit of
the individual financial statements as a whole, we are not aware of facts, circumstances or other
information on the basis of which to conclude, that related party transactions are not disclosed
in the attached separate financial statements for the year ending 31 December 2023 in all
material respects, in accordance with the requirements of ISA 24 Related Party Disclosures.
The results of our audit procedures on related party transactions have been considered by us
in the context of forming our opinion on the financial statements as a whole and not for the
purpose of expressing a separate opinion on related party transactions.
Statement in relation to art. 100(n), para. 4, item 3, letter "c" of the Public Offering of Securities
Act
Our responsibilities for an audit of the financial statements as a whole, described in the Auditor's
Responsibilities for the Audit of the Financial Statements section of our report, include
evaluating whether the financial statements present the material transactions and events in a
manner that achieves fair presentation. On the basis of our audit procedures on the material
transactions underlying the individual financial statements for the year ending December 31,
2023, we have not become aware of facts, circumstances or other information on the basis of
which to conclude that there are cases of material unreliable presentation and disclosure in
accordance with the applicable requirements of IFRSs, adopted by the European Union.
The
results of our audit procedures on the transactions and events of the Bank material to the
financial statement have been considered by us in the context of forming our opinion on the
financial statement as a whole, and not for the purpose of expressing a separate opinion on
these material transactions.
10
Reporting on the compliance of the electronic format of the individual financial
statements, included in the annual individual financial statements for the activity under
art. 100n, paragraph 4 of POSA, with the requirements of the EEEF Regulation
In addition to our responsibilities and reporting under the ISAs described above in the section
"Auditor's responsibilities for the audit of individual financial statements", we have completed
the procedures under the "Guidelines on the expression of an audit opinion in relation to the
application of the European Single Electronic Format (EEEF) for the financial statements of
companies whose securities are admitted to trading on a regulated market in the European
Union (EU)" of the professional organization of registered auditors in the Bulgaria, the Institute
of Certified Public Accountants (ICPA)". These procedures concern verification of the format
and whether the human-readable part of this electronic format corresponds to the audited
individual financial statements and expressing an opinion regarding the compliance of the
electronic format of the individual financial statements of First Investment Bank AD for the year
ending December 31, 2023, attached to the electronic file "549300UY81ESCZJ0GR95-
20231231-BG-SEP. XHTML", with the requirements of Commission Delegated Regulation (EU)
2019/815 of 17 December 2018 supplementing Directive 2004/109/EC of the European
Parliament and of the Council by means of regulatory technical standards laying down a single
electronic reporting format ('EEEF Regulation'). Based on these requirements, the electronic
format of the individual financial statements, included in the annual individual financial
statements for the activity under art. 100n, para. 4 of the POSA, must be presented in XHTML
format. The management of First Investment Bank AD is responsible for the application of the
requirements of the EEEF Regulation in the preparation of the electronic format of the individual
financial statements in XHTML. Our opinion is only with regard to the electronic format of the
individual financial statements, attached in the electronic file "549300UY81ESCZJ0GR95-
20231231-BG-SEP. XHTML" and does not cover the other information included in the annual
individual financial statements for the activities under art. 100n, para. 4 of POSA. Based on the
procedures performed, our opinion is that the electronic format of the individual financial
statements of First Investment Bank AD for the year ending December 31, 2023, contained in
the attached electronic file "549300UY81ESCZJ0GR95-20231231-BG-SEP. XHTML", has been
prepared in all essential respects in accordance with the requirements of the EEEF Regulation.
Additional reporting in connection with Ordinance No 58/2018 of the Financial
Supervision Commission
Statement in relation to art. 11 of Ordinance No 58/2018 of the FSC on the requirements for the
protection of financial instruments and client funds, for product management and for providing
or receiving remuneration, commissions, other monetary and non-monetary benefits.
Based on the audit procedures performed and the knowledge and understanding of the Bank's
activities in the course and context of our audit of its individual financial statements as a whole,
the organization established and applied in connection with the storage of client assets complies
11
with the requirements of Art. 3-10 of Ordinance No 58 of the FSC and art. 92-95 of the Markets
in Financial Instruments Act, with regard to the Bank's activities in its role as an investment
intermediary.
Reporting according to art. 10 of Regulation (EU) No 537/2014 in relation to the
requirements of art. 59 of the Independent Financial Audit Act
According to the requirements of the Independent Financial Audit Act in connection with art. 10
of Regulation (EU) No 537/2014, we further report the information set out below.
Mazars OOD and Ecovis Audit Bulgaria OOD were appointed as mandatory auditors of the
financial statements of First Investment Bank AD (the "Bank") for the year ending December
31, 2023, by the General Meeting of Shareholders held on May 18, 2023, for a period of one
year.
The audit of the individual financial statements for the year ending December 31, 2023, of
the Bank is a second full continuous statutory audit engagement of this enterprise performed
by Mazars Ltd. and a second full continuous statutory audit engagement of this enterprise,
conducted by Ecovis Audit Bulgaria OOD.
In support of the audit opinion, we have provided, in the "Key Audit Question" section, a
description of the most important risks assessed, a summary of the auditor's response and
important observations in relation to those risks where appropriate.
We confirm that the audit opinion expressed by us is in accordance with the additional report
submitted to the audit committee of the Bank, as required by Art. 60 of the Independent
Financial Audit Act.
We confirm that we have not provided the provisions of art. 64 of the Independent Financial
Audit Act prohibited services outside the audit.
For the period to which our statutory audit relates, apart from the audit, we have not provided
any other services to the Bank and its controlled entities.
We confirm that in performing the audit we have maintained our independence from the
Bank.
Sofia, March 12, 2024
About Ecovis Audit Bulgaria Ltd:
Georgi Trenchev
Managing Director
Georgi Trenchev
Managing Director
Registered auditor responsible for the
audit
Sofia, Gen. Blvd. Edward I. Totleben, 71
-
73
About MAZARS Ltd:
Athanasios Petropoulos
Procurator
Iva Slavkova
Registered auditor responsible for the
audit
Sofia, str. Mosco
vska No 3A
ACTIVITY REPORT
(ON AN INDIVIDUAL BASIS)
OF FIRST INVESTMENT BANK AD
FOR 2023
MARCH 2024
Activity Report 2023
on an individual basis
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The present report is prepared on the grounds of and in compliance with the requirements of the
Accounting Act, the Law on Public Offering of Securities, Ordinance №2 of the Financial Supervision
Commission for initial and subsequent disclosure of information in public offering and admittance
for trade on a regulated market of securities, Regulation (EU) No 575/2013 of the European
Parliament and of the Council on prudential requirements for credit institutions and investment
firms, Regulation (EU) 2020/852 of the European Parliament and of the Council on the establishment
of a framework to facilitate sustainable investment, and its supplementing acts, as well as the
National Corporate Governance Code, approved by the Financial Supervision Commission.
Activity Report 2023
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SELECTED INDICATORS
Return-
on-equity
(ROE)
9.6%
BGN 518m
operating
income from
banking
operations
Net loans/
deposits
ratio
62.28%
Cost of Risk
1.83%
Customer
deposits
BGN 11.5b
Total assets
BGN 13.9b
BGN 135m
Net profit
42.25%
Cost/income
ratio
9% growth
in retail loans
2023
Total
capital
adequacy
21.09%
OPERATING INCOME
BY TYPE OF INCOME
LOANS FOR
INDIVIDUALS
PORTFOLIO BY
SECTORS
2023
2023 2023
LOANS FOR
CORPORATES
2023
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FIRST INVESTMENT BANK
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MISSION AND DEVELOPMENT PRIORITIES
First Investment Bank AD aspires to continue to be one of the best banks in
Bulgaria, recognized as a rapidly growing, innovative, customer-oriented bank,
offering outstanding products and services to its customers, ensuring excellent
careers for its employees, and contributing to the community. The Bank shall
continue to develop high-technological solutions providing its customers with
opportunities for banking from any place around the world at any time.
For more information see section Development priorities“.
SUSTAINABLE
BUSINESS MODEL
AND STABILITY
HIGH QUALITY OF
CUSTOMER SERVICE
SHAREHOLDERS
RETURN
FOCUS ON
DIGITALIZATION AND
INNOVATION
COST OPTIMIZATION
UNIVERSAL BANK
LEADING IN KEY
SEGMENTS
RESPONSIBLE
BANKING FOR
SUSTAINABLE FUTURE
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TABLE OF CONTENTS
MACROECONOMIC DEVELOPMENT ..................7
BANKING SYSTEM ......................................... 11
FIBANK PROFILE ............................................ 16
Corporate status ............................................ 16
Memberships ................................................. 16
Market position Error! Bookmark not defined.
Market share .... Error! Bookmark not defined.
Correspondent relations ............................... 17
Branch network ............................................. 17
Subsidiaries .................................................... 17
Awards 2023 ..... Error! Bookmark not defined.
FIBANK: DATES AND FACTS ............................ 18
HIGHLIGHTS 2023 .......................................... 21
FINANCIAL REVIEW........................................ 25
Key indicators ................................................ 25
30 years Fibank . Error! Bookmark not defined.
Financial results ............................................. 27
Balance sheet ................................................ 30
Loan portfolio ................................................ 32
Loans ......................................................... 32
Related party transactions ........................ 34
Contigent liabilities .................................... 34
Attracted funds ............................................. 35
Capital ............................................................ 37
Regulatory capital ..................................... 37
Capital requirements ... Error! Bookmark not
defined.
Capital buffers ........................................... 39
Leverage .................................................... 40
Eligible liabilities ........................................ 41
RISK MANAGEMENT ...................................... 42
Risk management strategy ............................ 42
Risk appetite framework ... Error! Bookmark
not defined.
Risk map ...... Error! Bookmark not defined.
Risk culture .. Error! Bookmark not defined.
Risk management framework ................ Error!
Bookmark not defined.
Lines of defence ......... Error! Bookmark not
defined.
Structure and internal organisation ......... 45
Collective risk management bodies .......... 46
System of limits ........... Error! Bookmark not
defined.
Recovery plan............................................ 48
Restructuring planning process ................ 49
Credit risk .......... Error! Bookmark not defined.
Loan process ............................................. 49
Models for credit risk measurement ......... 51
Credit risk mitigation methods ................. 52
Problem exposures, repossessed assets
and reduction strategy ............................. 52
Classification, impairment and provisioning
of exposures .............................................. 53
Market risk ....... Error! Bookmark not defined.
Position risk ............................................... 55
Interest rate risk in the banking book ....... 55
Currency risk ............................................. 56
Counterparty risk and settlement risk ...... 56
Liquidity risk ................................................. 57
Internal liquidity adequacy assessment
process ...................................................... 58
Operational risk Error! Bookmark not defined.
Information security ................................. 60
Personal data protection .......................... 60
Outsourcing .............................................. 61
Risk exposures .............................................. 61
Internal capital adequacy analysis ................ 62
DISTRIBUTION CHANNELS .............................. 64
Branch network Error! Bookmark not defined.
Contact center .. Error! Bookmark not defined.
Corporate website .......... Error! Bookmark not
defined.
Corporate blog .. Error! Bookmark not defined.
Sales .................. Error! Bookmark not defined.
Digital banking .. Error! Bookmark not defined.
My Fibank electronic banking ................... 67
CORPORATE GOVERNANCE STATEMENT ........ 69
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Corporate governance framework ................ 70
Corporate governance code .......................... 70
Corporate structure ....................................... 72
Supervisory Board ......................................... 73
Structure and competences ....................... 73
Diversity policy and independence ............ 73
Functions and responsibilities ................... 74
Assessment of the activity ......................... 74
Committees ............................................... 74
Managing Board ............................................ 77
Structure and competences ....................... 77
Diversity policy ........................................... 77
Functions and responsibilities ................... 78
Committees and councils to MB ................ 78
General meeting of shareholders .................. 79
Control environment and processes ............. 79
Internal audit ............................................. 80
Registered auditors ................................... 80
Protection of shareholders’ rights ................. 81
Convening of GMS and information .......... 81
Main transfer rights and restrictions......... 81
Minority shareholders and institutional
investors .................................................... 82
Information disclosure .................................. 82
Investor relations director ......................... 83
Stakeholders .................................................. 84
Shareholders’ structure ................................. 84
Share price and market capitalisation ........... 85
REPORT ON THE IMPLEMENTATION OF THE
REMUNERATION POLICY ................................ 86
Remuneration policy .................................. 87
NON-FINANCIAL DECLARATION Error! Bookmark
not defined.
Business model .............................................. 92
Sustainable development .............................. 93
Environmental issues ................................ 94
Social issues .. Error! Bookmark not defined.
Governance issues .................................. 100
Ethical issues ............................................... 100
Code of ethics.......................................... 100
Responsibility and compliance ................ 100
Whistleblowing ....................................... 101
HUMAN CAPITAL ..Error! Bookmark not defined.
Policy for nomination and suitability
assessment ................................................. 104
INFORMATION TECHNOLOGY ...................... 105
BUSINESS REVIEW ....................................... 107
Retail banking ............................................. 107
Deposits .................................................. 107
Loans ....................................................... 108
Corporate banking ...................................... 110
Deposits .................................................. 110
Loans ....................................................... 110
External programs and guarantee schemes 115
Payment services ........................................ 115
Card payments ........................................ 116
International payments .......................... 117
Gold and commemorative coins ................. 118
Private banking ........................................... 118
Capital markets ........................................... 118
MEETING THE 2022 GOALS .......................... 121
SUBSEQUENT EVENTS .................................. 124
DEVELOPMENT PRIORITIES ......................... 125
OTHER INFORMATION ................................. 126
Members of the Supervisory Board ............ 126
Members of the Managing Board .............. 129
LIST OF ABBREVIATIONS .............................. 133
LIST OF BRANCH NETWORK ......................... 136
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MACROECONOMIC DEVELOPMENT
In 2023 the Bulgarian economy developed in a dynamic environment, dominated by global challenges
and comprehensive risks. The problems in supply chains on international level, the inflation, energy
and food crisis, that emerged from COVID-19 pandemic, intensified with the war in Ukraine and the
subsequent events in the Middle East. The accumulated risks and their consequences require applying
a consistent and focused actions in supporting economic development, taking into consideration the
national specifics.
2023
2022
2021
2020
2019
Gross domestic product (BGN million)
184,029
167,809
138,979
120,492
120,342
Gross domestic product, real growth (%)
1.8
1
3.9
7.7
(4.0)
4.0
- Private consumption, real growth (%)
6.3
1
3.9
8.5
(0.6)
6.0
- Public consumption, real growth (%)
(0.8)
1
5.5
0.4
8.3
2.0
- Investments, real growth (%)
2.4
1
6.5
(8.3)
0.6
4.5
- Net exports, real growth (%)
5.1
1
-3.3
0.4
(6.1)
(1.3)
Inflation, at period-end (%)
4.7
16.9
7.8
0.1
3.8
Average annual inflation (%)
9.5
15.3
3.3
1.7
3.1
Unemployment, at period-end (%)
5.6
5.4
4.8
6.7
5.9
Current account (% of GDP)
0.3
(1.4)
(1.7)
(0.0)
1.9
Trade balance (% of GDP)
(3.8)
(5.9)
(4.1)
(3.2)
(4.7)
International reserves of BNB (BGN million)
81,999
75,151
67,666
60,334
48,574
FDI in Bulgaria (% of GDP)
3.6
3.1
2.1
4.8
2.7
Gross external debt (% of GDP)
47.2
2
51.6
58.1
63.3
61.3
Government and government guaranteed debt
(% of GDP)
22.9
22.5
23.9
24.3
19.7
Consolidated budget balance (% of GDP)
(3.1)
(0.8)
(2.7)
(2.9)
(1.0)
USD exchange rate (BGN for USD 1)
1.77
1.83
1.73
1.59
1.74
Sources: NSI, BNB, MF, Employment agency
1
Data for nine months of 2023
2
Data as of November 2023
REPUBLIC OF BULGARIA
INDICATORS
Population 6.45 mln. people
Area 110,994 km
2
Member of the European
Union
2007
Member of NATO 2004
Memberships in the European
exchange mechanism II and
the Banking union
2020
Exchange rate EUR/BGN
(fixed)
1.95583
Flat tax rate 10%
Fitch Ratings BBB, Positive
S&P BBB, Positive
Moody’s Baa1, Stable
BG
AL
CY
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In 2023, gross domestic product growth slowed to 1.8% for the first nine months of the year (2022:
3.9%). Private consumption was the main driver (9M23: 6.3%; 2022: 3.9%) as a result of stronger
domestic demand and falling inflation rates. Fixed capital investment (9M23: 2.4%; 2022: 6.5%) and
net exports (9M23: 5.1%; 2022: -3.3) also contributed to economy growth, notwithstanding the impact
of the still slow recovery of supply flows on trade and investment activity.
For the nine months of 2023, gross value added in the economy grew by 1.0%, decelerating from 5.3%
for the previous year 2022. The services sector had the most significant share to value added (9M23:
1.1%; 2022: 3.9%), including trade, transport and tourism (9M23: 2.3%), government and healthcare
(9M23: 1.2%), real estate operations (9M23: 1.0%) and financial and insurance activities (9M23: 0.9%).
The industrial sector also rose by 1.2% overall for the period (2022: 12.1%), in particular mining and
manufacturing (9M23: 1.3%) and construction (9M23: 0.6%). A decline was reported in the agricultural
sector (9M23: -4.6%; 2022: -4.4%), influenced by lower volumes of production in the plant growing
industry and especially in technical crops, due to droughts and associated lower yields during the year.
In 2023, the labor market remained stable, with unemployment rate standing at 5.6% at the end of
the year (2022: 5.4%). More pronounced positive trends were observed in the summer months, due
to higher seasonal employment. The total number of employed persons increased to 2,288,000 people
in December 2023, compared to 2,279,000 for the same month a year earlier. As of the end of
December 2023, 64% of the total workforce was employed in the services sector, 30% in industry and
6% in agriculture.
Inflation in the country slowed down, with average annual values for 2023 amounting to 9.5% (2022:
15.3%), and year-end inflation standing at 4.7% (2022: 16.9%). The influence was wide-spread across
sectors, mainly driven by food (2023: 5.7%) and energy products (2023: 0.5%), in an environment of
similar decrease in the prices of basic raw materials in international markets. Services and non-food
goods in the consumer basket also registered a slowdown, at 3.1% and 4.9% respectively. Harmonized
inflation, as a measure of price stability in the Eurozone, was 5.0% at the end of 2023 (2022: 14.3%)
and 8.6% on average over the period (2022: 13.0%).
COMPONENTS
CONTRIBUTION TO GDP
SECTOR CONTRIBUTION
TO GROSS VALUE ADDED
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In 2023, direct investments in the country increased to EUR 3,371 million or 3.6% of GDP (2022: EUR
2,631 million or 3.1% of GDP). Such dynamics were mainly due to higher reinvested earnings, reflecting
the share of foreign investors in the financial result of companies, rather than to proceeds from debt
instruments (financial, bond and trade loans) and equity investments. By country, most investments
were attracted from Switzerland (EUR 821 million), followed by Austria (EUR 377 million) and Belgium
(EUR 336 million). The higher decline in imports (-10.0% for 2023 YoY to EUR 46,990 million) compared
to exports (-7.9% to EUR 43,439 million) led to a decrease in the trade balance deficit to EUR -3,551
million or -3.8% of GDP at the end of 2023. This, combined with the growth in transport services and
tourism, caused a current account surplus of EUR 274 million or 0.3% of GDP (2022: EUR -1200 million
or -1.4% of GDP).
Gross external debt decreased to 47.2% of GDP as of November 2023 (2022: 51.6%), with a decrease
reported in the private sector (11M23: 31.9% of GDP). Public sector debt, despite the reported increase
(11M23 : 15.2% of GDP), remained among the lowest in the European Union. Total government and
government-guaranteed debt, including debt issued on the domestic market, amounted to 22.9% of
GDP at the end of 2023 (2022: 22.5%).
INFLATION UNEMPLOYEMENT RATE
2023
FDI INVESTMENTS IN THE COUNTRY GROSS EXTERNAL DEBT
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In 2023, the consolidated budget reached a deficit of BGN 5,619 million or 3.1% of GDP by the end of
the year (2022: BGN 1,324 million or 0.8% of GDP), reflecting the higher growth of costs relative to
revenues in the national budget and a deficit on EU funds. Expenditures under the consolidated fiscal
program increased by 9.9% to BGN 72,677 million (2022: BGN 66,112 million), as a result of an increase
in capital and non-interest expenses, which included higher investment expenses on EU fund accounts,
as well as higher costs of municipal budgets under the municipal project investment program.
Tax revenues increased by 11.8% YoY to BGN 52,324 million as of December 2023, an increase being
reported in all main sources, including personal income tax (by 16.4% to BGN 6,190 million), corporate
tax (by 8.9% to BGN 5,001 million), VAT revenues (by 5.8% to BGN 16,226 million) and excise duties
(by 7.7% to BGN 6,148 million). Revenues from social security contributions also increased, amounting
to BGN 15,627 million, of which BGN 11,311 million social security contributions and BGN 4,317 million
health contributions.
During the year, the credit ratings of Bulgaria were affirmed by Fitch Ratings (BBB, positive outlook),
Standard & Poor's (BBB, positive outlook) and Moody's Investors Service (Baa1, stable outlook). Since
2020, the Bulgarian lev has officially been part of the European Exchange Rate Mechanism (ERM) II in
accordance with the Currency Board system operating in the country. During the period, preparatory
actions related to the National Plan for the introduction of the euro in the Republic of Bulgaria
continued, including integration into the European payment infrastructures. For more information, see
section Banking system“.
CONSOLIDATED BUDGET STRUCTURE OF TAX REVENUES
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BANKING SYSTEM
In 2023, the banking system in Bulgaria reported good financial indicators and profitability achieved in
a dynamic macro environment. The efforts of the banking sector were aimed at sustainable
development and stable capital position. Since 2020, Bulgaria has been part of the Banking Union
through its participation in the Single Supervisory Mechanism (SSM) and the Single Restructuring
Mechanism (SRM).
in % / change in p.p.
2023
2022
2021
23/22
22/21
CET 1 ratio
20.22
3
19.98
21.66
0.24
(1.68)
Tier 1 capital ratio
20.68
3
20.48
22.04
0.20
(1.56)
Capital adequacy ratio
21.84
3
20.88
22.62
0.96
(1.74)
Leverage ratio
9.88
3
9.41
10.52
0.47
(1.11)
Liquidity coverage ratio (LCR)
246.7
235.0
274.1
6.9
(39.1)
Loans/deposits
4
71.21
68.21
69.38
3.0
(1.17)
Return-on-equity (ROE)
18.64
3
12.01
8.53
6.63
3.48
Return-on-assets (ROA)
2.18
3
1.34
1.05
0.84
0.29
Non-performing loans and advances
5
2.76
3.55
4.60
(0.79)
(1.05)
Source: Bulgarian National Bank
The total capital ratio (TCR) for the system amounted to 21.84% at the end of September 2023. (2022:
20.88%), and the CET1 ratio to 20.22% (2022: 19.98%), both indicators being significantly above the
regulatory requirements. From January 1, 2023, adjustments related to the transitional treatment
according to Regulation (EU) 2017/2395 for mitigating the impact of the introduction of IFRS 9 no
longer apply to these indicators. The leverage ratio, comparing Tier 1 capital to the total on- and off-
balance sheet exposures of banks, was 9.88% as of September 2023, compared to 9.41% as of end-
2022. It is used as an additional supervisory tool, measuring the capital held by banks which is not
sensitive or risk-weighted.
Due to the continuing high growth rates in lending and the cyclical risks in real estate market, the BNB
kept the level of countercyclical capital buffer at 2.0% during the year, effective until the first quarter
of 2025. During the period, the BNB announced its annual review of the buffer for Other Systemically
Important Institutions (O-SIIs), identifying as such six banks for which individual levels were set in the
range of 0.50% to 1% for 2024. In 2023 the systemic risk buffer remained unchanged, at 3% of banks’
risk exposures in Bulgaria.
Liquidity in the system remained high, reflecting consistent conservative risk management and the
increased deposit base. The Liquidity Coverage Ratio (LCR), correlating the liquidity buffers maintained
by banks against net outflows over a period of 30 calendar days, stood at 246.7% (2022: 235.0%), which
is well above the minimum requirement of 100%. The ratio of liquidity buffer to balance sheet assets
for the system increased to 30.8%. Liquidity was also affected by the two increases in mandatory
minimum reserves undertaken by the BNB: from 5% to 10% for borrowings from non-residents,
3
Data as of 30 September 2023.
4
Gross loans and advances (without central banks and credit institutions)/deposits (without credit institutions)
5
Non-performing loans and advances/gross loan and advances. (For comparability, a broad definition of loans
and advances has been used, including cash balances with central banks and other demand deposits).
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effective from June 1, 2023, and from 10% to 12% for borrowings residents and non-residents,
effective July 1, 2023.
BGN million/ change in %
2023
2022
2021
23/22
22/21
Net interest income
4,846
3,227
2,757
50.2
17.0
Net fee and commission income
1,474
1,430
1,241
3.1
15.2
Administrative expenses
2,200
1,972
1,784
11.6
10.5
Impairment
411
586
594
(29.9)
(1.3)
Net profit
3,417
2,079
1,416
64.4
46.8
Source: Bulgarian National Bank
In 2023, the net profit of the banking system increased to BGN 3,417 million, compared to BGN 2,079
million for 2022, mainly due to net interest income generated in an environment of increased lending
and preserved interest spread. Another driver was the continuing downward trend of impairment
costs, amounting to BGN 411 million for the period (2022: BGN 586 million).
Net interest income for 2023 increased by 50.2% to BGN 4,846 million (2022: BGN 3,227 million), and
net fee and commission income reached BGN 1,474 million (2022: BGN 1,430 million), providing a solid
contribution to profit comprising 21.3% of the system's total operating income. The achieved financial
results accounted for return on assets (ROA) of 2.18% for the nine months of 2023 (2022: 1.34%) and
a return on equity (ROE) of 18.64% for the same period (2022: 12 .01%).
BGN million / change in %
2023
2022
2021
23/22
22/21
Assets
172,075
155,406
135,410
10.7
14.8
Loans to non-financial corporations
48,460
44,908
40,286
7.9
11.5
Loans to individuals, including:
39,473
33,945
29,468
16.3
15.2
- Mortgage loans
22,028
18,365
15,815
19.9
16.1
- Consumer loans
18,040
16,138
14,304
11.8
12.8
Deposits from non-financial corporations
46,303
43,169
34,374
7.3
25.6
Deposits from individuals
82,614
74,282
68,107
11.2
9.1
Source: Bulgarian National Bank
Total balance sheet assets increased by 10.7% YoY to BGN 172,075 million by the end of 2023 (2022:
BGN 155,406 million) with loans and advances holding a predominant share in the balance sheet
structure at 60, 0% of total assets (2022: 59.6%) followed by cash and balances with central banks at
21.1% of assets (2022: 20.9%) and investments in securities at 15.6% (2022: 15 .7%), which mainly
included government debt securities.
Lending activity in 2023 remained high, with more pronounced dynamics in households compared to
non-financial corporations. Residential mortgage loans increased by 19.9% to BGN 22,028 million
(2022: BGN 18,365 million) and consumer loans by 11.8% to BGN 18,040 million (2022: BGN 16,138
million) at the end of 2023. Loans to non-financial corporations retained their major share at 49.8% of
total customer loans, reaching BGN 48,460 million (2022: BGN 44,908 million).
The share of non-performing loans and advances continues to decline, down to 2.76% of gross loans
and advances as of December 2023 (2022: 3.55%). Loans to non-financial corporations accounted for
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the largest share in the structure of non-performing loans (65.0%), followed by loans to households
(31.6%) and other financial corporations (2.1%).
In 2023, borrowed funds in the banking system (excluding credit institutions) increased by 8.4% to BGN
136,768 million as of December 2023 (2022: BGN 126,197 million), reflecting confidence in the system.
An increase was reported mainly in deposits of households (by 11.2% to BGN 82,614 million), which
retained their dominant share at 60.4% of all borrowings, and to a lesser extent in deposits of non-
financial corporations (by 7, 3% to BGN 46,303 million). The currency structure of deposits remained
unchanged, the share of BGN deposits standing at 65.9%, deposits in EUR at 27.6% and those in other
currencies at 6.5% as of December 2023.
During the year, the trend of increasing interest rates in the country strengthened but remained less
pronounced compared to other EU and Eurozone countries. This was mainly due to high levels of
liquidity in the system and to binding reference interest rates on loans applied by banks (mainly in the
retail banking segment) to average cost of deposits. Interest rates on deposits (new business
6
) of
households and non-financial corporations increased on average for 2023 (volume-weighted) to 0.48%
and 1.88%, respectively (2022: 0.11% and -0.13%). An increase was also reported in average interest
rates on loans for the period (new business
7
): in consumer loans up to 8.63% (2022: 8.16%), in
mortgage loans up to 2.58% (2022: 2, 54%), and in loans to non-financial corporations up to 4.00%
(2022: 2.60%).
In 2023, a number of projects were implemented in the field of payments which will help integrate the
payment systems in the country with those of the Eurozone. In March 2023, the BNB and the banking
community in Bulgaria, together with the Bulgarian ancillary systems for client payments in euro and
for securities settlement, successfully migrated to the Eurosystem's new T2 payment system. It
comprises a Real-Time Gross Settlement (RTGS) component and a central liquidity management tool
and replaces the previous TARGET2 system. The Central Depository also joined the Eurosystem's
securities settlement platform T2S, enabling pan-European delivery-versus-payment settlement of
securities and cash in central bank money.
6
Term deposits in BGN up to 1 year
7
Loans by original maturity in BGN
LOANS AND DEPOSITS (BGNm)
INTEREST RATES ON LOANS AND DEPOSITS
2023
20222021
20102019
Deposits
Loans
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During the year, a migration project for budget payments in line with the new SEPA standards was also
successfully implemented.
By the end of 2023, the instant transfers in BGN under the Blink scheme of BORICA AD, which are
executed with 10 seconds, increased their share in payments across the country. Its additional P2P
functionality for transfers by mobile number continues to gain popularity among participating
payment service providers and their customers.
New technologies and digitization of activity gave impetus to the development of payment and
financial markets. The regulatory framework at the national and European level also contributed to
this. A new Regulation (EU) 2023/1114 on markets in crypto-assets (MiCA) was added to the existing
Digital Operational Resilience Act (DORA) - Regulation (EU) 2022/2554 and Regulation (EU) 2022/858
on a pilot regime for market infrastructures based on distributed ledger technology. It introduced
uniform requirements for public offering and admission to trading on crypto-asset trading platforms,
as well as disclosure and transparency requirements for crypto-asset service providers. In 2023, a new
Regulation (EU) 2023/1113 on information accompanying transfers of funds and certain crypto-assets
(TFR) was also adopted, expanding the scope of such information.
During the period, amendments were made to the Payment Services and Payment Systems Act
concerning basic payment accounts (BPA), envisaging a special regime of servicing, provided that the
funds received on the accounts come from labor remunerations and social payments.
In the field of corporate governance, a new Whistleblower Protection Act was adopted. It regulates
the terms, procedure and measures for protection of whistleblowers on violations of the law,
established in working context, as well as the terms and conditions for submitting and considering
whistleblowing reports.
Regulations in the field of recovery and resolution were supplemented by new EBA Guidelines on the
overall recovery capacity in recovery planning (EBA/GL/2023/06), Guidelines for institutions and
resolution authorities on improving resolvability (EBA/GL/2023/05), Guidelines to resolution
authorities on the publication of their approach to implementing the bail-in tool (EBA/GL/2023/01),
and Guidelines on transferability to complement the resolvability assessment for transfer strategies
(EBA/GL/2022/11).
With regard combatting money laundering and terrorist financing, new EBA Guidelines were adopted
on policies and controls for the effective management of ML/TF risks when providing access to financial
services (EBA/GL/2023 /04), Guidelines on customer due diligence and the factors credit and financial
institutions should consider when assessing the money laundering and terrorist financing risk
associated with individual business relationships and occasional transactions (EBA/GL/2023/03), as
well as Guidelines on the use of remote customer onboarding solutions (EBA/GL/2022/15).
At the end of 2023, 23 credit institutions operated in the country, of which 6 were branches of foreign
banks. The consolidation processes in the system continued, following global trends towards
optimization in the structure and efficiency of banking institutions. The share held by significant
banking institutions (according to ECB criteria) in the country amounted to 68.3% of bank assets as of
September 2023, those of the less significant registered 28.8%, while those of the branches of foreign
banks were at 2.8%.
Banks operated in an environment of strong competition, advanced development of technologies,
process transformation and customer behavior. The competition increased also from online banking,
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fintech companies and e-commerce as a whole. This requires expanding opportunities for cross sales
and fast digital solutions in response of customers’ expectations, proactiveness and personalization of
services.
In 2024, the main challenges faced by banks will continue to include the processes of digitization of
banking services and the related measures and actions for active management of ICT risks and cyber
security, the upcoming implementation of the EU banking package known as CRD6 and CRR3
concerning capital and prudential requirements, the integration of ESG factors and the transition to a
sustainable economy, as well as the promotion of financial literacy through advising and assisting
customers. Should a decision be taken to introduce the euro in the Republic of Bulgaria, this will
become a leading priority for banks in the country.
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FIBANK PROFILE
CORPORATE STATUS
First Investment Bank is a joint-stock company
registered with Sofia City Court pursuant to a ruling
dated 8 October 1993. Since 28 February 2008 the
Bank has been registered in the Commercial
Register of the Registry Agency.
First Investment Bank is a public company
registered in the Commercial Register of Sofia City
Court by a decision dated 4 June 2007 and in the
register of public companies and other issuers held
by the Financial Supervision Commission by a
decision dated 13 June 2007.
The Bank owns a universal banking license for
domestic and international operations. First
Investment Bank is a licensed primary dealer in
government securities and it is a registered
investment intermediary.
MEMBERSHIPS
Association of Banks in Bulgaria
Bulgarian Stock Exchange AD
Central Depository AD
BORICA AD
MasterCard International
VISA Inc.
S.W.I.F.T.
Factors Chain International
Head office and business address of First Investment Bank AD Sofia 1784, 111P, Tsarigradsko shose
Blvd.
MARKET POSITION
8
Fifth in assets
Fifth in deposits
Fifth in deposits from individuals
Fifth in lending
Fifth in corporate lending
Fifth in consumer loans
Fifth in mortgage loans
MARKET SHARE
9
8.07% of bank assets in Bulgaria
8.40% of deposits in the country
9.41% of deposits from individuals
8.23% of loans in the country
9.62% of corporate lending
7.57% of consumer lending
5.88% of mortgage lending
Among the leading banks in the card business. Among the leading banks in payment services,
including international payments and trade transactions
8
Market positions are determined based on unconsolidated data from the BNB.
9
Market shares are determined based on unconsolidated data from the BNB.
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CORRESPONDENT RELATIONS
Fibank has a wide network built up of correspondent banks, through which it performs international
payments and trade financing operations in almost all parts of the world. The Bank executes
international transfers in foreign currency, and issues cheques and performs different documentary
operations. Fibank is a respected, reliable and fair partner, which has built over the years a good
reputation among international financial institutions and gained valuable experience and know-how
from its numerous business partners, investors, customers and counterparties.
BRANCH NETWORK
As at 31 December 2023 First Investment
Bank had 119 branches and offices, covering
the territory of Bulgaria and a foreign branch
in Cyprus.
Fibank maintains diversification of the
distribution channels, which constantly
enhance in accordance with technological
development and customer needs.
SUBSIDIARIES
As at 31 December 2023, First Investment Bank AD had nine subsidiary companies:
First Investment Bank - Albania Sh.a., Fi Health Insurance AD, MyFin EAD, Diners Club Bulgaria AD,
Debita OOD, AMC Imoti EAD, Creative Investment EOOD, Lega Solutions EOOD and Inkaso Garant
EOOD.
For further information regarding subsidiary companies, see Note 36 “Subsidiaries” of the Standalone
Financial Statements for the year ended 31 December 2023.
AWARDS 2023
First Investment Bank was awarded in the Bank of the Year and
Employer branding categories at the Company of the Year
ceremony, which promotes successful management models and
effective business practices among the Bulgarian public.
Fibank received the Mystery Customer Bank award for best
customer service in Bulgaria in the prestigious Bank of the Year
competition, organized by the Bank of the Year Association.
Diverse set of
distribution
channels
Corporate
website
Digital
banking
Contact
center
Direct
sales
Corporate
website
Branch
network
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FIRST INVESTMENT BANK: DATES AND FACTS
1993
First Investment Bank was established on 8 October 1993 in Sofia.
Fibank was granted a full banking license for carrying out operations in Bulgaria and abroad.
1994-95
The Bank developed and specialized in servicing corporate clients.
1996
Fibank was the first in Bulgaria to offer services enabling banking from home or from the office.
Fibank was the first bank to receive a 5-year loan from the European Bank for Reconstruction and
Development for financing small and medium-sized enterprises in Bulgaria.
1997
The Bank started issuing Cirrus/Maestro debit cards, Eurocard/Mastercard credit cards and the American
Express card. Fibank was the first Bulgarian bank to offer debit cards with international access.
Thompson Bankwatch awarded Fibank its first credit rating.
The Bank opened its first branch abroad, in Cyprus.
1998
Fibank obtained its first syndicated loan from foreign banks. The Bank negotiated financing for the import
of investment goods from a number of EU countries, guaranteed by export insurance agencies.
1999
The Bank negotiated a syndicated loan organized by EBRD to the total amount of EUR 12.5 million.
First Investment Bank received a medium-term loan for EUR 6.6 million from a German government
organization for financing of Bulgarian companies.
A foreign banking branch in Tirana, Albania was opened servicing Albanian companies and individuals.
2000
First Investment Bank started developing its business in the field of retail banking. Deposits from private
individuals grew 2.3-fold.
2001
Fibank launched the first virtual bank branch in Bulgaria, allowing customers to bank via the Internet.
The Bank was awarded the prize “Bank of the Year” by ‘Pari’ (‘Money’) daily.
Maya Georgieva (Executive Director of First Investment Bank), received the prize “Banker of the Year” from
‘Banker’ Weekly.
2002-04
Fibank was named twice “Bank of the Client“ in the annual rating of ‘Pari’ daily.
Products and services to individuals became the focus of the Bank’s activities. Loans to individuals increased
over five times during the year.
The Bank expanded its infrastructure. The branch network expanded by 27 new branches and offices, the
ATM network more than doubled.
2005
Fibank acquired 80% of the capital of Diners Club Bulgaria AD.
The Bank issued Eurobonds to the amount of EUR 200 million on the Luxembourg Stock Exchange. Fibank
was also the first Bulgarian bank to issue perpetual subordinated bonds.
Matthew Mateev (Deputy Chief Executive Director of First Investment Bank) was awarded the prize “Banker
of the Year” by ‘Banker’ weekly.
2006
Fibank was named “Bank of the Client” for the third time in the annual rating of ‘Pari’ daily.
185 million syndicated loan, organised by Bayerische Landesbank with 33 international banks participation.
The Bank’s share capital was increased from BGN 20 million to BGN 100 million by transforming retained
profits into new shares.
2007
First Investment Bank realized the biggest banking initial public offering of shares in Bulgaria and became a
public company.
„Fibank Mobile“ – the first banking mobile portal created by the Bank with useful financial information for
its customers, started functioning.
Fibank is among the first banks in Bulgaria to implement chip technology by issuing cards.
First Investment Bank Albania Sh.a. was issued a full banking license in Albania.
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2008
Fibank implemented a new centralized and integrated core banking information system FlexCube.
Fibank received a syndicated loan in the amount of EUR 65 million from 11 leading international banks.
Fibank became the first bank in Bulgaria to launch its own corporate blog.
Fibank received the OSCARDS award for innovation in the card business.
2009
Fibank started offering the sale and redemption of investment diamonds.
A new Internet service “My Fibank” was offered, providing e-statements on bank accounts and credit cards.
2010
Fibank welcomed its one millionth client.
First Investment Bank signed an agreement with IFC for cooperation in the field of trade finance.
Fibank was the first Bank in Bulgaria to offer contactless payments using the PayPass technology.
Fibank acquired a controlling interest in FI Health AD health insurance fund.
2011
First Investment Bank was recognized as the Best Bank in Bulgaria in 2011 by the financial magazine
Euromoney.
New Executive Directors of the Bank appointed Dimitar Kostov, Vassil Christov, Svetoslav Moldovansky.
Maya Georgieva (Executive Director of First Investment Bank) received the Banker of the Year 2011 award
from “Banker” Weekly for market sustainability achieved and customer confidence earned
2012
Fibank was “Bank of the Year“ from “Bank of the Year” Association, with the best complex performance.
The Bank signed an agreement with the EIF for the financing of SME under the JEREMIE initiative.
Vassil Christov, Executive Director of First Investment Bank won the prestigious award “Banker of the Year”
of the “Banker” Weekly.
2013
First Investment Bank AD signed an agreement with the Hungarian MKB Bank Zrt. for the acquisition of
100% of the shares of MKB Unionbank EAD.
Fibank finalized the issuance of new EUR 100 million hybrid debt.
Online sale of products of investment gold and other precious metals was started.
2014
The merger of Union Bank EAD into First Investment Bank AD was carried out, including integration of
operational systems, procedures, infrastructure, human resources, products and services
Fibank overcame the pressure on the banking system thanks to its sound liquidity, high professionalism, as
well as to the liquidity support received pursuant to EC Decision C(2014) 4554/29.06.2014.
Fibank was awarded as the best bank in the field of retail banking by the international portal Global Banking
& Finance Review.
2015
A joint project with the IFC for upgrading Fibank’s risk management and corporate governance systems was
realized in line with the principles of the Basel Committee and the recognized international standards.
A new independent member of the Supervisory Board was elected: Mr. Jyrki Koskelo, an accomplished
professional having extensive experience with the IFC.
A new organizational structure of the Bank was adopted, further developing the control functions.
Fibank was named the strongest brand among banks in Bulgaria by the global organization Superbrands.
2016
An innovative platform was launched for electronic payments using NFC-enabled mobile devices and digital
bank cards.
The Bank repaid the liquidity support received pursuant to EC Decision C(2014) 8959/25.11.2014.
Fibank successfully passed the asset quality review and the stress test conducted in the country.
New contactless debit cards for children and teenagers were developed.
2017
Fibank created its integrated e-banking platform My Fibank, as a single customer omnichannel.
The Bank became direct participant in the STEP2 SCT (SEPA Credit Transfer) system.
Fibank updated its core banking information system by migrating to Oracle Flexcube12.
Fibank developed its online consumer credit services at www.credit.fibank.bg.
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2018
First Investment Bank celebrated the 25th anniversary of its founding.
A new Smart Lady program was launched in support of women entrepreneurs, mainly targeting micro, small
and medium-sized enterprises.
A software Fibank Token was developed as a means of signature and authentication in the electronic
banking system of the Bank.
An innovative new-generation Evolve credit card was developed, combining three brands (Fibank, Diners
Club and Mastercard) into one payment instrument.
2019
Card services were further developed, with an emphasis on digital cards and payments using smart devices.
A centralized back office was initiated in the Bank's system, its main purpose being to optimize the
efficiency in servicing the Bank's customers.
Fibank passed the asset quality review and stress test conducted by the ECB during the year.
Initiatives were undertaken aimed at enhancing financial literacy, including among children and teens.
2020
First Investment Bank successfully increased its capital by BGN 195,424 thousand. New shareholders of the
Bank became the Bulgarian Development Bank AD with 18.35% and Valea Foundation with 7.87%.
Fibank was the first bank in Bulgaria, which allowed rescheduling of payments to borrowers experiencing
difficulties in connection with the state of emergency and the COVID-19 pandemic.
New executive directors were elected Nikola Bakalov and Ralitsa Bogoeva, as well as new Chief Financial
Director Ianko Karakolev.
Fibank supported the founding of a startup company in the field of payment services: MyFin EAD, licensed
as an electronic money company with a share capital of BGN 1 million.
First Investment Bank signed agreements with the Bulgarian Development Bank and Fund of Funds for
overcoming the consequences from the COVID-19 pandemic.
2021
First Investment Bank offered the innovative Gold Account product designed for keeping, purchase and sale
of dematerialized gold (XAU).
A new video consultation service was launched for customers interested in retail credit products, available
at www.fibank.bg and through My Fibank electronic banking.
A new Business Process Management (BPM) system for retail lending was implemented.
MyCard was launched: a new virtual credit card with pre-approved limit, issued entirely online through the
My Fibank mobile application.
Debit Mastercard Platinum was launched: a new debit card for the premium segment offering a number of
benefits, including a virtual assistant app (AskPLEEZ!) and concierge services.
2022
First Investment Bank launched an innovative service for instant payments (up to 10 seconds) in BGN under
the Blink scheme.
Electronic signing of documents by e-Sign pad was introduced at the Bank's offices.
A new Debit Instant Card was offered: a virtual debit card issued through the My Fibank mobile app,
intended for making online payments by smartphone.
The use of the BPM credit process management system was extended to business customers.
A new Sustainable Future mortgage loan was developed according to responsible banking policies, for
financing real estate with high energy efficiency (class A+, A or B).
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HIGHLIGHTS 2023
JANUARY
A number of initiatives and campaigns were launched related
to the 30th anniversary of the First Investment Bank.
Fibank customers were the first in Bulgaria to make instant
Blink P2P payments in BGN through the My Fibank mobile
application.
The new Sofia Tech Park office of Fibank welcomed its first
customers.
FEBRUARY
The exclusive metal World Elite Mastercard credit card was
offered, with additional features such as concierge services,
EGO Club membership, personal banker assistance, VIP
access to airport lounges, and high-coverage travel
insurance.
An accent was placed on investment and working capital
loans to small businesses, with longer repayment periods
and relaxed collateral terms.
MARCH
The Bank successfully migrated to the new T2 (TARGET2) real-time gross settlement (RTGS)
system of Eurosystem for processing large-value payments.
Fibank's Smart Lady program in support of women entrepreneurs marked its fifth anniversary
by organizing the Business Lady Excellence international conference, attended by business
leaders from across Europe.
The fully online issuance of virtual credit cards was launched
through the My Fibank mobile application.
The Bank offered financing to Bulgarian enterprises under
the EU competitiveness and innovation programs, for
development of rural areas and under the National Recovery
and Resilience Plan.
Fibank participated in the European Money Week 2023
initiative for early financial literacy in a number of schools in
the country.
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APRIL
Become a Fibank Customer a new service for remote
customer onboarding through the My Fibank mobile app,
using ID card and video identification (eID).
Fibank signed a portfolio insurance agreement with the
Bulgarian Export Insurance Agency, providing coverage
against financial losses on loans granted to micro, small and
medium-sized enterprises.
EGO Portfolio a private banking service featuring a personal
investment advisor for structuring and management of
portfolios and investment advice.
The Green Transport, Green Energy - Free Market, and Green
Energy - Own Use products for business customers, intended
for purchase of electric vehicles or construction of
photovoltaic systems, were presented at the Business
Financing 2023+ forum.
MAY
A new Fibank High Tech Pro corporate program was launched, aimed at training, professional
guidance and career development for young talents in the field of information technology and
cyber security.
Software token a new functionality of My Fibank Cyprus electronic banking, providing safer
and easier access for customers of the Cyprus branch.
Health and Body Modeling Fi Pro a new sports initiative for Fibank employees, aimed at a
healthy lifestyle and good physical shape, relaxation and harmonious balance in the working
environment.
JUNE
A Regular Annual General Meeting of the shareholders of
First Investment Bank was held, at which a decision was
taken that the net profit for 2022 would be capitalized.
Fibank experts presented opportunities for career
development at the banking institution at the Career and Life
- Why in Bulgaria forum, held by Bulgaria Wants You in Sofia
Tech Park.
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JULY
The Bank actively offered its POS Overdraft product to small businesses: a revolving credit facility
based on the volume of realized POS transactions.
For yet another year, Fibank organized the Best Bulgarian Company of the Year competition. It
aims to raise public awareness of good business examples in the country and promote successful
business models.
AUGUST
A campaign was launched to offer the Digital Me program,
the Digital Light package and the Career Start consumer loan
to students in the country.
The Bank upgraded its IT infrastructure in terms of cyber
security, introducing new software solutions and minimizing
vulnerabilities in line with the best practices in the field.
A 10-year Sustainable Development Strategy and a Green
Finance Framework were developed, setting the standards
for ecological and environmentally friendly lending according
to the principles of the International Capital Market
Association (ICMA).
Fibank became the institution accepting applications for issuance of European Health Insurance
Cards in Bulgaria, through its branch network in the country.
SEPTEMBER
Visa Platinum Business Debit a new high-class card product
for business customers, designed to manage company funds,
with additional features such as cash back, travel insurance
when traveling abroad, and access to business airport
lounges with the Lounge Key program.
A campaign was launched for the issuance of new Debit
Mastercard PayPass Kids/Teen debit cards without fees for
issuance, maintenance, POS payments, or ATM withdrawals.
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OCTOBER
Green Energy for Households a new retail credit product
intended for financing installations for energy production
from renewable sources (e.g. photovoltaic systems or solar
hot water systems).
Fibank successfully adapted its payment systems and
customer documentation to the new budget payment
requirements implementing the SEPA standards.
The Bank brought its activities in line with the provisions of
the new Whistleblower Protection Act.
NOVEMBER
Green Transport for Households a new retail credit product
intended for financing the purchase of electric vehicles.
Loans cover up to 100% of the vehicle cost, plus up to BGN
10 thousand for additional costs related to the purchase.
Reference information on personal loans in My Fibank e-
banking was expanded, aiming at greater detail and
convenience for users.
DECEMBER
A new silver coin commemorating the Year of the Dragon
2024 was offered by Fibank in collaboration with the New
Zealand Mint.
The Bank developed exclusive debit and credit cards with
designs dedicated to the 2024 Olympic and Paralympic
Games in Paris.
The Children of Fibank a Christmas party was organized for
employees of the Bank and their children as part of the Sofia
Christmas Fest.
Fibank presented its 2024 charity calendar dedicated to sustainable development and focusing
on water resources and their conservation.
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FINANCIAL REVIEW
KEY INDICATORS
2023
2022
2021
2020
2019
Financial indicators (BGN thousand)
Net interest income
369,902
270,740
263,144
232,649
230,696
Net fee and commission income
151,549
139,515
118,865
95,849
103,230
Net trading income
23,295
19,717
15,380
11,991
14,929
Total income from banking operations
517,554
444,167
408,757
350,833
420,785
Administrative expenses
(210,667)
(205,113)
(179,441)
(181,842)
(209,157)
Impairment
(137,168)
(135,349)
(122,494)
(93,660)
(117,490)
Net profit
135,041
81,205
100,083
38,881
129,221
Balance-sheet indicators (BGN thousand)
Assets
13,888,528
12,714,058
11,268,870
10,832,829
10,200,031
Loans and advances to customers
7,158,309
6,384,541
6,315,581
6,038,889
5,776,915
Investments in securities
2,583,949
2,598,137
1,482,699
1,132,106
843,378
Due to other customers
11,494,164
10,798,450
9,425,251
9,100,155
8,684,001
Other borrowed funds
439,634
116,487
106,271
104,151
109,723
Hybrid debt
257,871
256,861
320,733
267,579
267,615
Shareholders’ equity
1,472,926
1,328,209
1,268,864
1,177,749
943,065
Key ratios (in %)
Capital adequacy ratio
21.09
21.74
21.46
21.78
18.80
Tier 1 capital ratio
21.09
21.74
21.46
21.78
18.80
CET 1 ratio
17.60
18.11
17.86
18.18
15.00
Leverage ratio
11.05
11.84
13.26
13.79
12.13
Liquid assets/deposits from customers
39.22
36.75
28.07
29.84
27.43
Liquidity coverage ratio (LCR)
278.55
225.36
230.36
236.84
198.25
Net stable financing ratio (NSFR)
150.48
145.47
137.42
132.35
130.38
Net loans/deposits ratio
62.28
59.12
67.01
66.36
66.52
Cost of risk
1.83
2.02
1.82
1.40
1.86
Net interest income/total income from
banking operations
71.47
60.95
64.38
66.31
54.83
Cost/income ratio
42.25
47.57
43.39
56.99
44.43
Resources (in numbers)
Branches and offices
120
126
127
134
144
Staff
2,408
2,454
2,466
2,524
2,572
In June 2023, Fitch Ratings fully affirmed the credit ratings of First Investment Bank as follows: long-
term rating “B” with a stable outlook, short-term rating “B”, viability rating “b“, government support
rating ns” (no support).
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30 YEARS FIBANK
In 2023, First Investment Bank celebrated its 30th anniversary.
During these 30 years, Fibank:
Actively participated in the formation and development of the banking market in Bulgaria,
contributing with innovative products and viable solutions;
Maintained a high quality of customer service by constantly improving processes, offering
a variety of services, advising and supporting customers;
Built a flexible business model and recognizable brand among the best in the sector.
Actively managed the risks inherent in its activity by enhancing the protection mechanisms
and maintaining solid capital and liquidity positions;
Applied the principles of responsible banking, aiming to achieve sustainable development
and establish itself as a preferred employer and a socially responsible institution.
BALANCE-SHEET INDICATORS
FINANCIAL INDICATORS
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FINANCIAL RESULTS
In 2023, First Investment Bank reported very good financial results as the net profit increased by 66.3%
to BGN 135,041 thousand (2022: BGN 81,205 thousand), and the profit before impairment to BGN
287,985 thousand compared to BGN 226,094 thousand a year earlier. The results were influenced by
the higher operating income and the policies to reduce non-performing exposures and repossessed
assets. Total income from banking operations increased to BGN 517,554 thousand (2022: BGN 444,167
thousand) with an increase in all main sources of income, incl. mainly in net interest income. The return
on equity (after tax) was 9.60% and the return on assets (after tax) was 1.03%.
In 2023, net interest income increased by 36.6% to BGN 369,902 thousand (2022: BGN 270,740
thousand), increasing its share as the main source of income for the Bank accounting for 71.5% of total
operating income (2022: 61.0%). For the reporting period, interest income increased to BGN 404,711
thousand (2022: BGN 310,785 thousand), as a result of an increase in the main business segments,
including of retail banking (2023: BGN 140,711 thousand; 2022: BGN 129,095 thousand) and
enterprises
10
, incl. large enterprises (2023: BGN 93,147 thousand; 2022: BGN 77,063 thousand),
medium-sized enterprisies (2023: BGN 39,934 thousand; 2022: BGN 32,358 thousand), small
enterprises (2023: BGN 45,626 thousand; 2022: BGN 37,200 thousand) and micro-enterprises (2023:
BGN 9,397 thousand; 2022: BGN 7,427 thousand). An increase was also recorded in investments in the
debt instruments (2023: BGN 71,060 thousand; 2022: BGN 24,520 thousand), used as an additional
source of interest income.
In interest expenses the trend from the previous years was preserved, as a decrease continued to be
reported in the expenses on customer deposits, which reached BGN 1,043 thousand, compared to BGN
1,567 thousand a year earlier. A decrease was recorded in the interest expenses on hybrid debt (2023:
BGN 25,753 thousand; 2022: BGN 33,488 thousand) as a result of the undertaken by the Bank
measures for its optimisation. Increase was recorded in the interest expenses on other attracted funds
(2023: BGN 7,041 thousand; 2022: BGN 4,285 thousand), related to increasing obligations on loan
10
According to business segments of the Bank, incl. criteria for annual turnover, as well as: microenterprises
up to BGN 3.9 million; small enterprises up to BGN 19.5 million; medium-sized enterprises up to BGN 97.5
million.
NET PROFIT
TOTAL INCOME FROM
BANKING OPERATIONS
13%
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contracts, offered to meeting MREL requirements. The net interest margin of the Bank amounted to
3.75% for the period.
Net fee and commission income for 2023 increased by 8.6% to BGN 151,549 thousand (2022: BGN
139,515 thousand), forming 29.3% (21.3% average for the banking system) of total income from
banking operations (2022: 31.4%), providing a solid contribution to operating profit. An increase was
recorded in all major sources of income, incl. payment operations (2023: BGN 31,075 thousand; 2022:
BGN 28,421 thousand), card services (2023: BGN 53,406 thousand; 2022: BGN 46,547 thousand),
letters of credit and guarantees (2023: BGN 3,653 thousand; 2022: BGN 3,559 thousand), as well as
other services (2023: BGN 64,963 thousand; 2022: BGN 45,536 thousand), at the expense of customer
accounts which decrased (2023: BGN 39,508 thousand; 2022: BGN 48,927 thousand). The Bank aims
for developing banking services, with focus in the field of cross-selling and maintaining long-term
relations with clients.
For 2023, net trading income reached BGN 23,295 thousand (2022: BGN 19,717 thousand), the
increase mainly due to higher income from foreign currency transactions, which amounted to BGN
22,148 thousand, compared to BGN 20,259 thousand a year earlier. Net income was reported for debt
and equity instrument transactions, which totaling BGN 1,147 thousand for the period, compared to
net expenses of BGN 542 thousand for the previous year. The relative share of net trading income
remained insignificant at 4.5% of total income from banking operations (2022: 4.4%).
The other net operating expenses amounted to BGN 27,192 thousand, compared to net revenues of
BGN 14,195 thousand a year earlier, influenced mainly due to higher operating expenses related to
debt instruments BGN 44,993 thousand.
For the period, administrative expenses increased to BGN 210,667 thousand compared to BGN
205,113 thousand a year earlier, influenced mainly by the inflationary processes in the country and
the related increase in the personnel costs (2023: 85,816 thousand; 2022: BGN 74,545 thousand). An
increase was also recorded in the costs for advertising (2022: BGN 10,176 thousand; 2022: BGN 8,455
thousand), related to organised marketing campaigns, as well as those related to telecommunications,
software and other computer maintainance (2023: BGN 15,351 thousand; 2022: BGN 13,753
thousand), which are in line with the development of information technologies. At levels close to the
previous year remained the costs for depreciation of property, plant and equipment (2023: BGN
12,969 thousand; 2022: BGN 12,060 thousand), while decrease was registered in the costs of
depreciation of right-of-use assets (2023: BGN 32,195 thousand; 2022: BGN 40,021 thousand), as well
as in the costs of external services (2023: BGN 54,160 thousand; 2022: BGN 56,279 thousand). For the
INTEREST INCOME FEE AND COMMISSION INCOME
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period, cost/income ratio amounted to 42.25% on an individual basis (2022: 47.57%), which is within
the target value of below 50%, set as a quantitative indicator in the development strategy.
During the year additional write-downs were made on loans, off-balance sheet commitments
amounting to BGN 233,223 thousand, while BGN 96,055 thousand impairment losses were reversed.
As a result, net impairment for 2023 amounted to BGN 137,168 thousand (2022: BGN 135,349
thousand). For more information see the “Risk Management section.
For the reporting period, First Investment Bank reported other net expenses in the amount of BGN
18,902 thousand, compared to BGN 12,960 thousand a year earlier, which included mainly
contributions made by the Bank to guarantee schemes, including deposit insurance funds, for
restructuring and investor compensation (2023: BGN 23,838 thousand; 2022: BGN 24,534 thousand).
For more information, see the Individual Financial Statements for the year ending 31 December 2023.
ADMINISTRATIVE EXPENSES
STRUCTURE OF
ADMINISTRATIVE EXPENSES
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BALANCE SHEET
In 2023, the total assets of First Investment Bank increased by 9.2% to BGN 13,888,528 thousand,
compared to BGN 12,714,058 thousand a year earlier. The dynamics reflected the increase of the
borrowed funds, the development of the loan portfolio and the management of cash and liquid assets.
Fibank maintains its leading position among banks in the country, ranking fifth in terms of assets at the
end of 2023 (2022: fifth), with a market share of 8.07% on an individual basis (2022: 8.18%).
In the structure of the Bank's assets, loans and advances to customers strengthen their structure-
determining share - 51.5% of total assets (2022: 50.2%), followed by investments in securities - 18.6%
(2022: 20.4%) and cash and receivables from central banks 16.7% (2022: 15.0%). The repossessed
assets continue to reduce their share to 2.9% (2022: 3.2%) and investment properties to 5.4% (2022:
5.9%) as part of actions aimed at reducing of non-interest-bearing assets and their effective realization.
The net loans/deposits ratio amounted to 62.3% compared to 59.1% for the previous year in
accordance with the conservative risk management policy.
Cash and receivables from central banks increased to BGN 2,325,807 thousand, compared to the levels
of the previous year - BGN 1,911,371 thousand, mainly as a result of an increase in receivables from
central banks (2023: BGN 1,844,620 thousand; 2022: BGN 1,427,241 thousand), which is influenced by
the requirements increased by the BNB during the period for maintaining minimum mandatory
reserves for borrowed funds from 10 to 12 percent. As of the end of 2023, cash on hand increased
(2023: BGN 311,763 thousand; 2022: BGN 248,540 thousand), at the expense of current accounts in
foreign banks (2023: BGN 235,590 thousand; 2022: BGN 165,600 thousand), managed as part of
liquidity.
Loans and advances to banks and financial institutions decreased (2023: BGN 259,718 thousand; 2022:
BGN 264,984 thousand), mainly influenced by the receivables from foreign banks, at the expense of
those from local banks and financial institutions.
The securities investment portfolio remains almost unchanged at the end of the year (2023: BGN
2,583,949 thousand; 2022: BGN 2,598,137 thousand), managed according to market conditions and
with a view to generating additional income while maintaining proper balance between risk and return.
The structure of the portfolio mainly includes government securities of the Bulgarian government
(2023: BGN 542,334 thousand; 2022: BGN 575,672 thousand) and of foreign governments (2023: BGN
1,681,195 thousand; 2022: BGN 1,575,324 thousand), which mainly contain government debt of
ASSETS STRUCTURE OF ASSETS
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European Union member states. Bonds and other securities issued by enterprises amount to BGN
280,619 thousand, and those issued by banks - to BGN 39,114 thousand).
In accordance with the requirements regarding the business models and the IFRS 9 criteria for
classification and valuation of financial assets in the Bank's portfolios BGN 1,077,079 thousand of the
securities portfolio were measured at fair value through other comprehensive income (2022: BGN
468,247 thousand), BGN 1,263,279 thousand - at amortized cost (2022: BGN 1,862,203 thousand), and
BGN 243,591 thousand - at fair value through profit or loss (2022: BGN 267,687 thousand). Investments
in subsidiaries decreased to BGN 34,683 thousand at the end of the period, compared to BGN 38,526
thousand a year earlier, as a result of terminated subsidiary during the year - First Investment Finance
B.V., Netherlands.
As of December 31, 2023, Fibank's operations abroad (Cyprus branch) formed 5.1% (2022: 2.0%) of the
Bank's assets and 5.0% (2022: 6.4%) of the Bank's liabilities, as the Cyprus branch’s activities were
focused on the micro and small business segments, as well as on retail banking.
Repossessed assets decreased to BGN 403,523 thousand (2022: BGN 412,996 thousand), while
investment properties were BGN 756,767 thousand (2022: BGN 750,324 thousand). During the year,
such properties were acquired in the amount of BGN 147 thousand and properties sold amounting to
BGN 9,532 thousand were written off. Additional costs were recognized in asset value at BGN 11,351
thousand, as well as transferred assets from property and equipment at BGN 4,477 thousand.
Other assets of the Bank amounted to BGN 120,177 thousand (2022: BGN 114,246 thousand), including
deferred expenses, gold and other receivables. The right-of-use assets amounted to BGN 121,410
thousand at the end of the year (2022: BGN 124,159 thousand), decreasing mainly in connection with
the accumulated depreciation for the period.
For more information see the Individual Financial Statements for the year ended December 31, 2023.
PORTFOLIO OF
FINANCIAL INSTRUMENTS
PORTFOLIO OF GOVERNMENT DEBT
BY COUNTRIES
2023
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LOAN PORTFOLIO
LOANS
In 2023 the net loan portfolio of First Investment Bank increased by 12.1% to BGN 7,158,309 thousand
(2022: BGN 6,384,541 thousand), with an increase in all main business segments. As of December 31,
2023, Fibank ranked fifth in terms of loans among banks in the country, reporting a market share of
8.23% (2022: 8.27%).
In BGN thousand / % of total
2023
%
2022
%
2021
%
Retail banking
2,547,968
33.9
2,334,010
34.5
2,120,134
31.3
Micro enterprises
216,593
2.9
198,538
2.9
182,625
2.7
Small enterprises
1,021,711
13.6
878,135
13.0
878,125
13.0
Medium-sized enterprises
1,179,493
15.7
1,085,974
16.0
1,123,631
16.6
Large enterprises
2,557,431
34.0
2,270,652
33.6
2,474,806
36.5
Gross loan portfolio
7,523,196
100
6,767,309
100
6,779,321
100
Impairment
(364,887)
(382,768)
(463,740)
Net loan portfolio
7,158,309
6,384,541
6,315,581
The structure of the portfolio remained balanced, with exposures in the retail banking segment
forming 33.9% of the gross portfolio (2022: 34.5%), micro, small and medium-sized enterprises
11
respectively 2.9% (2022: 2.9%), 13.6% (2022: 13.0%) and 15.7% (2022: 16.0%) or a total of 32.2% (2022:
31.9%) structured according to the Law on Small and Medium-sized Enterprises, while the large
enterprises 34.0% of the gross portfolio (2022: 33.6%).
In BGN thousand / % of total
2023
%
2022
%
2021
%
Loans in BGN
4,976,546
66.2
4,233,941
62.6
4,048,836
59.7
Loans in EUR
2,342,198
31.1
2,326,562
34.4
2,481,510
36.6
Loans in other currency
204,452
2.7
206,805
3.0
248,975
3.7
Gross loan portfolio
7,523,196
100
6,767,309
100
6,779,321
100
Impairment
(364,887)
(382,768)
(463,740)
Net loan portfolio
7,158,309
6,384,541
6,315,581
In the currency structure of the loan portfolio, loans in BGN had a predominate share BGN 4,976,546
thousand (2022: BGN 4,233,941 thousand) or 66.2% of the total portfolio (2022: 62.6%), followed by
those in euro BGN 2,342,198 thousand (2022: BGN 2,326,562 thousand) or 31.1% (2022: 34.4%) of
total loans. The country has a currency board system in place which minimizes the BGN/EUR currency
risk. Since 2020, Bulgaria is part of the European Exchange Rate Mechanism (ERM) II and the Single
Supervisory Mechanism (SSM), which was a step towards the country's accession to the Eurozone.
Loans in other currencies amounted to BGN 204,452 thousand (2022: BGN 206,805 thousand), forming
2.7% of total loans (2022: 3.0%).
11
According to business segments of the Bank, incl. criteria for annual turnover/assets, as well as:
microenterprises up to BGN 3.9 million; small enterprises up to BGN 19.5 million; medium-sized enterprises
up to BGN 97.5 million/ BGN 84 million.
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At the end of the period, impairment charges for potential losses on the loan portfolio amounted to
BGN 364,887 thousand compared to BGN 382,768 thousand a year earlier. In 2023, additional
impairment was recognized in the amount of BGN 232,980 thousand, impairment losses in the amount
BGN 95,022 thousand were reversed, and BGN 225,693 thousand were written off as part of the
successive actions to reduce non-performing exposures.
It is the policy of the Bank to require adequate collateral upon granting loans. All legally permissible
types of collateral are accepted, and a discount rate is applied depending on their expected realizable
value.
As of the end of 2023, the type of collateral with the largest share in the Bank's portfolio were sureties
and other guarantees 46.8%, followed by pledges of receivables 26.2% and mortgages 20.5%.
For more information on credit risk, see Note 3 “Risk Management” of the Individual Financial
Statements for the year ended December 31, 2023.
LOAN PORTFOLIO AND IMPAIRMENT COST OF RISK
2%
LOAN PORTFOLIO
BY TYPE OF COLLATERAL
COVERAGE OF THE PORTFOLIO
WITH COLLATERAL
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RELATED PARTY TRANSACTIONS
In the course of its ordinary activities, the Bank also enters into transactions with related parties. These
transactions are carried out under market criteria and in accordance with applicable law.
Type of related party
Parties that control or
manage the Bank
Enterprises under
common control
In BGN thousand
2023
2022
2021
2023
2022
2021
Loans
1,553
2,944
3,515
71,359
78,316
83,666
Deposits and loans received
16,144
14,195
13,725
80,751
115,177
125,350
Deposits placed
-
-
-
81,338
92,146
5,868
Other receivables
-
-
-
15,118
12,467
18,037
Other borrowings
-
-
-
6,334
150
420
Off-balance sheet commitments
2,100
1,023
1,061
3,541
2,029
2,792
Leasing liabilities
-
-
-
2,669
2,684
1,513
Type of related party
Parties that control or
manage the Bank
Enterprises under
common control
In BGN thousand
2023
2022
2021
2023
2022
2021
Interest income
31
35
24
4,193
3,065
3,089
Interest expense
7
8
8
1,512
231
547
Fee and commission income
30
27
16
771
1,769
1,082
Fee and commission expense
7
6
4
6
301
296
For more information regarding related party transactions, see Note 35 “Related party transactions”
of the Individual Financial Statements for the year ended December 31, 2023.
CONTIGENT LIABILITIES
Contingent liabilities of First Investment Bank include bank guarantees, letters of credit, unused credit
lines, promissory notes and others. These are provided in accordance with the general credit policy on
risk assessment and collateral value. With regard to documentary transactions performed, the Bank is
also guided by the unified international rules in the area, protecting the interests of parties to such
transactions.
At the end of the period, the total amount of off-balance sheet commitments amounted to
BGN 1,186,167 thousand compared to BGN 1,026,495 thousand a year earlier. An increase was
reported in unused credit lines up to BGN 992,286 thousand (2022: BGN 837,477 thousand), in bank
guarantees up to BGN 160,443 thousand (2022: BGN 157,251 thousand) and in letters of credit up
to BGN 33,438 thousand (2022: BGN 31,767 thousand).
For more information on off-balance sheet commitments, see Note 32 "Contingent liabilities" of the
Individual Financial Statements for the year ended December 31, 2023 .
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ATTRACTED FUNDS
In 2023, attracted funds from customers increased by 6.4% and reached BGN 11,494,164 thousand
(2022: BGN 10,798,450 thousand), remaining the main source of funding for the Bank and forming
92.6% of total liabilities (2022: 94.8%). First Investment Bank offers savings products and package
programs tailored to market conditions and customer needs. As at December 31, 2023, the Bank
ranked fifth by deposit size among banks in Bulgaria (2022: fifth) with a market share of 8.40% on
individual basis (2022: 8.59%).
Deposits of individuals increased by 7.0% to BGN 7,772,234 thousand at the end of the period
compared to BGN 7,260,749 thousand a year earlier. They retained a major share of total borrowings
at 67.6% (2022: 67.2%). The currency structure of retail deposits was dominated by funds in BGN
accounting for 43.8% of all borrowings (2022: 42.2%), followed by funds in euros at 19.5% (2022:
20.2%) and in other currencies at 4.3% (2022: 4.9%).
In BGN thousand / % of total
2023
%
2022
%
2021
%
Attracted funds from individuals
7,772,234
67.6
7,260,749
67,2
6,993,994
74.2
In BGN
5,031,180
43.8
4,552,829
42,2
4,352,688
46.2
In EUR
2,244,113
19.5
2,182,818
20,2
2,131,028
22.6
In other currency
496,941
4.3
525,102
4,9
510,278
5.4
Attracted funds from corporate,
state-owned and public
institutions
3,721,930
32.4
3,537,701
32,8
2,431,257
25.8
In BGN
2,153,963
18.7
2,018,602
18,7
1,400,350
14.9
In EUR
1,343,191
11.7
1,272,193
11,8
883,292
9.4
In other currency
224,776
2.0
246,906
2,3
147,615
1.6
Total attracted funds from
customers
11,494,164
100
10,798,450
100
9,425,251
100
In accordance with the regulatory requirements, First Investment Bank allocates annual contributions
to the Deposit Insurance Fund. As provided by law, the Fund guarantees amounts up to BGN 196,000
kept in a customer’s accounts with the Bank.
Attracted funds from corporates and institutions increased by 5.2% to BGN 3,721,930 thousand (2022:
BGN 3,537,701 thousand), which is influenced by the Bank’s consistent policy of developing the
transaction business and maintaining lasting customer relationships. At the end of 2023 their relative
share amounts to 32.4% of the total borrowings from customers (2022: 32.8%). As regards the currency
structure, funds in BGN attracted from corporates and public institutions formed 18.7% of all
borrowings (2022: 18.7%), those in euros 11.7% (2022: 11.8%) , and those in other currencies 2.0%
(2022: 2.3%).
Other borrowings increased to BGN 439,634 thousand as of December 31, 2023 compared to BGN
116,487 thousand a year earlier, mainly as a result of an increase in the obligations under borrowing
agreements for the fulfillment of the requirements for eligible liabilities (MREL) according to
Regulation (EU) 575/2013 and the Law on Recovery and Restructuring of Credit Institutions and
Investment Intermediaries. For more information, see the Capital section.
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Liabilities for received financing amount to BGN 34,574 thousand (2022: BGN 36,611 thousand), which
included financing from the Fund Manager of Financial Instruments in Bulgaria (Fund of Funds) - BGN
19,366 thousand (2022: BGN 20,174 thousand), from the Bulgarian Development Bank AD BGN
14,331 thousand (2022: BGN 14,931 thousand), as well as from the European Investment Fund under
the JEREMIE 2 initiative BGN 877 thousand (2022: BGN 1,506 thousand). For more information, see
the "External programs and warranty schemes" section.
For 2023, liabilities due to banks in the form of current and term accounts amounted to BGN 54,326
thousand, compared to BGN 45,703 thousand a year earlier.
Leasing liabilities amounted to BGN 121,503 thousand at the end of the year (2022: BGN 124,240
thousand), decreasing in connection with the lease payments made during the period.
For more information on borrowings, see the Individual Financial Statements for the year ending 31
December 2023.
CUSTOMER DEPOSITS OTHER ATTRACTED FUNDS
9%
4%
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CAPITAL
As of December 31, 2023 the share capital of First Investment Bank amounted to BGN 149,085
thousand, divided into 149,084,800 ordinary, registered, dematerialized shares with voting rights in
the Total General Meeting of Shareholders and a nominal value of BGN 1 each. The share capital has
been paid in full. The share premium amounted to BGN 250,017 thousand.
The balance sheet equity of First Investment Bank increased by 10.9% to BGN 1,472,926 thousand
(2022: BGN 1,328,209 thousand), influenced by the increase in other reserves and retained earnings,
which reached BGN 1,035,102 thousand at the end of the period (2022: BGN 900,061 thousand).
REGULATORY CAPITAL
First Investment Bank maintains own funds for the purpose of capital adequacy in the form of Common
Equity Tier 1 and Additional Tier 1 capital, following the requirements of Regulation (EU) No575/2013
and the EC implementing regulations, as well as Ordinance No7 of the BNB on the Organization and
Management of Risks in Banks.
By the end of the reporting period the CET1 capital amounted to BGN 1,282,862 thousand, compared
to BGN 1,269,041 thousand a year earlier, when corrections related to the transitional treatment
according to Regulation (EU) 2017/2395 on mitigating the impact of the introduction of IFRS9 were
last applied. Tier 1 capital amounted to BGN 1,537,120 thousand (2022: BGN 1,523,299 thousand), and
total regulatory equity was BGN 1,537,120 thousand (2022: BGN 1,523,299 thousand).
As of 31.12.2023, First Investment Bank had four hybrid instruments (bond issues) with an original
principal amount of EUR 60 million (ISIN: BG2100022123), EUR 30 million (ISIN: BG2100023196), EUR
30 million (ISIN: XS2419929422) and EUR 10 million (ISIN: XS2488805461), included in the additional
Tier 1 capital of the Bank. Three of the issues are admitted to trading on the regulated market of the
Luxembourg Stock Exchange (LuxSE). At the end of the reporting period, the amortized cost of the
hybrid debt amounted to BGN 257,871 thousand (2022: BGN 256,861 thousand). For more
information, see Note 29 "Hybrid Debt" of the Individual Financial Statements for the year ending 31
December 2023.
BALANCE-SHEET EQUITY STRUCTURE OF EQUITY
2023
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For the purpose of reporting qualifying holdings outside the financial sector, First Investment Bank
applies the definition of eligible capital, which includes tier 1 capital and tier 2 capital, which cannot
exceed 1/3 of tier 1 capital. As at 31 December 2023, the eligible capital of First Investment Bank,
calculated in accordance with Regulation (EU) No 575/2013 and Ordinance No7 of BNB for the
organization and management of risks in banks amounted to BGN 1,537,120 thousand.
CAPITAL REQUIREMENTS
At the end of 2023, First Investment Bank reported stable capital ratios as follows: Common Equity
Tier 1 (CET1) ratio at 17.60%, Tier 1 capital ratio at 21.09% and Total Capital Adequacy ratio at 21 .09%,
exceeding the minimum regulatory capital requirements expressed by the overall capital requirement,
including the additional capital requirement for risks other than the risk of excessive leverage (in the
amount of 2.10% of the risk exposures) and the combined buffer requirement. For more information,
see the "Capital buffers" section.
In BGN thousand / % of risk
exposures
2023
%
2022
%
2021
%
CET 1 capital
1,282,862
17.60
1,269,041
18.11
1,264,009
17.86
Tier 1 capital
1,537,120
21.09
1,523,299
21.74
1,518,267
21.46
Own funds
1,537,120
21.09
1,523,299
21.74
1,518,267
21.46
Total risk exposures
7,289,126
7,007,065
7,075,369
The reported capital ratios resulted from the application of comprehensive and targeted measures
regarding the implementation of capital levers in key areas, including successful subscription of a new
public issue of shares, retention of profit, inclusion of the issued debt-capital (hybrid) instrument in
the Additional Tier 1 capital, as well as maintaining high discipline in risk management.
REGULATORY CAPITAL CAPITAL ADEQUACY IN 2023
1%
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CAPITAL BUFFERS
In addition to the capital requirements set out in Regulation (EU) № 575/2013 and the Law on Credit
Institutions, First Investment Bank maintains four capital buffers in accordance with the requirements
of Ordinance №8 of the BNB on Capital Buffers, the Combined Buffer Requirement, Restrictions on
Distributions and the Guidance on Additional Own Funds.
First Investment Bank maintains a capital conservation buffer, comprised of common equity tier 1
capital, equal to 2.5% of the total risk exposure of the Bank, as well as buffer for systemic risk covered
by common equity tier 1 capital with the aim for decreasing the effect of potential long-term non-
cyclical system or macroprudential risks in the banking system in the country. In 2023 the level of the
capital buffer for systemic risk applicable to all banks in Bulgaria remained unchanged at 3% of the
total risk exposures in the country.
With the aim for protection of the banking system against potential losses arising from the
accumulated cyclical systemic risk in periods of excessive credit growth, the banks in Bulgaria, incl.
Fibank maintains a countercyclical capital buffer, applicable to credit risk exposures in the Republic of
Bulgaria. Its level is determined by the Bulgarian National Bank each quarter, and in 2023 it gradually
increased to 1.5% as of 01.01.2023 and to 2.0% as of 01.10.2023. According to decisions of the BNB (in
2023 d.) its level will remain unchanged until the first quarter of 2025.
In addition, the determined by BNB other systematically important institutions (O-SII) in the country
among which First Investment Bank AD should maintain a buffer for O-SII with a view on their
significance for the national economy and financial system. The applicable for Fibank buffer for O-SII
on an individual and consolidated basis, determined as a share of the total value of the risk exposures
has been reduced from 1.00% to 0.75% as of 01.01.2023 and from 01.01.2024.
Capital
buffer for
O-SII
Decision of MB of BNB
from 22.12.2022 and
from 21.12.2023
Decision of MB of
BNB from
18.10.2023
Counter-
Cyclical capital
buffer
CAPITAL BUFFERS
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LEVERAGE
The leverage ratio is an additional regulatory and supervisory tool, which measures the required capital
maintained by banks that is not risk-sensitive or risk-weighted, thereby complementing and building
on the risk-based capital ratios applicable under the existing regulatory framework. In terms of the
leverage ratio, on EU level, banks should report and disclose the indicator in order to maintain the
minimum required amount of 3% under Regulation (EU) № 575/2013.
First Investment Bank calculates the leverage ratio by matching its Tier 1 capital to the total exposure
of the Bank (assets, off-balance sheet items, and other exposures to derivatives and securities
financing transactions), subject to the requirements of Delegated Regulation (EU) 2015/62 of the
Commission concerning the leverage ratios and the other applicable regulations. As at 31 December
2023, the leverage ratio amounted to 11.05% on a standalone basis compared to 11.84% for the
previous period, impacted by the increase in the total exposure measure.
First Investment Bank has written rules in place to identify, manage and monitor the risk of excessive
leverage resulting from potential vulnerability of the Bank related to the maintained levels of leverage.
The risk of excessive leverage is currently monitored based on specific indicators, which include the
leverage ratio, calculated in accordance with applicable regulatory requirements, as well as the
mismatches between assets and liabilities. The Bank manages this type of risk using various scenarios,
including such that take into account its possible increase due to a decrease in the Tier 1 capital
resulting from potential losses. The leverage ratio is also part of the capital indicators of the system
for ongoing monitoring and early warning, and is incorporated in the framework for risk management
at the Bank, including in the management processes in case of potential financial risks.
LEVERAGE RATIO EQUITY/ ASSETS RATIO
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ELIGIBLE LIABILITIES
In compliance with the requirements of the Law on Recovery and Resolution of Credit Institutions and
Investment Firms and Regulation (EU) No 575/2013, banks need to meet minimum requirements for
own funds and eligible liabilities (MREL), as well as subordination requirements in relation to them,
determined individually for each institution by the restructuring authority and calculated as a
percentage of the total risk exposure amount (TREA) and the leverage ratio exposure measure (LRE).
According to a decision of the BNB, the deadline for meeting the minimum requirements for the Bank
is July 1, 2025. In order to ensure gradual accumulation of own funds and eligible liabilities,
intermediate target levels have been set (as of January 1, 2022, January 1, 2023 , January 1, 2024 and
January 1, 2025).
In 2023, First Investment Bank continued to develop its products in fulfillment of the minimum
requirements for eligible obligations (MREL), incl. the obligations under committed funds and the
Perspective+ borrowing products, which are senior unsecured debt product with a fixed yield,
structured in such a way as to comply with the requirements for maturity, security, subordination, loss
sharing, acceleration, and others under the Law on the Recovery and Resolution of Credit Institutions
and Investment Firms and Regulation (EU) No 575/2013.
For more information on capital and eligible liabilities see the Individual Financial Statements as at 31
December 2023.
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RISK MANAGEMENT
First Investment Bank has built, maintained, and developed a risk management system which ensures
the identification, assessment and management of risks inherent to its activity, taking into
consideration the challenges of the external environment and the regulatory requirements.
In 2023, the Bank operated in accordance with its Risk Management Strategy and Risk Appetite
Framework, aiming to maintain a moderately low level of risk and further increasing the protection
mechanisms against risks inherent in banking. The Bank continued to pursue its objectives for
reduction and management of non-performing exposures, incl. recovery and restructuring of loan
exposures, as well as regular write-offs of fully impaired and non-collectable risk exposures in
accordance with the Strategy for Reduction of Non-performing Exposures and Repossessed Assets.
RISK MANAGEMENT STRATEGY
The risk management strategy of First Investment Bank is an integral part of its business strategy. The
main objective in managing the overall risk profile of the Bank is to achieve a balance between risk,
return and capital. The risk profile is relevant to the product policy of the Bank and is determined in
accordance with the economic factors in the country and the Bank’s internal characteristics and
requirements.
The Bank determines its risk propensity and risk tolerance levels so that they correspond to its strategic
objectives and stable functioning, as well as to the required level of equity capital and an effective
management process.
Fibank maintains financial resources that are commensurate with the volume and type of operations
performed and with its risk profile, by developing internal control systems and mechanisms for risk
management in accordance with regulatory requirements and best practices. The main goals on the
basis of which the risk strategy is structured, are defined, as follows:
achieving a sustainable level of capital to ensure good risk-taking capacity, as well as capacity
to cover risks in the long term;
RISK
STRATEGY
Risk
management
framework
Three lines
of defense
model
Risk
map
Strategic
goals
Risk
appetite
TARGET RISK PROFILE
Risk
culture
A system
of limits
Assessment,
monitoring
and reporting
of risks
KEY ELEMENTS OF RISK STRATEGY
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maintaining good asset quality while providing for an efficient decision-making process;
achieving a balanced risk/return ratio for all business activities of the Bank through defining a
risk tolerance for achieving the targeted business goals and tasks.
In 2023, as part of the annual review, the Risk Strategy was updated in accordance with the Risk
Appetite Framework and the Business Plan of the Bank. With regard to the risk profile, the Strategy
focused on the development of retail and SME segments, as well as on the digitization of processes,
cyber security and data protection, and development and applying the principles of responsible
banking, incl. reflecting ESG factors. Constant emphasis is placed on ensuring effective control
environment in relation to existing business processes, active management of credit and operational
risk, maintaining an adequate level of unencumbered liquid assets, and keeping assumed market risk
within current limits.
During the period, First Investment Bank AD developed a new 10-year Sustainable Development
Strategy taking into account the applicable ESG factors, the risks related to the transition to a
sustainable economy and the physical risks, as well as a new Climate and Environmental Risk
Management Policy.
RISK APPETITE FRAMEWORK
The Risk appetite framework of First Investment Bank is an integrated instrument for defining and
limiting the overall risk level, which the Bank is willing and able to take to achieve its strategic and
business goals. For 2023, a medium-low level of risk appetite is set to be maintained.
Defining and applying a risk appetite framework is based on assessment of the risk profile of the Bank
on the basis of the material risks identified in the risk map, as the overall risk profile is expressed into
a rating aggregated from the scores assigned to each of the specific risks throughout a 5-level scale
with quantitative values and risk levels.
Within the risk appetite framework, the risk capacity of the Bank is defined, which represents the
maximum level of risk the Bank can operate without breaking regulatory requirements and other limits
with respect to capital and funding needs and liabilities to counterparties. The risk tolerance is defined,
as a precautionary measure within maintaining the risk appetite, which as set on a strategic level is
defined as a percentage lower than 100% of the overall risk capacity of the Bank. For calculating the
risk appetite are the specific risk indicators and limits (for example the total capital ratio, the common
equity Tier 1 ratio, MREL ratio, leverage ratio, loan to deposit ratio, liuidity coverage ratio, net stable
funding ratio, return on equity, non-performing exposure ratio, provisioning ratio, operating
losses/regulatory capital, etc.), as well as early warning indicators in accordance with the type of risk.
The risk appetite framework is subject to review by the Managing Board and approval from the
Supervisory Board once a year or more often, if needed, in accordance with the business environment
dynamics. It is part of the annual process for defining the strategy and planning within the Bank.
RISK MAP
First Investment Bank develops a risk map, which classifies risks into different types and identifies
those the Bank is exposed to or may be exposed to in its activity. It is updated once a year or more
often if needed, aiming at defining all material risks and their adequate integration within the risk
management framework of the Bank.
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The types of risks are differentiated into groups (Pillar 1 and Pillar 2) as well as the methods for their
measurement in accordance with the applicable regulatory framework.
RISK CULTURE
Prudent and consistent risk culture is one of the key elements of effective risk management. In
compliance with the best standards, the Fibank seeks to develop a risk culture that will further enhance
visibility and prevention in terms of individual risk types, their identification, evaluation and
monitoring, including by applying appropriate forms of training among the employees and senior
management involved in risk management.
The Bank aims at applying the following principles for ensuring high risk culture:
risk taking within the approved risk appetite;
approval of every risk in accordance with the effective approval levels and the internal risk
management framework;
current/ongoing monitoring and risk management, incl. taking into consideration the
ecological, social and governance (ESG) factors;
responsibility of employees at all levels to the management and escalation of risks, while
applying a conservative and future-oriented approach in their assessment;
effective communication and constructive criticism aimed at making rational and informed
decisions, as well as creating conditions for open and positive engagement throughout the
organization;
applying appropriate incentives to contribute to sound and efficient management,
discouraging risk-taking in excess of the level acceptable to the Bank.
TYPES OF RISKS
PILLAR I
PILLAR II
CREDIT RISK OPERATIONAL RISK
External factors Internal factors
СТЪЛБ I
MARKET RISK
СТЪЛБ I
LIQUIDITY RISK
Strategic risk
Reputational risk
Risk from the usage of
statistical models
Risk of non-compliance
Risk of excessive
leverage
Interest rate risk in
the banking book
Concentration risk
Residual risk
Securitization risk
Currency risk to hedged
borrowers
Външни фактори Външни фактори
Political
Macro-economical
Social
Technological
Environment
Regulations
Employees
Processes
Systems
Products
Clients
Reputation
RISK PROFILE AND RISK MAP
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RISK MANAGEMENT FRAMEWORK
The risk management framework of First Investment Bank includes automated systems, written
policies, rules and procedures, mechanisms for the identification, assessment, monitoring and control
of risks, and measures to reduce them. Its main underlying principles are: objectivity, dual control of
any operation, centralized management, separation of duties, independence, clearly defined levels of
competencies and authority, adequacy of the intrabank requirements to the nature and volume of
activity, effective mechanisms for internal audit and control. The Bank meets the requirements of
current legislation to credit institutions for the preparation and maintenance of current recovery plans
in case of potential occurrence of financial difficulties and for the continuity of processes and activities,
including with regard to recovery of all critical functions and resources.
LINES OF DEFENCE
The risk management framework of First Investment Bank is structured in accordance with the
principle and model of the three lines of defense which is in compliance with the Basel Committee for
Banking Supervision principles for corporate governance in banks:
First line of defence: the business units which take the risk and are responsible for managing
it, including through identification, assessment, reporting in accordance with current limits,
procedures and controls implemented in the Bank;
Second line of defence: the Risk Management and Compliance functions which are
independent of the first line of defence. The Risk Management function monitors, assesses
and reports risks, while the Compliance function monitors and controls the maintaining of
internal regulations in compliance with the applicable regulatory provisions and standards;
Third line of defence: Internal Audit which is independent of the first and the second lines of
defence. It provides an independent review of the quality and effectiveness of risk
management, business processes and banking activity, as well as of the business planning and
internal policies and procedures.
The Bank’s policies on internal governance with respect to the internal control framework and the
independent risk management, compliance and audit functions are in accordance with the applicable
requirements in this sphere, including Ordinance No 10 of the BNB on the Organisation, Governance
and Internal Control of Banks, Ordinance No 7 of the BNB on Organisation and Risk Management of
Banks, the EBA Guidelines on internal governance pursuant to Directive 2013/36/EU
(EBA/GL/2021/05) and the EBA Guidelines on policies and procedures in relation to compliance
management and the role and responsibilities of the AML/CFT Compliance Officer under Article 8 and
Chapter VI of Directive (EU) 2015/849 (EBA/GL/2022/05).
STRUCTURE AND INTERNAL ORGANISATION
First Investment Bank has a developed risk management and control function, organized in line with
recognized international practices and standards, under the management of a Chief Risk Officer (a
member of the Managing Board) with appropriate experience and qualifications and directly reporting
to the Risk Committee of the Supervisory Board.
The Chief Risk Officer organizes the overall risk management framework of the Bank, manages the
process of its implementation, coordinates the activities of the risk committees of the Bank, and
controls the credit process in its entirety, including the process of collection of problem loans. He
ensures the effective monitoring, measuring, controlling and reporting of all types of risk to which the
Bank is exposed.
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First Investment Bank has also developed a compliance function, whose main objective is to identify,
assess, monitor and report the risk of non-compliance. The function ensures the compliance of
activities with regulatory requirements and recognized standards, and supports the Managing Board
and senior staff in the management and control of this risk. The function is organized under the
management of the Chief Compliance Officer and subordination to the Chief Executive Officer, with
direct reporting to the Risk Committee and/or the Supervisory Board. The Chief Executive Officer
(member of the Managing Board of the Bank) ensures the organization for applying the compliance
function within the Bank, as well as its integration in the established risk management framework
across the Bank, by all business units and at all levels. In 2023, a new Chief Compliance Officer was
appointed. The CCO leads and coordinates the Compliance function at individual and group level,
reporting to the MB, the SB and the Risk Committee on non-compliance risks and their overall
assessment.
First Investment Bank maintains an information system allowing for the measurement and control of
risks through the use of internal rating models for assessment of the quality of the borrower, assigning
of credit rating to exposure, and obtaining quantitative assessment of risk. The information system
ensures maintenance of a database and subsequent processing of data for the purposes of risk
management, including for preparation of the regular reports necessary for monitoring the risk profile
of the Bank.
COLLECTIVE RISK MANAGEMENT BODIES
The overall process of risk management is carried out under the guidance of the Managing Board of
First Investment Bank. The Supervisory Board exercises control over the activities of the Managing
Board on risk management, liquidity and capital adequacy, directly and/or through the Risk Committee
which functions as an auxiliary body to the Supervisory Board in accordance with existing internal bank
rules and procedures.
Risk committee advises the Supervisory Board and the Managing Board in relation to the overall
current and future strategy on ensuring compliance of the risk policy and risk limits, risk-taking
propensity and control on its execution by the senior management. During the year there were no
changes in the composition of the Risk Committee. As at 31 December 2023, it consisted of three
members of the Supervisory Board of First Investment Bank AD. The Chairman of the Risk Committee
is Mr. Jyrki Koskelo, independent member of the Supervisory Board.
For supporting the activity of the Managing Board in managing the various types of risks, the following
collective management bodies operate at the Head Office of First Investment Bank: a Credit Council,
an Asset, liability and Liquidity management Council (ALCO), a Restructuring Committee and an
Operational Risk Committee, which carry out their activities on the basis of written structure, scope of
activities and functions.
The Credit Council supports the management of the credit risk undertaken by the Bank by issuing
opinions on loan transactions in accordance with the authority level assigned thereto, including with
regards to proposals from the operational/business units in the Head Office, as well as from the
branches of the Bank in the country and abroad. During the year there were no changes in the
composition of the Credit Council. The Chairman of the Credit Council is the Chief Risk Officer (CRO),
while the other members include the Chief Corporate Banking Officer (CCBO), the Director and
Member of the Managing Board regarding Small Enterprises Banking, as well as the Director of the
Credit Risk Management, Monitoring and Provisioning department.
The Asset, liability and Liquidity management Council (ALCO) is a specialized collective body which
advises the Managing Board on matters relating to implementing the policy for asset and liability
management, and maintaining adequate liquidity in the Bank. It carries out systematic analysis of the
interest-rate structure of assets and liabilities, of the maturity ladder and of liquidity indicators, with a
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view to possible early warning and taking actions for their optimization. During the year there were no
changes in the composition of ALCO. The Chairperson of ALCO is the Chief Executive Officer (CEO), and
other members include, the Chief Financial Officer (CFO), and the directors of the Treasury, Risk
Analysis and Control, Retail Banking and Large Enterprises Banking departments.
The Restructuring Committee is a specialized internal bank body responsible for the monitoring,
evaluation, classification, impairment and provisioning of risk exposures and commitments. It also
gives motivated written proposals to the Managing Board, and decides on restructuring of exposures
according to the current authority levels in the Bank. During the year there were no changes in the
composition of the Restructuring Committee. The Chairman of the Restructuring Committee is the
Chief Executive Officer (CEO), while the other members include: the Chief Risk Officer (CRO) and the
directors of the Impaired assets, the Intensive Loan Management; and a representative from the Legal
department.
The Operational Risk Committee is an advisory body to the MB, designed to help the adequate
management of operational risk by monitoring and analyzing operating events. The Committee
proposes measures to minimize operational risks, as well as prevention measures. During the year
there were no changes in the composition of the Operational Risk Committee The Chairman of the
Operational Risk Committee is the director of Risk Analysis and Control department and the other
members are the directors of the following departments: Card Payments; Compliance Regulations
and Standards; Accounting, Information Technology and Branch Network.
Apart from the collective management bodies, the risk function in First Investment Bank is executed
by the Risk Analysis and Control department, the Credit Risk Management, Monitoring and
Provisioning department and the specialized unit for Strategic Risk Management (Risk Management
Directorate), as well as the Compliance function by departments Compliance Regulations and
Standards and Compliance Anti-Money Laundering and Financing of Terrorism (Compliance
Directorate), which are independent (separate from the business of the Bank) structural units in the
organizational structure of the Bank.
The Risk Analysis and Control department performs functions for the identification, measurement and
management of the various types of risks inherent in the Bank’s activity. The department monitors the
determined levels of risk appetite and risk tolerance, is responsible for the implementation of new
requirements relating to risk assessment and capital adequacy, and assists other departments in
carrying out their functions related to risk management and control.
The Credit Risk Management, Monitoring and Provisioning department performs the functions of
management and monitoring of credit risk, and exercises secondary control over risk exposures
according to the current authority levels on loan transactions. The department manages the process
of categorization of credit exposures, including the assessment of potential losses.
The specialized unit for Strategic Risk Management aims at identifying and assessing the strategic risk,
including the main risks in the Bank’s strategic projects, as well as analyzing the realistics of the
assumptions embedded in the strategies of the Bank with respect to changes in the external
environment and the markets it operates in.
The Compliance Regulations and Standards department carries out the activities of identifying,
assessing and managing the risk of non-compliance, ensures adequate and legitimate internal
regulatory framework in the structure of the Bank, and monitors for compliance of the Bank's products
and services with existing regulations. It also manages and analyses the customer satisfaction in the
Bank in relation to customer complaints. As part of it a Compliance investment services and activities
unit functions, which executes ongoing control over the execution of the regulatory requirements with
respect to the Bank’s activity as an investment intermediary and on the market abuse with financial
instruments, as well as a Data protection officer, who has a leading role in ensuring the lawful
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processing of personal data in the Bank's structure for further information see section Personal Data
Protection.
The Compliance Anti-Money Laundering and Terorism Financing Department performs the Bank's
activities related to prevention of money laundering and terrorist financing as a specialized service
under Article 106 of the Measures Against Money Laundering Act (MAMLA). It also ensures regulatory
compliance of this activity according to the EBA Guidelines on policies and procedures in relation to
compliance management and the role and responsibilities of the AML/CFT Compliance Officer under
Article 8 and Chapter VI of Directive (EU) 2015/849 (EBA/GL/2022/05) and BNB Ordinance 10 on the
Organization, Management and Internal control in Banks, as well as exercises control over the
application of fraud prevention requirements.
SYSTEM OF LIMITS
First Investment Bank applies a system of internal limits for different types of risks, in line with the
regulatory requirements and the Bank's risk management strategy, including limits by
client/counterparty, type of instrument and portfolio, sector, market, etc. The limits applied are
monitored on a regular basis and are subject to periodic review and update in line with the risk
appetite, market conditions and current regulatory framework.
For more information on the internal limits for different types of risk, see the subsections on credit risk,
market risk, liquidity risk, operational risk, as well as the Individual Financial Statements for the year
ended 31 December 2023.
RECOVERY PLAN
In pursuance of the Law on Recovery and Resolution of Credit Institutions and Investment Firms, banks
in the country are required to prepare and maintain recovery plans in case of potential occurrence of
financial difficulties.
In 2023, First Investment Bank updated its Recovery Plan, including the recovery indicators, calibrating
their levels according to the regulatory requirements and the applicable capital buffers. The recovery
measures were updated applying a more conservative approach, and new measures were added
meeting the MREL requirement. Increased risk parameters were used in the assumptions when
preparing different stress scenarios, taking into account the challenges of the external environment
and the macroeconomic conditions.
The Recovery plan includes the detailed process of escalation and decision-making, as well as the units
and bodies within the Bank responsible for its updating and implementation. It includes quantitative
and qualitative early warning and recovery indicators, based on a wide range of capital & MREL,
liquidity, profitability, asset quality, market-based and macroeconomic indicators, upon the
occurrence of which a phased process is initiated, involving analysis and identification of the best way
to overcome the crisis situation, as well as taking decisions to trigger the appropriate actions according
to the procedures for reporting and escalation.
For the purposes of the plan, the key business lines and the critical functions of the Bank have been
identified that are necessary for its smooth operation. According to the applicable requirements and
in order to determine the range of hypothetical events, different stress scenarios of idiosyncratic,
systemic and combined shock have been defined, against which effective recovery measures have
been identified and the effect they might have on the financial and operating continuity.
In connection with the implementation of the plan, an effective process of communication and
disclosure has been structured in First Investment Bank, including internal communication (to internal
bank bodies and employees) and external communication (to supervisors, shareholders and investors,
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customers and counterparties, and other stakeholders), as well as measures for the management of
potential negative market reactions.
RESTRUCTURING PLANNING PROCESS
Pursuant to the Law on the Recovery and Resolution of Credit Institutions and Investment Firms, banks
in the country are obliged to assist the resolution authority with a view to operational preparedness
for carrying out potential restructuring of the institution should such a situation arise.
In this regard, in 2023 First Investment Bank finalised the development of an internal Bail-in Playbook
to document the operational process related to a potential bail-in event, including the operational
steps related to write-off mechanisms and conversion of instruments and liabilities, as well as the
internal and external aspects for applying and operationalizing the bail-in process.
CREDIT RISK
Credit risk is the risk arising from the debtor’s inability to meet the requirements of a contract with the
bank or inability to act in accordance with the agreed terms. The different types of credit risk include
concentration risk, residual risk, dilution risk, counterparty risk, and settlement risk. Credit risk is the
major source of risk to the banking business and its effective assessment and management are crucial
for the long-term success of credit institutions.
First Investment Bank manages credit risk by applying internal limits on exposures, on
customers/counterparties, types of instruments, industry sectors, markets, by written rules and
procedures, by internal rating and scoring models, as well as by procedural requirements in the
originating and managing of loan exposures (administration).
The internal bank regulations regarding credit risk are structured in accordance with the business
model and organization of the activity, as well as in compliance with the regulatory requirements and
recognized banking practices and standards, which include internal rules for lending and managing
problem exposures, rules for classification, impairment and the provisioning of exposures, approval
levels in the origination of loan exposures, as well as the methodology for conducting of credit analysis
and internal credit ratings (scoring models) regarding the creditworthiness of customers. Internal rules
and procedures are updated regularly with the aim of identifying, analyzing and minimizing potential
and existing risks. The applied limits on credit risk exposures are monitored on an ongoing basis and in
compliance with the market conditions and regulatory framework.
LOAN PROCESS
The credit process at First Investment Bank is automated through the Business Process Management
(BPM) system, developed on the IBM Business Automation Workflow platform. It is integrated in the
core information system of the Bank and includes control mechanisms and levels of authority in the
review and approval of credit transactions. Approved transactions are administered centrally, at the
Credit Administration Department, applying the "four eyes" principle.
The Bank has an integrated and advanced Business Process Management (BPM) system for processing
retail and business loans. The system covers the activities of accepting loan applications, preparing
opinions, approval and disbursement of new loans, as well as renegotiating existing ones. The
applicable limits and authority levels for approval/renegotiating of individual types of credit exposures
are integrated in the system. Automating the credit process aims to increase the quality of customer
service, as well as to reduce the time for processing credit applications.
In 2023, changes were made to the lending rules and to the levels of authority for approval of credit
transactions. The aim was to optimize the internal decision-making processes, bringing them in line
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with structural units and automated credit processing systems in the Bank, as well as to refine the
requirements for off-balance sheet commitments. During the year, changes were also made to the
internal rules for real estate lending to individuals in line with the Law on consumer real estate loans.
Those included updating the internal processes for working with credit intermediaries, as well as the
methodology for assessing the creditworthiness of individuals.
With respect to business units involved in lending, the activity is structured in accordance with the
customer segmentation applied by the Bank. It corresponds to the European requirements for defining
micro, small and medium-sized enterprises, which were transposed by the Law on Small and Medium-
sized Enterprises.
Credit product are priced so that income generated by them covers the cost of funds, the assumed
risk/expected loss, the administrative costs, as well as the return on equity allocated to the respective
product, incl. the minimum requirement for own funds and eligible liabilities (MREL).
First Investment Bank maintains systems for the ongoing administering and monitoring of different
portfolios and exposures to credit risk, including aiming at recognizing and managing exposures in
default and performing adequate value adjustments for credit risk. Considering the impact of the
economic cycle, Fibank manages exposures in default with a view to their timely diagnosis and taking
measures consistent with the repayment capacity of the clients and the Bank’s policy on risk-taking.
The monitoring system of the Bank as well as the internal procedures for monitoring of credit
exposures are subject to regular review and update, as well as the procedures for review of individually
significant loan exposures, incl. early warning signals and indicators for probabiitiy of delay/overdue
and indicating the probability of non-payment.
In the Bank a department functions for Intensive loan management, which manages the exposures of
customers transferred from the business units with increased credit risk compared to the initial
disbursement of the loan, as well as from the impaired assets unit, when there are indicators for
recovery of the exposure and objective possibility for future regular servicing. The processes are
organized in accordance with the Rules for transfer of credit exposues and the different phases of the
life-cycle of the loan, which were specified during the period aiming to optimize the processes for retail
and business clients.
ANALYSIS AND APPROVAL
RESTRUCTURING AND
RECOVERY
MONITORING AND
MANAGEMENT
LOAN QUALITY
Regulator
monitoring
Restructuring and
recovery
Business and loan analysis
Approval according to
competence levels
Signing contract and
utilization
Increased
risk
Client in default
Increased
risk
Intensive
care
Recovery of
receivables
LOAN-LIFE CYCLE
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MODELS FOR CREDIT RISK MEASUREMENT
First Investment Bank applies internal credit risk models to assess the probability of default (PD), loss
given default (LGD), and exposure at default (EAD) which allows the calculation of risk-adjusted
returns. All credit risk exposures are controlled on an ongoing basis.
The framework, defined in accordance with the Basel standards, sets minimum regulatory capital
requirements to cover financial risks. In addition to regulatory capital, First Investment Bank also
calculates economic capital which is included in the internal measurement and management of risk.
Economic capital is maintained for the purpose of protection and covering of unexpected losses arising
from market conditions or events.
For further information regarding economic capital see subsection Internal Capital Adequacy
Analysis“.
The Bank uses internal models for credit assessment of business and retail customers. Assessment
models are based on quantitative and qualitative parameters, weights of individual parameters being
defined on the basis of historical experience. Business clients are assigned a credit rating, while
individuals are based on scoring. An additional assessment for business clients is made based on a
behavioral scoring model. The credit risk assessment derived from the rating models is further
examined by a credit specialist/risk manager.
The Bank has project finance evaluation models (including for real estate, industrial projects and
financing of individual fixed assets), applying quantitative analysis (based on estimated cash flows) and
qualitative evaluation of the project and investor management, market environment and credit
structuring, as well as a separate evaluation of the assets being funded.
All risk assessment models are adopted by the Managing Board, proposed for their review after prior
approval from the Chief Risk Officer.
There is a structured process within the Bank for assessment and validation of the risk management
models to ensure their reliability, accuracy and effective implementation. It envisages the preparation
of regular validation reports in the Bank: brief/monitoring quarterly reports and extended annual
validation reports, covering both quantitative analysis (statistical, econometric and other quantitative
approaches) and analysis of the qualitative (non-statistical) characteristics, in compliance with the
current regulatory requirements and good banking practices in the area, aiming at timely reporting of
the results to the competent bodies within the Bank.
Exposures
at default
(EAD)
Probability
of default
(PD)
Loss given
default
(LGD)
Maturity
Correlation
factor
EXPECTED LOSS (%)
EXPECTED LOSS (AMOUNT)
PARAMETERS FOR ASSESSING ECONOMIC CAPITAL
RISK PARAMETERS FOR ASSESSING EXPECTED AND
UNEXPECTED LOSSES
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CREDIT RISK MITIGATION METHODS
Credit risk is managed also by acceptance of guarantees and collateral of types and in amounts
according to the current regulations and the Bank’s internal rules and requirements. First Investment
Bank requires collateral for credit risk exposures, including for contingent liabilities which bear credit
risk. For reduction of the credit risk the Bank applies established techniques, procedures and rules,
ensuring effective credit protection, including through the monitoring and control of residual risk.
Secured protection is ensured by assets which are liquid enough and have relatively unchanging value
in time. The Bank applies internal written rules regulating eligible collaterals by type and amount, in
compliance with the regulatory requirements for their recognition, as well as the legal requirements
for supporting documentation. For reduction of credit risk, First Investment Bank applies the financial
collateral simple method under the requirements of Regulation (EU) No 575/2013.
First Investment Bank currently monitors the relative regulations, as well as the acknowledged
standards and good practices in this area, aiming constantly at further development and enhancement
of the rules and processes existing in the Bank with respect to the acceptance, evaluation and
management of collaterals, including with regards to the methods for evaluation. In the processes of
managing collaterals requirements for appraisers rotation are applied after certain number of
successive valuations of the same asset, in accordance with Guidelines on loan origination and
monitoring (EBA/GL/2020/06). In 2023, the rules for the acceptance, assessment and management of
collateral were updated with regard to assessment approaches and standards applied, as well to the
collateral monitoring process.
PROBLEM EXPOSURES, REPOSSESSED ASSETS AND STRATEGY FOR THEIR
REDUCTION
First Investment Bank has internal rules and written procedures for managing problem credit
exposures, which include all main actions related to the management of problem loans, including
analysis and assessment of risk exposures, restructuring and recovering, enforced collection, sale and
writing off of problem exposures. Fibank uses a specialized system for the integrated management of
problem assets, which includes all stages for monitoring and recovery of receivables.
The Bank has structured processes and internal organization regarding the management and sale of
repossessed assets, as well as for debt-to-asset/debt-to-equity conversion. There is an Asset
Management and Sale Committee acting as an auxiliary body to the Management Board. It performs
functions related to the management, administration and sale of acquired assets in accordance with
the levels of authority operating in the Bank.
Among the strategic priorities of the Bank regarding its risk profile is reducing the portfolio of
nonperforming exposures and repossessed assets, as in this regard a Strategy for reduction of
nonperforming exposures and repossessed assets for 3-year period is in place, as well as an operating
plan for its implementation, in which measures adequate to the business model and risk profile were
identified aligned with the EBA Guidelines on management of nonperforming and forborn exposures
(EBA/GL/2018/06). In 2023, the Bank’s strategy was updated as part of the annual planning and
budgeting process, including target levels for key indicators. The set in it main goals and priorities,
included:
Regular write-off of fully impaired and uncollectible credit exposures and sale of portfolios of
non-performing exposures, in such volume and time horizon as the market dynamics allow
and the prices offered;
Achieving stable recovery, covering the entire life cycle of credit exposures and perfecting the
practices and processes in order to achieve higher recovery rates;
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Improving the ways and methods for restructuring, aimed at increasing collections from non-
performing exposures;
Reduction of the risk profile of the loan portfolio and applying a conservative approach in
collateral valuation;
Reduction of the relative weight of the portfolio of foreclosed assets in the Bank's balance
sheet in order to free up cash resources and reduce risk.
During the year, as a result of the consistent actions and measures for improving collection, write-offs
and reduction of problem exposures, non-performing exposures decreased net by 18.9% or by BGN
229,936 thousand y/o/y. As at 31 December 2023, the nonperforming loan (NPL) ratio calculated in
accordance with the requirements of the European Banking Authority decreased by 3.9 percentage
points to 10.1% of gross loans and advances under the FinREP financial reporting framework (2022:
14.0%), and the nonperforming exposure (NPE) ratio decreased by 2.8 percentage points to 8.0% of
gross loans and advances and debt instruments other than held for trading (2022: 10.8%).
CLASSIFICATION, IMPAIRMENT AND PROVISIONING OF EXPOSURES
First Investment Bank applies a consistent exposure classification process, structured in accordance
with the requirements of Regulation (EU) No. 575/2013 and its implementing regulations, Ordinance
No. 7 of the BNB on the organization and management of risks in banks, as well as the EBA Guidelines
on the application of the definition of default under Article 178 of Regulation (EU) No 575/2013
(EBA/GL/2016/07), the EBA Guidelines on PD estimation, LGD estimation and treatment of defaulted
assets (EBA/GL/2017/16) and the EBA Guidelines on credit risk management practices and accounting
for expected credit losses (EBA/GL/2017/06). Internal processes cover the definition of default,
including indications of default and unlikeliness to pay, materiality thresholds for past due credit
obligations, implementation of forbearance measures and reclassification, as well as units and internal
banking bodies responsible for the process, taking into account the BNB Instructions on the treatment
of regulated real estate and on the scope of insurance coverage for the purposes of applying and
determining the risk weights.
With respect to impairment and provisioning of risk exposures, the Bank applies written rules, which
are structured based on the principles of individual and portfolio evaluation of risk exposures,
depending on the classification and amount of exposure. For exposures reported as non-performing
specific impairment is determined, calculated on the basis of individual cash flows for individually
significant exposures, or on portfolio basis for the others. Regarding exposures reported as performing,
32
CONFIDENTIAL
GENERAL TARGETS
QUANTITATIVE TARGETS
STRATEGIC TARGETS
Improving the processes for management of risk and
of non-performing exposures, including portfolio
segmentation
Recovery and restructuring measures
Collection through contact center campaigns
Collection through direct (on-site) contact with
borrowers
1
2
3
Measures involving litigation
Sale and write- off of non-performing exposures
4
5
6
MEASURES/OPTIONS REDUCE NON-PERFORMING EXPOSURE
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the Bank applies impairment on a portfolio basis (taking into account potential losses), grouping
exposures with similar credit risk characteristics. According to IFRS9 an allowance for impairment loss
is calculated equal to the expected credit losses over the life of the instrument, if the credit risk of the
financial instrument has increased significantly since the original recognition. Otherwise, an allowance
for impairment losses is calculated equal to the expected credit losses over a 12-month horizon.
The Bank has written parameters for defining the increased credit risk, which includes days past due,
as well as other indicators i.e. presence of forborne measures, deterioration in the rating/scoring of
the client and others, as well as defining the parameters for meeting the cash flow test for solely
payments of principal and interest (SPPI test), including defining new or changed credit products.
At the beginning of 2023, the Bank finalized the review of its internal rules for classification,
provisioning and impairment, aiming to further enhance of internal processes.
For more information on credit risk, see note 3 “Risk Management” from the Individual Financial
Statements for the year ended 31 December 2023.
MARKET RISK
Market risk is the risk of losses due to changes in the price of financial instruments resulting from
general risk factors inherent in the markets and not related to the specific characteristics of individual
instruments, such as changes in interest rates, exchange rates and/or specific risk factors relating to
the issuer.
The management of market risk is based on applying internal limits and written rules and procedures
with respect to the processes and control environment. For the purpose of assessing and minimizing
market risk the Bank applies internal models for assessment, which are based on the “Value at Risk”
(VaR) concept, and in addition other duration analyses, calculation of stressed VaR, stress tests and
scenarios are used.
The limits applied by the Bank for debt and capital instruments are structured with the aim of
minimizing the risk and applying a wide and risk-based framework of limits, which are directly
connected with the risk profile of the investments, as well as with the dynamics of the risk profile in
time. The Bank applies a uniform framework regarding its limits on investments in debt securities to
governments and financial institutions in accordance with the development of market conditions and
Impairment for
expected credit
losses over the
entire life of the
exposure
Impairment for
already incurred
credit losses over
the entire life of
the exposure
Impairment for
expected credit
losses over a
12-month horizon
1 2 3
Increased
credit risk
Presence of an event
leading to loss
IMPAIRMENT OF RISK EXPOSURES
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opportunities to generate returns and returns. In 2023, the rules for managing market risks were
updated, mainly with respect to overview of the positions and assessment of the inherent risks, incl.
towards ecological, social and governance (ESG) risk factors.
POSITION RISK
Position risk is the risk of changes in the prices of debt and equity instruments as a result of
circumstances related to the issuer and / or changes in market conditions. Position risk includes general
and specific position / price risk.
It is the policy of the Bank to maintain an insignificant trading portfolio in accordance with the criteria
of Regulation (EU) № 575/2013. Therefore, it does not calculate capital requirements for interest rate
and pricing risk in this portfolio.
For quantifying measurement of the interest rate and position risk in the trading portfolio, the Bank
applies VaR analysis with a 1-day horizon and 99% confidence level, which means that there is 1%
probability for the trading portfolio to depreciate within a 1-day interval more than its calculated VaR.
The model is calculated and monitored on a daily basis by estimating the maximum loss that could
occur over a specified horizon under normal market conditions, due to the adverse changes in the
market rates, if the positions remained unchanged for the specified time interval.
In compliance with the European Banking Authority guidelines, the Bank measures stressed value at
risk (sVaR) of the debt securities portfolio, where model inputs are calibrated so as to reflect an
extended period of significant stress in the international financial markets.
INTEREST RATE RISK IN THE BANKING BOOK
Interest rate risk in the banking book os the risk from negative effect on the economic value of the
capital and the net interest income of the Bank due to change in the market interest rate levels.
First Investment Bank manages this type of risk through written rules, limits and procedures aimed at
reducing the interest sensitivity gap of assets and liabilities in accordance with the requirements of the
EBA Guidelines issued on the basis of Article 84 (6) of Directive 2013/36/EU specifying criteria for the
identification, evaluation, management and mitigation of the risks arising from potential changes in
interest rates and of the assessment and monitoring of credit spread risk, of institutions’ non-trading
book activities (EBA/GL/2022/ 14) and the requirements of Ordinance No. 7 of the BNB on the
Organization and Risk Management of Banks.
INTEREST RATE VAR FOR THE TRADING BOOK
OF DEBT INSTRUMENTS
INTEREST RATE VAR FOR THE TRADING BOOK
OF DEBT INSTRUMENTS DURING 2023
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Interest rate risk in the banking book is measured using models that assess the impact of interest rate
scenarios on the economic value of the Bank and on net interest income. The interest rate risk
assessment framework in the banking book (IRRBB) takes into account various sources of the IRRBB,
incl. the risk of mismatch, underlying and option risk, and the risk of change in the credit spreads of
financial instruments (CSRBB). The set of stress scenarios applied by the Bank includes those related
to non-parallel changes in the interest rate curve, as well as taking into account a number of behavioral
features in cash flows, in the context of different stress scenarios.
As at 31 December 2023 the interest rate risk on the economic value of the Bank (IRRBB) following a
standardized shock of +100/-100 bp was BGN +35.7/-14.8 million, while on the net interest income
one year forward was BGN +19.6/-20.0 million
CURRENCY RISK
Currency risk is the risk of loss resulting from an adverse change in exchange rates. Fibank’s exposure
to currency risk arising from positions in the banking and trading book is limited by the application of
regulatory-required and internal limits.
The Bank actively manages the amount of its overall open foreign exchange exposure, and seeks to
maintain negligible levels of currency mismatches in its entire activity. In addition, First Investment
Bank calculates and applies limits, based on an internal VaR model, regarding the maximum loss that
could be incurred within 1 day at a confidence level of 99.0%.
The Bank is also exposed to currency risk as a result of proprietary trading transactions. The volume of
such transactions is very limited and controlled through limits on open foreign currency positions, and
stop-loss limits on open positions.
COUNTERPARTY RISK AND SETTLEMENT RISK
Counterparty risk (counterparty credit risk) is the risk that a counterparty in a particular transaction
will default before the final settlement of the cash flows of the transaction. It arises mainly from
transactions in derivative instruments, repo transactions, securities and commodities
lending/borrowing transactions, margin lending transactions and extended settlement transactions.
The Bank manages and controls this type of risk by applying limits and minimum credit quality
requirements to counterparties /issuers.
EFFECT ON THE INTEREST INCOME EFFECT ON THE EQUITY
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Settlement risk for the Bank is the risk of outstanding transactions in securities, commodities or
currency. It arises both in transactions with settlement services on the principle of "delivery versus
payment" (delivery versus payment - DvP) and in trade without DvP ("free deliveries"). For DvP
transactions, the Bank assesses the risk that the price difference between the agreed settlement price
for the respective instrument and its current market value will lead to a loss for the Bank. For those
related to "free deliveries", the risk is controlled by applying internal credit quality limits to
counterparties / issuers.
For further information regarding market risk see note 3 “Risk management” of the Individual Financial
Statements as at 31 December 2023.
LIQUIDITY RISK
Liquidity risk originates from the funding of the banking business and in positions management. It
includes the risk of failure to meet a payment when due, or failure to sell certain assets at a fair price
and in the short term to meet an obligation.
First Investment Bank manages liquidity risk through an internal system for monitoring and daily
liquidity management, maintenance of a sufficient amount of cash consistent with the currency
structure of assets and liabilities and maturity ladder, regular gap analysis of inflows and outflows,
maintaining a low risk portfolio of assets to meet current liabilities, and operations on the interbank
market.
In order to maintain a medium-low risk profile, Fibank has established an adequate framework for
liquidity risk management. The Bank's policy on liquidity management is designed so as to ensure
meeting all obligations even under stress originating from the external environment or from the
specifics of banking activity, as well as to maintain an adequate level and structure of liquid buffers
and apply appropriate mechanisms for the distribution of costs, profits and risks related to liquidity.
The Bank applies a combination of methods, financial models and instruments for assessment and
management of liquidity, including the requirements for reporting and monitoring of the liquidity
coverage ratio (LCR) and net stable funding ratio (NSFR) in compliance with Regulation (EU) No
575/2013 and the applicable delegated regulations of the European Commission. In order to reduce
the liquidity risk, preventive measures have been taken aimed to extend the maturity of borrowings
from customers, to encourage long-term relationships with clients and to increase customer
satisfaction. In order to adequately manage liquidity risk, the Bank monitors cash flows on a daily basis,
and also maintains a maturity ladder, which is part of the additional liquidity monitoring indicators and
a tool for detailed monitoring of cash inflows and outflows by maturity interval.
During the year, in implementation of the changes in Ordinance No. 21 of the BNB, actions were taken
to reflect the increased mandatory minimum reserves that banks maintain at the Bulgarian National
Bank at the systemic, operational and reporting levels. The internal processes for managing asset
encumbrance risks were also updated.
As regards asset/liability and liquidity management policies, First Investment Bank applies the business
model requirements and the criteria for classification and valuation of financial assets in the Bank's
portfolios in accordance with IFRS 9. Based on the purpose for managing the financial assets, the
business models applied by the Bank include: 1) a business model whose purpose is the assets to be
held to collect contractual cash flows (hold to collect); 2) a business model whose purpose is both to
collect contractual cash flows as well as sale of financial assets (hold to collect and sell); 3) another
business model when the purpose is different from the previous two business models, and which
includes assets held for trading.
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During the reporting year Fibank maintained an adequate volume of liquid assets, as at 31 December
2023 the ratio of liquid assets covering the attracted funds due to other customers amounted to
39.22% (2022: 36.75%), which was significantly above the BNB recommended level of 20%. According
to the regulatory requirements the Bank should maintain a buffer of liquid assets to ensure liquidity
coverage of net liquidity outflows over a 30-calendar day stress period with a minimum amount of
100%. At the end of the reporting period, the liquidity coverage ratio (LCR) amounted to 278.55% on
an individual basis (2022: 225.36%).
First Investment Bank also calculates a net stable funding ratio (NSFR), which is an instrument
introduced to ensure that long-term liabilities are adequately covered by stable financing tools both
under normal circumstances and in stress conditions. At year-end, the net stable funding ratio
amounted to 150.48% on an individual basis (2022: 145.47%) and was above the reference value of
100% in accordance with Regulation (EU) No 575/2013.
INTERNAL LIQUIDITY ADEQUACY ASSESSMENT PROCESS
First Investment Bank prepares a regular report on the internal liquidity adequacy assessment process
(ILAAP), aimed at performing a comprehensive internal assessment of the liquidity management and
funding framework of the Bank in the context of its strategy and risk appetite in terms of liquidity.
In 2023, as part of its annual review process, the ILAAP report was updated, including with regards to
the results of stress scenarios and stress tests used, the quantitative information on funding plans and
sources of funding, as well as the capacity for generating liquidity and the survival periods. Internal
liquidity indicators were structured in compliance with the requirements for consistency with Recovery
Plan levels, the latter being part of the monitoring and early warning system incorporated in the Bank’s
risk management framework. The information was expanded regarding the maintained liquidity
buffers and the so-called management buffer, as well as the required documentation package
including the governing body's opinion on adequacy of liquidity positions and management of liquidity
risks. The ILAAP methodology was refined taking into account the deposit outflow assumptions under
different types of stress scenarios. It describes the approaches to preparing and updating the ILAAP
report, including with regard to the key components under the EBA Guidelines on ICAAP and ILAAP
information collected for SREP purposes.
With respect to the internal processes and organization on ILAAP the CFO has general responsibility
for controlling the process for updating, for making proposals for amendments on the document, as
well as ensuring control before presenting for approval from the competent bodies within the Bank.
LIQUID ASSETS LCR AND NSFR
21%
NSFR & LCR
Minimum
requirements
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The assessment takes into consideration the systems and processes existing in the Bank for
management of risks related to liquidity and funding, including information on the daily management
of liquidity risk and on the allocation of costs and benefits related to liquidity, which are determined
based on a methodology for internal transfer prices (ITP) introduced in the Bank. The ILAAP also takes
into account the funding strategy of the Bank, including the funding plans within a three-year horizon,
as well as the strategy on maintaining liquidity buffers and monitoring of encumbered assets. The
quantitative measurements of the readiness of the Bank to deal with a sudden and significant outflow
of borrowings (liquidity crisis) are established through stress tests and scenario analyses. For the
purposes of ILAAP, First Investment Bank applies a combination of three stress scenarios: of
idiosyncratic, market and combined shock, with a horizon of one week and one month, which take into
account the stability of the deposit base and the sensitivity of the customers.
To ensure adequate capacity of the Bank to meet all its obligations and commitments, even in the
context of a liquidity crisis, First Investment Bank has developed an action plan in case of contingency
with respect to liquidity which is an integral part of the overall system for liquidity management. In
2023, the plan was updated, including with regard to shock scenarios applied, as well as to ensuring
consistency with the liquidity indicators laid down in the Recovery Plan.
For further information regarding liquidity risk see note 3 “Risk management” of the Individual
Financial Statements as at 31 December 2023.
OPERATIONAL RISK
Operational risk is the risk of loss resulting from inadequate or failed processes, people or systems, or
from external events. In order to mitigate the risks arising from operational events, First Investment
Bank applies written policies, rules and procedures that are based on the requirements laid down in
Bulgarian and EU legislation and good banking practices. In 2023 the rules were enhanced with respect
to the procedures for incident reporting. With respect to capital requirements for operational risk, the
Bank applies the standardized approach as per requirements of Regulation (EU) 575/2013, incl.
methodology for allocation of the indicators as per group activities.
First Investment Bank maintains a system for registration, tracking and control of operational incidents
and near-misses that complies with the effective regulatory requirements. Operational risk
management at Fibank is based on the principles of not assuming unsound risk, strict compliance with
the authority levels and applicable laws, and active management of operational risk. The Bank applies
reliable methods for avoiding, transferring, and limiting the impact of operational risks, including
through separation of functions and responsibilities, double control, approval levels, internal control,
insurance contracts, and information security.
With the aim of developing and enhancing its processes for operational risk management key risk
indicators are defined within the Bank, which are applied both at Bank level, and specifically for each
business unit and process in the Bank. They are used for the purpose of effective signaling of changes
that may be relevant to the active management of operational risk, as well as for implementing better
monitoring and control of the risk tolerance and of the thresholds and limits on individual types of risk.
The Risk Analysis and Control department defines and categorizes operational events across event
types and business lines inherent in banking, as well as the obligations and responsibilities of the Bank's
employees in connection with their registration and reporting. The Operational Risk Committee
regularly reviews and analyzes operating events and suggests to the Managing Board measures for
prompt correction of their causes, as well as for strengthening the controls in the management of
processes, activities, products and services at all levels of the Bank's system.
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In order to assess the exposure and reduce operational risk, as well as to enhance and improve the
control procedures, First Investment Bank conducts regular Risk Control Self-Assessment (RCSA) in the
form of questionnaires and analyzing of processes. According to good banking practices the self-
assessment is an important tool for additional evaluation of the Bank’s exposure to operational risk,
as well as a tool contributing to the analysis of the effectiveness of existing controls for its mitigation.
INFORMATION SECURITY
Information security and cyber security play an increasingly important role in banking, given the
growing digitization of services and automation of processes. It is as integral part of the Bank's
priorities aiming at protection of ICT assets ensuring continuity of service and key banking processes.
The Bank's information security policy sets out principles and rules for protecting the confidentiality,
integrity and availability of data and information of Fibank and its customers, and of related services.
The Bank applies internal rules covering the organizational and managerial framework and employee
responsibilities for ensuring the security of data, systems and relevant infrastructure. Measures have
been put in place to guarantee proper logical and physical security, information asset management,
access control and risk management.
An “Information security” department functions within the Bank under the supervision of the Chief
Risk Officer, which coordinates the activities related to information security, defines the requirements
towards controls and security of data, as well as organizes the execution of the Management Board’s
decisions in this respect.
PERSONAL DATA PROTECTION
As part of its internal organization as a data controller, the Bank further structured and developed the
principles and grounds for processing personal data, including with regard to their transparency,
legitimacy, rights of data subjects, as well as technical and organizational measures to protect such
data.
In compliance with the requirements of the General Data Protection Regulation (GDPR), the Bank has
a Data Protection Officer (DPO) e-mail: dpo@fibank.bg. The DPO has a leading role in ensuring the
lawful processing of personal data in the Bank's structure, conducts awareness-raising training and
contributes to building a data protection culture. The DPO is a contact person with the Commission for
the Protection of Personal Data and on issues related to the exercise of the rights of the data subjects.
The Data Protection Officer coordinates and organizes balancing tests and impact assessments, as well
as regular monitoring of data processing registers under the GDPR.
As a personal data administrator, First Investment Bank provides privacy notices to customers.
Information regarding the processing of personal data is provided depending on the services used (e.g.
payment services, bank cards, loans, investment services and activities, etc.). Where necessary, the
Bank enters into agreements with counterparties involving exchange of personal data in compliance
with current regulations and GDPR requirements.
In order to secure and protect personal data, the Bank carries out daily monitoring of personal data
exchanged with external recipients through a specialized Data Loss Prevention (DLP) system which it
constantly develops and improves.
BUSINESS CONTINUITY MANAGEMENT
In order to ensure the effective management of business continuity, First Investment Bank maintains
contingency and business continuity plans, as well as plans for the recovery of all its critical functions
and resources, which are regularly tested. Business continuity management ensures sustainability at
all organizational levels within the Bank, as well as the opportunity for effective actions and reactions
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in crisis situations. The organization of processes ensured within the Bank aims at protecting the
interests of all stakeholders, its reputation, brand and the value-adding activities.
Building an appropriate corporate culture with regard to business continuity management is an
important part of the overall risk culture of the Bank. To further integrate information and apply a
centralized approach, the internal rules on business continuity were structured into a single document
with main content and separate action plans for specific incidents and crisis situations. The
organization thus established aims to ensure rapid and effective action for addressing potential crisis
situations, as well as the timely elimination of any negative consequences.
In 2023, as part of the annual review, an update of the Business Continuity Plan was carried out,
including in connection with the methodology for impact assessment in process disruption or loss of
resources in line with the set priorities and maximum admissible time for recovery, as well as with
regards to the procedures for indicent reporting.
OUTSOURCING
First Investment Bank has an Outsourcing Policy in place consistent with the requirements for
outsourcing activities as defined by the Law on Credit Institutions and the EBA Guidelines on
outsourcing arrangements (EBA/GL/2019/02). It regulates the main phases of outsourcing, including
definition of business requirements for outsourcing arrangements; identification of critical and
important functions; identification, assessment and management of outsourcing risks; selection and
due diligence procedures for external providers; monitoring and management of outsourcing
agreements; keeping of documentation and registers; as well as business continuity planning.
The Bank maintains centralized and systematized information on outsourcing arrangements, and
conducts regular reporting to competent internal Bank bodies on risks associated with outsourcing.
RISK EXPOSURES
As at 31 December 2023 First Investment Bank applied the standardized approach for the calculation
of risk exposures for credit risk, in accordance with Regulation (EU) No 575/2013. Due to the limited
volume of financial instruments in the trading book (bonds and other securities) capital requirements
are calculated in accordance with the requirements of Regulation (EU) No 575/2013 as applied to the
banking portfolio. With respect to capital requirements for operational risk, the Bank applies the
standardized approach as per requirements of Regulation (EU) 575/2013, incl. methodology for
allocation of the indicators as per group activities.
In BGN thousand/ % of total
2023
%
2022
%
2021
%
For credit risk
6,702,613
92.0
6,462,477
92.2
6,546,743
92.5
For market risk
4,413
0.1
4,350
0.1
4,713
0.1
For operational risk
582,100
8.0
540,238
7.7
523,913
7.4
Total risk exposures
7,289,126
100
7,007,065
100
7,075,369
100
In 2023 the structure of risk-weighted assets comprised predominantly of those to credit risk at 92.0%
of total exposures (2022: 92.2%), following by those for operational risk at 8.0% (2022: 7.7%) and to
market risk at 0.1% (2022: 0.1%) The Bank continued to maintain a conservative approach in the risk
assessment and risk management.
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Apart from Supervisory purposes, Fibank also calculates the economic capital that will ensure its
solvency and business continuity in adverse market conditions. For that purpose, an internal capital
adequacy analysis (ICAAP) is carried out.
INTERNAL CAPITAL ADEQUACY ANALYSIS
First Investment Bank AD performs regular internal capital adequacy analysis (ICAAP) in the context of
its business strategy, risk profile and risk appetite. The assessment of the required economic capital of
the Bank reflects the risk profile of its activity, as well as its risk appetite, as the main indicators of the
quantitative evaluation methods used take into account unfavorable external environment scenarios.
In 2022, the ICAAP report was updated in accordance with Fibank’s Risk Strategy and business
development goals, as well as in line with the operational environment and external conditions. The
quantitative information and the integrated stress test results assessing the Bank's resilience under
the baseline macroeconomic scenario and the adverse scenario (negative shock) were updated. The
information was expanded regarding the maintained capital buffers and the so-called management
buffer, as well as the required documentation package including the governing body's opinion on
adequacy of capital positions and capital planning. The ICAAP methodology was refined taking into
account integrated stress test assumptions, as well as scenario changes regarding liquidity risk and
interest rate risk in the banking portfolio.
When preparing the ICAAP report, a business model assessment is made, as well as internal control
framework, incl. independent risk, compliance and internal audit functions are taken into
consideration. The internal system for assessing the required internal capital is based on VaR
forecasting models for credit and market risk, stress tests for credit, market, liquidity, reputational,
and interest rate risk in the banking book, using the standardised approach and stress tests regarding
operational risk, the Earnings-at-Risk approach for strategic risk, and on analytical tools and techniques
that allow more detailed assessment of capital adequacy in accordance with the risk profile of the Bank
and the current operating environment. For aggregating the various types of risks the Bank uses a
correlation matrix, which takes into account the connection between the separate risk categories,
aiming at a more realistic and more enhanced approach for measuring the risk the Bank is exposed to,
at the same time as sufficiently conservative estimates.
For calculation of capital adequacy regarding the exposure to credit risk, First Investment Bank
uses internal valuation models, except in particular cases, e.g. in exposure classes with
negligible impact on the risk profile. For exposure classes of substantial importance, which constitute
the main credit activity of Fibank, economic capital is determined based on a single-factor portfolio
credit-VaR model which determines the probable distribution of losses that may be incurred within a
one-year horizon, at confidence interval corresponding to the risk appetite of the Bank. To quantify
the risk of occurrence of extraordinary, unlikely but possible events, stress scenarios are applied. The
stress scenario results are compared with the capital requirements for credit risk, calculated according
to the portfolio VaR model.
As part of the overall assessment of the exposure to credit risk, for the purposes of ICAAP, First
Investment Bank assesses the concentration risk which is due to the uneven distribution of credit
exposures by client, or by a group of related persons, as well as by economic sectors, from the
perspective of its financial stability and ability to carry out its core business. For the quantitative
evaluation of the needed economic capital for this risk, the Bank matches the results of the portfolio
VaR model between the real and a hypothetical portfolio, in which the amount of exposures is one and
the same at all customers at equally all other conditions. For calculating the concentration risk as per
economic sectors, a Herfindahl-Hirschman Index (HHI) is used.
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The Bank’s exposure to market risk is limited and involves the assessment of capital adequacy
in relation to position risk, foreign exchange risk, and commodity risk. For calculation of the
economic capital for market risk, internal value-at-risk (VaR) models are used, with a time
horizon of 1 year and a confidence level corresponding to the risk appetite of the Bank, as well as stress
tests for position risk of the equity portfolio.
For the purposes of the internal analysis of capital adequacy, Fibank manages the interest rate risk in
its banking book (IRRBB) by managing the structure of investments, controlling the costs and terms of
financial liabilities, as well as controlling the interest rate structure of the loan portfolio and the other
interest-bearing assets. Two aspects are being measured for the interest rate in the banking book
the effect of interest rates on the net interest income at a one-year horizon, and the effect on the
economic value of the Bank. For calculating the sufficiency of the economic capital with respect to
interest rate risk in the banking book the largest decrease in the economic value of the Bank or the net
interest income is defined resulting in a shift of the yield curves in the following scenarios: Parallel
shock parallel increase/decrease of interest rate levels; Short rates shock increase/decrease in the
interest rate levels in the short part of the curve; Steepener the short part of the yield curve registers
decrease, while the long part increase; Flattener the short part of the yield curve registers increase,
while the long part decrease. In addition to the non-risk interest rate component, reported are also
the stress scenarios for change in the credit spread (CSRBB).
For the purposes of ICAAP, First Investment Bank calculates the required economic capital for
operational risk on the basis of the results from the applied stress tests and the annual self-
assessment exercise on risk and controls, which units in the Bank go through, and on
identifying potential scenarios for rare but plausible operational events. The used by the Bank stress
tests are for extraordinary but probable events, including different scenarios based on their financial
impact and probability of occurrence. The economic capital for operational risk, incl. legal risk, is
calculated as the overall financial effect in a one-year horizon based on all analyzed stress scenarios.
To assess liquidity risk, the Bank differentiates the analysis in two directions regarding the risk
of insolvency and the risk of providing liquidity. The risk of insolvency is managed and covered
by maintaining an appropriate buffer of unencumbered, highly liquid assets, while the risk of providing
liquidity is covered and mitigated by economic capital. The Bank calculates economic capital for
liquidity risk by assessing the amount of loss that would be incurred as a result of a liquidity crisis,
(idiosyncratic, market and combined shock), taking into account the cost of repo transactions or
liquidating assets to meet the cash outflow, as well as the expected increase in interest expense on
borrowings.
For the purpose of ICAAP, the Bank assesses and other risks, including strategic risk and reputational
risk. For the quantification of strategic risk, the Earnings-at-Risk approach is used, measuring the
historical deviations between the budgeted and generated net profit of the Bank. The capital for
strategic risk is determined by applying a percentage of deviation corresponding to the accepted
confidence level to the budgeted net profit for the next year.
The reputational risk reflects the risk that the Bank's reputation may differ negatively from the
expected standard in terms of its expertise, integrity and reliability. Reputational risk may materialize
mainly in loss of business, increased cost of funding, or liquidity crisis the effects of which are measured
in the assessment of strategic risk and liquidity risk.
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DISTRIBUTION CHANNELS
First Investment Bank maintains diversification of the channels for distribution of the products and
services offered, including a well-developed branch network, wide network of ATM and POS terminals,
e-banking, mobile banking, direct sales, contact center, corporate website and a corporate blog. All
channels are constantly improved in line with the current trends in banking, market conditions,
technological development and customer needs.
BRANCH NETWORK
First Investment Bank strives to maintain an adequate balance between a well-developed network of
physical locations and the provision of modern remote banking techniques, including in the context of
the digital transformation in the banking sector.
In 2023 the Bank continued to optimize its branch network, taking into account the external
environment and market conditions, the workload of individual locations and the volumes of activity,
as well as the processes related to activity digitalization. During the year, five offices in the city of Sofia
were closed and one new office was opened Sofia Tech Park. As at 31 December 2023 the branch
network of First Investment Bank comprised a total of 120 branches and offices on an individual basis
(2022: 126), located in over 60 cities in Bulgaria: 38 locations in the city of Sofia (2022: 42), 81 branches
and offices in the rest of the country (2022: 83), and one foreign branch in Nicosia, Cyprus.
The branch network both in Sofia and in other places in the country is structured according to a unified
organizational model with a view to efficient allocation of budgetary targets, focusing on attracting
new customers and cross-selling. There are 27 branches in the country, while in the capital 5 functional
branches have been established: Central, East, West, North and South, to each of which offices are
allocated based on territorial location and business indicators.
As part of the branch digitization project, aimed at introducing a new model of customer servicing,
developing digitalization in everyday operations, an electronic signing of documents via e-Sign pad in
the branch network is provided for. When registering for the service, a sample of the customer's
signature (electronic specimen) is taken and used for comparison in subsequent signing. The use of e-
signing in basic banking transactions speeds up payment processing, improves customer service and
contributes to the Bank's consistent efforts to reduce CO2 emissions by digitizing banking services.
WIDE RANGE OF DISTRIBUTION CHANNELS FOR PRODUCTS AND SERVICES
Branch
network
Contact
center
Corporate
blog
Digital
banking
Direct
sales
Corporate
website
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30 years of Fibank on the occasion of the
anniversary of First Investment Bank, numerous
events were held throughout the year in the Bank's
branches, commemorating long-standing
customer relationships and significant projects
carried out for the improvement of the public and
business environment.
The Bank has centralized back office, which
contributes to better customer service . It
performs activities related to routing, distribution,
processing and archiving of documents signed by
customers, as well as to the generation of new
documents, are carried out through a specially developed back-office platform connected to the core
banking information system.
Fibank branches and offices in the country offer the full range of banking products and services to both
individuals and business customers. In an effort to better satisfy customer demand, part of the branch
network operates with extended working hours, while some offices are also open on weekends.
The branch of First Investment Bank in Nicosia, the Republic of Cyprus, has been operating since 1997,
initially mainly in the area of corporate lending. Over the years, it has systematically and consistently
expanded the range of products and services. At present, the branch offers standard credit and savings
products, payment services and e-banking, with a focus on SME customers and retail banking.
For more information on branch network see List of branches.
CONTACT CENTER *bank (*2265), 0800 11 011
Fibank’s Contact Center functioned as an effective channel for
communication and targeted selling of products and services.
It also contributed to the attraction of new and retention of
current customers through the provision of services in
accordance with the Bank's established standards and business
objectives.
In 2023 through the contact center, 12 outgoing campaigns of
different nature and topics were conducted, including
information campaigns, those related to the direct offer of card
products and services, as well as for researching the attitudes of users. According to them, nearly
65,000 outgoing calls were recorded with a high degree of addressees reached, as well as an increase
in the success rate of direct sales during the conducted commercial campaigns
For the reporting period, the Contact Center received over 79 thousand incoming calls, emails and chat
conversations in relation to various inquiries and requests by existing or potential customers, including
on general banking information, card services, contact and reference information, product requests,
etc. During the year, a project was launched to automate incoming telephone calls. Interactive voice
menus and customer self-service options were introduced, as well as automatic call distribution and
callbacks to minimize waiting times.
Through the Contact Center, customers may also apply for debit card overdrafts or apply for consumer
loans. They may receive up-to-date and timely information on products and services, the Tariff and
interest rates of the Bank, the location of branches and their working hours, as well as adequate and
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professional assistance by employees in case of questions or problems. Customers may communicate
remotely with the Bank by phone, email or online chat in real time through the corporate website of
the Bank.
CORPORATE WEBSITE www.fibank.bg
The corporate website of First Investment Bank is maintained and developed, with the aim of
transforming it into an active channel for product communication and cross-selling. In response to
remote banking needs, www.fibank.bg operates a video consultation service regarding credit
products, as well as opportunities to communicate (chat) directly with an expert from the Bank.
Through it, customers can submit online applications for credit cards, overdrafts and consumer loans.
The corporate website has a number of features, including visualization elements in line with current
digital trends and features for intuitive design and personalized content. They provide an easy way to
compare products and services offered by the Bank, allowing customers to quickly select the ones that
best meet their needs.
During the year, in fulfillment of the annual review requirements, the Bank’s accessibility statement
was updated ensuring compliance with the standards for providing accessible content (including under
harmonized standard EN 301 549 V2.1.2 (2018-08) on Accessibility requirements for ICT products and
services). The Bank is committed to maintaining a high level of accessibility of published materials and
usability of their content, enabling their use by people with disabilities (e.g. with impaired eyesight or
hearing).
CORPORATE BLOG
The corporate blog of First Investment Bank was created in 2008, which makes it the first corporate
and banking blog in Bulgaria. For its 15 years, the corporate blog continued to be one of the most used
by customers and useful online communication channels, along with the Bank's social networks. It
contains an important part of the key news, initiatives, as well as financial analyzes and studies related
to the market of banking products and services in the country. Thanks to the AskFibank platform, part
of the corporate blog, the Bank's customers can ask their questions and get an expert opinion.
First Investment Bank continued to maintain active online communication in real time with clients, in
addition to its blog, and through the leading social networks - Facebook, Instagram, LinkedIn, Twitter,
Youtube. In 2023, all these channels highlighted the terms of the Bank's products and services with
regards to its 30th anniversary.
In 2024, the corporate blog and social networks will continue to maintain a constant and positive
relationship with the Bank's customers, providing them with timely, accurate and useful information
about Fibank's products and services.
SALES
First Investment Bank uses direct sales as an additional opportunity for distribution of products and
services, including for comprehensive bank servicing of institutional and corporate clients This
approach helps to build long-term relationships with key customers, as well as to obtain direct
feedback on the Bank's products and services.
The Corporate Sales and Public Procurement Department in the system of First Investment Bank has
considerable experience in preparing the Bank's participation in public procurement, as well as in
servicing corporate and institutional clients, budget spending units, state and municipal enterprises
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DIGITAL BANKING
MY FIBANK ELECTRONIC BANKING
First Investment Bank has an integrated e-banking platform "My Fibank", developed as a single channel
for customer service and constantly evolving by upgrading and adding new functionalities. The
platform is integrated with the core banking IT environment, providing a high level of system security,
optimization and greater workflow efficiency, as well as increased productivity.
Through the My Fibank electronic banking, customers use both active and passive banking according
to their needs and depending on their access rights to the system. As part of the active banking,
customers can open and close current, deposit and other accounts, carry out payments in national and
foreign currency (including mass payments), make utility payments, apply for and enter into
agreements for credit products (including credit cards), request the issuance of debit cards, as well as
buy or sell foreign currency. Passive banking allows customers to check transactions and balances on
bank accounts and/or payment cards. It also provides information on locations of branches and ATMs,
as well as exchange rates, news and current promotions.
"My Fibank" ensures the execution of instant transfers Blink in BGN to other payment service
providers, which is accessible for this type of transfers. Instant Blink payments are executed by the
Bank 24/7/365. They are money transfers with instant or near-instant processing, whereby the
recipient's account is credited with the transferred amount within seconds of acceptance of the
payment order by the Bank. In this way, the Bank provides its customers with a highly innovative and
fast solution for making online transfers.
During the year, a new option for payment and/or verification of compensatory fees was added to the
possibility of purchasing electronic vignettes and route cards by using the customer's account or card
through electronic banking "My Fibank" or the mobile application.
In accordance with current EU regulations and trends in the development of digital banking, First
Investment Bank has provided Third Party Providers (TPPs) with access to customer accounts kept at
the Bank and available online, for payment initiation and account information services: the so-called
"Open Banking". In addition, with the aim of expanding and integrating customer service, First
Investment Bank offers its customers payment initiation and account information services through My
Fibank mobile banking. For more information on Open Bankingsee section Payment services“.
In 2023, the integrated My Fibank electronic banking platform established itself as a channel
generating the predominant share (over 90%) of the Bank's outgoing transfers. A growth of 18% in
transactions and 8% in the number of customers using the platform was reported. There was also an
increase in average number of transactions per customer, both in transfers and in utility payments.
MY FIBANK MOBILE APPLICATION
The Bank’s mobile application is part of My Fibank electronic banking, providing remote access to the
integrated platform by using a mobile device. The application is available for installation by customers
from the app marketplaces for the respective operating systems (e.g. AppStore, Google Play, Huawei
AppGallery).
With the mobile application, customers may use active or passive banking subject to limits set by the
Bank or by the customer. In addition, the innovative Digital Payments service developed by Fibank
allows customers to use digital bank cards through the mobile application and thus make digital
payments with their NFC enabled mobile devices at POS terminals supporting contactless payments.
In 2023, Fibank further developed the services provided through its mobile application. Instant Blink
P2P transfers were introduced where a mobile phone number is used as secondary account identifier
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instead of an IBAN. When ordering Blink P2P transfers from a mobile device registered with My Fibank,
recipients can be selected from the contact list or their number can be entered manually. The new
functionality makes online money transfers fast and simple, in line with modern trends.
In 2023, as part of introducing digitalization in its daily operations, the Bank launched the Remote
Onboarding service for retail customers. It allows individuals to remotely enter into an agreement for
a package including use of My Fibank with active banking rights, to open bank accounts, apply for debit
cards, or switch from passive to active banking in My Fibank mobile application. The registration and
verification process is performed remotely, through the use of a third-party authentication service
provider.
During the year, issuance of virtual credit cards was made available to all individual users of the mobile
application without the need for prior approval.
In 2024, the Bank will continue its efforts to provide first-class service while focusing on digital methods
and solutions, providing self-service options and developing sustainable banking.
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CORPORATE GOVERNANCE STATEMENT
pursuant to Art. 100m of the Public Offering of
Securities Act and Art. 40 of the Accountancy Act
As a public company and public interest entity, First Investment Bank discloses
information about its corporate governance practices, as this section of the Annual Report
represents a Corporate Governance Statement pursuant to Art. 100m of the Public
Offering of Securities Act and Art. 40 of the Accountancy Act.
CORPORATE GOVERNANCE FRAMEWORK ................................. Error! Bookmark not defined.0
CORPORATE GOVERNANCE CODE ................................................ Error! Bookmark not defined.
CORPORATE STRUCTURE .............................................................. Error! Bookmark not defined.
SUPERVISORY BOARD ................................................................. Error! Bookmark not defined.3
MANAGING BOARD .................................................................... Error! Bookmark not defined.7
GENERAL MEETING OF SHAREHOLDERS .................................................................................. 79
CONTROL ENVIRONMENT AND PROCESSES ........................................................................... 790
PROTECTION OF SHAREHOLDERS’ RIGHTS ............................................................................. 801
INFORMATION DISCLOSURE ..................................................................................................... 81
STAKEHOLDERS ......................................................................................................................... 82
SHAREHOLDERS’ STRUCTURE ................................................................................................. 845
SHARE PRICE AND MARKET CAPITALISATION .......................................................................... 84
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CORPORATE GOVERNANCE FRAMEWORK
For First Investment Bank AD good corporate governance is a key element for ensuring long-term and
sustainable development, and successful business model. The corporate policy of the Bank is based on
professional and transparent governance in accordance with internationally recognized standards and
principles of good corporate governance, taking into account changes in the regulatory and economic
environment as well as the financial markets in the country and abroad.
The corporate governance of First Investment Bank is a system of policies, rules, procedures and
practices by which the Bank is managed and controlled, with clearly defined functions, rights and
responsibilities at all levels: General Meeting of Shareholders, Supervisory Board and committees to
it, Managing Board and committees and councils to it, Internal Audit, and structures at the
headquarters, branches and offices. First Investment Bank has a two-tier governance system consisting
of a Supervisory Board and Managing Board.
First Investment Bank applies written policies for corporate governance on group level, which defines
the main principles on internal governance and control over the subsidiaries, as well as the procedures
and mechanisms facilitating the consistent and integrated development of the companies in line with
group strategy and in compliance with regulatory and supervisory bodies‘ requirements.
In 2023, the Bank improved its policies in the field of corporate governance, including with regard to
submitting and considering whistleblowing reports and in relation to the Compliance function.
CORPORATE GOVERNANCE CODE
First Investment Bank AD functions in accordance with the Corporate Governance Code adopted by
the Managing Board and approved by the Supervisory Board. It outlines and structures the main
components, functions and responsibilities constituting the system of corporate governance of First
Investment Bank. In addition to the requirements of applicable law in the Republic of Bulgaria, the
Code is structured by applying the principles of the Basel Committee on Banking supervision, the
guidelines of the European Banking Authority (EBA), as well as the applicable standards of the
Organization for Economic Cooperation and Development (OECD) in this field, and the
CORPORATE
GOVERNANCE
CODE
MANAGEMENT STRUCTURE
Managing
Board
General
meeting of
shareholders
Supervisory
Board
INTERNATIONAL STANDARDS AND GOOD PRACTICES
Remuneration
policy
Protection of
shareholder’s
rights
Interested
parties
Ethical standards
and values
Disclosure
of information
and transparency
Control
environment and
processes
Sustainable
development
(ESG factors)
KEY ELEMENTS IN THE CORPORATE GOVERNANCE FRAMEWORK
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recommendations of the National Corporate Governance Code, approved by the Financial Supervision
Commission.
The Code sets out the basic principles and requirements for maintaining and improving the
organization and methods of governance at the Bank, aimed at:
honest and responsible governance based on adding value;
effective practices of management oversight and control;
executive management and senior staff acting in the best interest of the Bank and towards
increasing the value of shareholders' equity;
timely information disclosure and transparency;
effective system of risk management and control based on the principle of three lines of
defense.
In compliance with the requirements of the applicable legislation, First Investment Bank annually
discloses information on the corporate governance practices and meeting the requirements set in the
Corporate Governance Code of First Investment Bank applying the “comply or explain” principle. Along
with its annual report and financial statements, the Bank discloses to the public also a corporate
governance assessment scorecard in compliance with the National Corporate Governance Code.
In addition to the Corporate Governance Code, First Investment Bank applies a Disclosure Policy. Both
documents are publicly available at the corporate website of the Bank (https://www.fibank.bg/bg/za-
nas/korporativno-upravlenie/kodeks-na-korporativno upravlenie).
In 2023, the requirements specified in these were met, including the requirements for disclosure of
regulated information and information under the financial calendar of the Bank for 2023.
CODE OF CONDUCT AND WHISTLEBLOWING POLICY
For the purpose of establishing the professional and ethical standards required and applicable to the
Bank as a business company, work environment and a credit institution, Fibank has a Code of Conduct
that determines the basic principles, ethical norms and corporate values which underlie the policies
and business plans, rules, procedures and daily operational activities of the Bank.
The Bank, led by the understanding that following a lawful and ethical conduct in relations between
managerial staff, employees, customers and partners of the Bank is an important aspect underlying its
overall activity, has in place a whistleblowing policy. The Policy aims to systematize the means and
procedures for sharing of information where there are suspicions of unlawful actions, or problems
related to the work process, thereby ensuring their transparent and fair consideration and resolution.
In 2023, the Bank updated the policies in compliance with the provisions of the new Whistleblower
Protection Act on violations of law, established in working context.
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CORPORATE STRUCTURE
SUPERVISORY BOARD
MANAGING BOARD
ALCO
Business units Supporting units
Remune-
ration
Committee
Nomination
Committee
Risk
Committee
Presiding
Committee
Audit
Committee
Internal
Audit
Credit
Council
Restructuring
Committee
Operational
Risk
Committee
GENERAL MEETING OF SHAREHOLDERS
IT
Committee
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SUPERVISORY BOARD
STRUCTURE AND COMPETENCES
In 2023 there were no changes in the composition of the Supervisory Board of First Investment Bank.
As at 31.12.2023 the Supervisory Board consisted of five members, as follows:
Name
Position
Term of office
Evgeni Krastev Lukanov
Chairman of the Supervisory Board
24.01.2027
Maya Lubenova Georgieva
Deputy Chair of the Supervisory Board
24.01.2027
Radka Vesselinova Mineva
Member of the Supervisory Board
24.01.2027
Jordan Velichkov Skortchev
Member of the Supervisory Board
24.01.2027
Jyrki Ilmari Koskelo
Member of the Supervisory Board
27.07.2025
The business address of all Supervisory Board members is 111P, Tsarigradsko shose Blvd, 1784 Sofia.
Each member of the Supervisory Board has professional experience, knowledge, qualifications and
abilities, in compliance with the fit and proper requirements, contributing for the collective suitability
in accordance with the activities carried out by the Bank, the main risks and long-term goals.
In 2023 there was no changes in the number of shares of First Investment Bank, held by members of
the Supervisory Board. As at 31 December 2023 the members of the Supervisory Board held a total of
367,652 shares of First Investment Bank, as follows: Mr. Evgeni Lukanov (337,139 shares), Ms. Maya
Georgieva (11,388 shares), Mr. Jordan Skortchev (19,125 shares), as none of them owned more than
1% of the issued share capital.
DIVERSITY POLICY AND INDEPENDENCE
First Investment Bank complies its activity and maintains policies and practices for ensuring diversity
in the composition of its governing bodies, including various aspects such as work experience,
educational qualifications, gender.
The Bank seeks to maintain a target level of 30% of the members of the Supervisory Board to be from
the underrepresented gender (rounding down to an integer if necessary). As of 31 December 2023,
the Bank fulfilled the set target level as two (40%) of the Supervisory Board members were women.
The reported levels exceeded the average levels in EU related to management board in its supervisory
function (28%) according to latest reported data in research for diversity practices of the European
Banking Authority (EBA Report on the benchmarking of diversity practices and the gender pay gap at
the level of the Management body at European Union level under Directive 2013/36/EU (2021 data),
EBA/REP/2023/07, published at https://eba.europa.eu/regulation-and-policy/internal-governance).
For further information regarding the professional experience and competences of the Supervisory
Board members see section „Other information“.
The composition of the Supervisory Board is structured so as to ensure conscientious, professional and
independent fulfillment of the obligations of its members. First investment bank complies with the
requirements applicable for significant banks and public companies, for 1/3 of the members of the
Supervisory Board to be independent.
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FUNCTIONS AND RESPONSIBILITIES
The Supervisory Board of First Investment Bank supervises and, where necessary, advises the
Managing Board and monitors the overall activities of the Bank. It adopts and oversees the
implementation of the strategic objectives, the corporate governance framework, and the corporate
culture of the Bank. When exercising supervision over the Managing Board, the Supervisory Board
takes into account the achievement of objectives, the strategy and risks in the activity of the Bank, as
well as the structure and operation of the internal systems for risk management and control.
The Supervisory Board ensures supervision of the risk management framework, including risk appetite,
internal governance and the control system of all types of risks, i.e. ESG risks, by requiring high risk
culture among employees. It carries out its activity effectively exchanging information with the
Managing Board subject to specifics, and by implementation of high ethical standards and the
corporate values of business conduct sets the tone for high corporate culture and business ethics for
sustainable development: "Tone of the Top".
The meetings of the Supervisory Board are determined in advance, in accordance with an annual work
plan. In 2023, the Supervisory Board held 13 meetings to consider issues within its competence.
Emphasis was placed on exercising ongoing supervision in the implementation of the Risk Strategy, the
Risk Appetite Framework and the Strategy for Reduction of Non-performing Exposures and Acquired
Assets, where the Risk Committee provided active support, as well as on raising MREL eligible liabilities.
Matters concerning the current state of the branch network and branch operations were also
discussed. Regular reviews were carried out of financial results and reporting and of the internal
control framework, where the Audit Committee provided assistance. Supervisory Board members
were constantly informed on the developments in the Bank’s activity and of its compliance with new
regulatory requirements.
The activity of the Supervisory Board is supported organizationally by a Secretary. In addition to
organizing the meetings of the Supervisory Board and the minutes, the secretary has the responsibility
to follow the application of the procedures, as well as to ensure the information to be provided and
exchanged between the members of the Supervisory Board, members of the committees and the
Managing Board.
ASSESSMENT OF THE ACTIVITY
Once a year, the Supervisory Board performs an assessment of the effectiveness of its own activities
as a collective body and individually, assessment of the governance practices and procedures,
suitability, as well as of the functioning of the Managing Board and the committees to the Supervisory
Board. Such assessment for 2023 was accomplished at the end of the fourth quarter of the year.
COMMITTEES
The Supervisory Board is supported in its activity by a Presiding Committee, a Risk Committee, a
Remuneration Committee, and a Nomination Committee which function according to written
competencies, rights and responsibilities in compliance with the applicable regulatory requirements.
The Presiding Committee is responsible for overseeing the activities of the Managing Board on
important strategic decisions, including the issue of new shares, bonds, hybrid instruments, the
adoption of programs and budgets relating to the activity of the Bank, the line responsibilities of the
members of the Managing Board, as well as the function for overview and control over the activity of
the subsidiary companies of the Bank. In 2023, there were no changes in the composition of the
Presiding Committee. Chair of the Presiding Committee is Ms. Maya Georgieva.
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In 2023, the Presiding Committee held 7 meetings to consider issues within its competence, including
allocation of responsibilities among members of the Management Board in relation to the
appointment of new Chief Compliance Officer, as well as making recommendations and coordination
of the budget of the Bank and monitoring of the activity of the subsidiaries.
The Risk Committee advises the Supervisory Board and the Managing Board in relation to the overall
current and future strategy on ensuring compliance of the risk policy and risk limits, risk-taking
propensity and control of its execution by senior management. In 2023, there were no changes in the
composition of the Risk Committee. Chairman of the Committee is Mr. Jyrki Koskelo.
The Risk Committee held 7 meetings during the reporting period, discussing issues of its competence.
It reviewed updated plans and current risk reports, including the Recovery Plan, for the purpose of
coordination and subsequent application. During the year, the Committee reviewed and made
recommendations on the Risk Management Strategy, Risk Appetite Framework and Strategy for the
Reduction of Non-performing Exposures and Repossessed Assets, as was regularly informed and
monitored their implementation, as well as the effectiveness of the internal risk management and
control systems, i.e. the compliance function.
The Remuneration Committee assists the Supervisory Board in the implementation of the
Remuneration policy of the Bank and its subsequent amendments, as well as in any other matters
concerning remuneration, in accordance with the regulatory requirements and best practices in the
area. In 2023, there were no changes in the composition of the Remuneration Committee. Chair of the
Remuneration Committee is Mr. Evgeni Lukanov.
In 2023, the Remuneration Committee held 5 meetings discussing issues of its competence related to
the Remuneration Policy, incl. with respect to newly appointed key function holders. It also reviewed
proposals in connection with the regular assessment process and updating the categories of identified
staff.
The Nomination Committee assists the Supervisory Board in assessing the individual and collective
suitability of members of the Supervisory Board and Managing Board, as well as assessing the
suitability of the key function holders in compliance with applicable regulations and the Policy of First
Investment Bank for nomination and assessment of the suitability of members of the managing and
supervisory bodies and persons holding other positions. In 2023, there were no changes in the
composition of the Nomination Committee. Chair of the Nomination Committee is Mr. Jordan
Skortchev.
During the year the Nomination Committee held 6 meetings considering issues within its competence,
including on the selection and suitability of key function holders, as well as periodic follow-up
assessments of the individual and collective suitability of members of the Supervisory Board, the
Management Board and key position holders. Topics were reviewed also on group level with regards
to the composition of the managing bodies of the subsidiary companies.
As a company of public interest and according with the Law on the Independent Financial Audit (LIFA),
the Bank has a functioning Audit Committee which is responsible for supervising the financial reporting
and the independent financial audit, as well as for the effectiveness of the systems for internal control
and risk management in the Bank. The Committee also makes a recommendation in the selection and
remuneration of the registered auditors to perform the independent financial audit of the Bank and
monitors their independence in accordance with the applicable European and national regulations, as
well as with the Code of Ethics for Professional Accountants. The activity of the Audit Committee is
structured based on written defined competencies, rights and responsibilities, included in its rules of
procedure (stature under the meaning of Art. 107 of LIFA) in compliance with the requirements of the
Law on the Independent Financial Audit and Regulation 537/2014 of the European Parliament and of
the Council on specific requirements regarding statutory audit of public-interest entities.
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First investment Bank fulfills the requirement the majority of the members, incl. the chairman of the
Audit Committee to be external and independent from the Bank. In 2023, there were no changes in
the composition of the Аudit Committee. Chair of the Audit Committee is Mr. Dimitar Dimitrov, who
possesses financial competencies as well as the knowledge, professional experience and qualifications
in the field of accounting and financial audit necessary for the effective performance of his duties.
During the year the present independent member Ms Rositsa Asova was re-elcted by the General
Meeting of Shareholders for a new 3-year term.
During the year, the Audit Committee held 9 meetings, addressing various matters of its competence,
including recommendations on the selection of statutory auditors, as well as ongoing monitoring of
financial reporting and independent financial audit, monitoring the effectiveness of the internal audit
function and control systems, including through regular meetings held with the Chief Financial Officer,
the Chief Compliance Officer, the Director of Internal Audit, as well as with representatives of the
statutory auditors of the Bank.
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MANAGING BOARD
In 2023 no changes were made to the composition of the Managing Board of First Investment Bank. In
April 2023 the mandates of the current members Ms. Ralitsa Bogoeva and Mr. Ianko Karakolev were
prolonged for a new 5-year term as members of the Managing Board of the Bank.
STRUCTURE AND COMPETENCES
At the end of 2023 the Managing Board of First Investment Bank AD consisted of six members elected
by the Supervisory Board on the recommendation of the Nomination Committee, in accordance with
the requirements of applicable law, the Statute of the Bank, and the Policy of First Investment Bank
for nomination and assessment of the suitability of members of the managing and supervisory bodies
and persons holding other positions.
Name
Position
Term of Office
Nikola Hristov Bakalov
Chief Executive Officer (CEO), Chairman of the
Managing Board
16.01.2025
Svetozar Alexandrov Popov
Chief Risk Officer (CRO), Member of the
Managing Board and Executive Director
21.04.2024
Ralitsa Ivanova Bogoeva
Chief Retail Banking Officer (CRBO), Member of
the Managing Board and Executive Director
28.04.2028
Chavdar Georgiev Zlatev
Chief Corporate Banking Officer (CCBO),
Member of the Managing Board and Executive
Director
25.01.2027
Ianko Angelov Karakolev
Chief Financial Officer (CFO) and Member of the
Managing Board
21.05.2028
Nadia Vasileva Koshinska
Member of the Managing Board and Director of
Small Enterprises Banking Department
30.06.2025
The business address of all Managing Board members is 111P, Tsarigradsko shose Blvd, 1784 Sofia.
The Management Board members are elected for period of up to 5 years and can be re-elected for
further mandates without limitation.
The members of the Managing Board are established professionals with high reputation and proven
leadership qualities and capacity to translate their knowledge, skills and experience into well-
argumented solutions that can be applied to the practices in the Bank, aiming to achieve the objectives
and the development strategy and stable management of the institution.
As at 31 December 2023 the members of the Managing Board held a total of 33,649 shares of First
Investment Bank, as follows: Mr. Nikola Bakalov (374 shares), Mr. Svetozar Popov (5856 shares), Mr.
Chavdar Zlatev (27,173 shares), Mr. Ianko Karakolev (12 shares), Ms. Nadia Koshinska (234 shares), as
none of them owned more than 1% of the issued share capital.
DIVERSITY POLICY
In accordance with the policies and practices for maintaining and ensuring diversity in the composition
of the management bodies, the Bank seeks to maintain a target level of 30% of the members of the
Managing Board to be from the underrepresented gender, if necessary rounding down to an integer.
As of 31 December 2023, the Bank fulfilled the set target level as two (33%) of the Managing Board
members were women. The reported levels exceeded the average levels in EU related to management
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board in its management function (18%) according to reported data in research for diversity practices
of the European Banking Authority (EBA Report on the benchmarking of diversity practices and the
gender pay gap at the level of the Management body at European Union level under Directive
2013/36/EU (2021 data), EBA/REP/2023/07, published at https://eba.europa.eu/regulation-and-
policy/internal-governance). For further information regarding the professional experience and
competences of the Supervisory Board members see section „Other information“.
The composition of the Managing Board is structured so as to ensure effective management of
operations, subject to the generally accepted principles of managerial and professional competence
and clear separation of duties and responsibilities. The Bank is represented together with each two of
the executive members of the Board (executive directors).
FUNCTIONS AND RESPONSIBILITIES
The Managing Board of First Investment Bank is the body which manages the Bank independently and
responsibly, in accordance with the established mission, objectives and strategies. The Managing
Board operates under rules of procedure approved by the Supervisory Board. Its main functions are to
manage and represent the Bank by resolving all matters affecting the Bank within its scope of activities,
except those of the exclusive competence of the General Meeting of Shareholders or the Supervisory
Board according to the law and the Statute of the Bank. The Managing Board organizes the
implementation of decisions of the General Meeting of Shareholders and the Supervisory Board, and
performs any other functions assigned to it by those bodies or the law. According to the statutes and
internal regulations, certain decisions of the Managing Board are subject to approval by the
Supervisory Board, while others require coordination with a committee to the SB.
In accordance with the principles of good corporate governance, an open dialogue is maintained
between the Supervisory Board and the Managing Board of First Investment Bank. Besides the regular
reports on implementation of objectives and activities, joint meetings are also conducted. The
Managing Board immediately notifies the Chairman of the Supervisory Board or his deputy of any
circumstances that are of material importance to the Bank and provides timely information regarding
implementation of the business strategy, risk appetite, achievement of objectives, risk limits or rules
relating to regulatory compliance, the system of internal control, or the compliance of the Bank's
activity with the regulatory requirements and the external environment.
The Managing Board of First Investment Bank holds meetings every week. The meeting agenda is
prepared in advance. For the meetings of the Managing Board minutes are prepared which are signed
by all members that were present at the meeting.
The activity of the Managing Board is supported organizationally by a Secretary, who is employed on
a full-time basis and possesses the necessary qualifications and skills to ensure that the governing
bodies follow internal rules and external regulations, as well as facilitating communication between
them.
COMMITTEES AND COUNCILS TO THE MANAGING BOARD
The activity of the Managing Board is supported by collective bodies, including the Credit Council,
Assets, Liabilities and Liquidity management Council (ALCO), Restructuring Committee, and the
Operational Risk Committee, which function according to written structure, scope of activities and
functions for more information see section Risk Management.
Other internal collective bodies also operate in the Bank, e.g. an IT Committee, which as an auxiliary
body to the MB, is responsible for monitoring the implementation of the Bank's IT strategic program,
and to manage and control the IT project portfolio, the targeted use of resources and the approved
budget in this area for more information see section Information technology.
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In line with the long-term priorities aimed at reducing non-interest-bearing assets and ensuring their
effective realization, a Commission for the management and sale of assets functions within the Bank.
Its role is to assist the Management Board in relation to the management, administration and sale of
acquired assets, in accordance with the Levels of authority established in the Bank. The Commission is
chaired by a member of the Management Board, while the other members include the directors of the
Impaired Assets, Asset Management and Administrative departments, as well as the Head of the Asset
Valuation division to the Finance department.
As an auxiliary body in the Bank functions also Commission on cash operations, chaired by the Chief
Retail Banking Officer, while the rest of the members include directors of the following departments:
Vault, Accounting, Branch Network, Analysis and Control of Risk and Security department.
GENERAL MEETING OF SHAREHOLDERS
The General Meeting of Shareholders of First Investment Bank is the most senior management body,
allowing shareholders to decide on fundamental issues concerning the existence and activities of the
Bank. In particular, the General Meeting of Shareholders decides on amendments and supplements to
the Statute of the Bank, on increasing or reducing the capital, as well as on transformation or
dissolution of the Bank. The General Meeting of Shareholders has powers to appoint or dismiss
members of the Supervisory Board, the Audit Committee and the Head of the Internal Audit of the
Bank, decide on the distribution of profit, on the issuance of bonds, as well as on any other matters
under the Statute of the Bank and the applicable law.
In June 2023, an Annual General Meeting of Shareholders was held, which represented 82.45% of the
share capital and voting rights, at which a decision was taken that the entire net profit of the Bank for
2022 shall be capitalized and set in other reserves with general purpose.
The General Meeting of Shareholders elected registered auditors for performing independent financial
audit of the Bank for 2023 Mazars OOD and Ecovis Audit Bulgaria OOD. The companies were elected
after prior approval of the Bulgarian National Bank and recommendation from the Audit Committee
of the Bank based on criteria for coordination of the selection, approved by the BNB together with the
Commission for Public Oversight of Statutory Auditors.
With a view to greater efficiency and facilitating the implementation of certain decisions, the General
Meeting of Shareholders with its previous decisions of 19.06.2019, 23.06.2021 and 16.06.2022
authorized the Management Board, with the prior approval of the Supervisory Board, to adopt
resolutions for: issuance of mortgage bonds under the Law on mortgage bonds with a general nominal
amount of BGN 400,000,000 with maturity up to 10 years from date of issuance and other conditions,
defined by the Managing Board (within a period of 5 years as from 23.07.2019); for the issuance of
debt instruments, including subordinated term debt and debt/equity (hybrid) instruments, up to the
aggregate amount of BGN 2 billion or its equivalence in another currency (within a period of 5 years as
from 11.08.2021) and for increase, through issuance of new shares, of the Bank’s capital until it reaches
an aggregate nominal amount of BGN 210,000,000 (within a period of 5 years as from 02.08.2022).
CONTROL ENVIRONMENT AND PROCESSES
The Bank has established and constantly improves a reliable and comprehensive internal control
framework which includes control functions with the necessary powers and rights of access, enabling
independent performance of duties by the structural and auxiliary units exercising monitoring and
control.
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The risk management processes, procedures and requirements are structured according to the "three
lines of defense" principle, which include the business units, risk management and compliance
functions, as well as internal audit. The control functions are independent of the operational business
units which they monitor and control, and are also organizationally independent of one another as
they perform different functions. For more information on risk management and compliance functions
see section Risk Management.
The internal control framework is in compliance with the applicable requirements in this sphere,
including Ordinance No 10 of the BNB on the Organisation, Governance and Internal Control of Banks
and EBA Guidelines on internal governance under Directive 2013/36/EU (EBA/GL/2021/05). During the
period, the Compliance policy, as well as the Compliance charter were updated with respect to
reflecting structural changes related to the adoption of the position of Chief Compliance Officer.
In relation to measures against money laundering and terrorist financing, the internal regulations were
updated in order to comply with EBA Guidelines on policies and procedures in relation to compliance
management and the role and responsibilities of the AML/CFT Compliance Officer under Article 8 and
Chapter VI of Directive (EU) 2015/849 (EBA/GL/2022/05); EBA Guidelines on policies and controls for
the effective management of ML/TF risks when providing access to financial services
(EBA/GL/2023/04) and EBA Guidelines on customer due diligence and the factors credit and financial
institutions should consider when assessing the money laundering and terrorist financing risk
associated with individual business relationships and occasional transactions (EBA/GL/2023/03).
First Investment Bank applies written policies and rules regarding the disclosure of conflicts of interest,
in accordance with the adopted Policy for managing of conflict of interest, which consolidates the
requirements in the applicable internal banking documents and further develops the necessary
organization for timely identification, management, avoidance and minimizing present and potential
conflicts of interest.
INTERNAL AUDIT
The internal audit function established in First Investment Bank has broad powers, independence,
resource availability and access to the competent management and supervisory bodies. It contributes
to the effective management of the Bank, giving reasonable assurance that legal regulations, rules and
procedures are adhered to, and appropriate and timely corrective actions are taken, thereby helping
to reduce the risk of losses and to achieve the business objectives of the Bank.
The internal audit carries out periodic inspections to ensure the achievement of goals and objectives,
the economical and efficient use of resources, adequate control of various risks, protection of assets,
reliability and integrity of financial and management information, and compliance of activity with
current legislation and the existing policies, plans, internal rules and procedures.
In 2023 the General Meeting of Shareholders of First Investment Bank approved the 2022 annual
report of the Internal Audit which informs shareholders of the main results of the control activities of
internal auditors, the measures taken, and their implementation. After the reporting date, at an
extraordinary General Meeting of Shareholders held on 15 January 2024, a new Head of Internal Audit
was elected in compliance with the regulatory requirements to effectively perform his duties.
REGISTERED AUDITORS
The annual financial statements of First Investment Bank are subject to independent financial audit
jointly by two audit companies, which are registered auditors pursuant to the Law on Independent
Financial Audit and in compliance with the applicable legislation. In order to ensure transparency and
to disclose the results of the Bank to all stakeholders, the audited financial statements are published
in Bulgarian and English on its corporate website at www.fibank.bg.
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The registered auditors are elected by the General Meeting of Shareholders on a proposal by the
Supervisory Board and following a recommendation by the Audit Committee of the Bank. The
registered auditors are audit companies independent from the Bank, and their selection is also agreed
in advance with the Bulgarian National Bank based on criteria for coordination of the selection,
approved by the BNB together with the Commission for Public Oversight of Statutory Auditors.
The registered auditors selected to perform independent financial audit of the annual financial
statements of the Bank for 2023 are:
Mazars OOD, UIC: 204638408, entered in the register of registered auditors auditing
companies, maintained by the Commission for Public Oversight of Statutory Auditors under
registration 169; and
Ecovis Audit Bulgaria OOD, UIC: 131039504, entered in the register of registered auditors
auditing companies, maintained by the Commission for Public Oversight of Statutory Auditors
under registration 114.
In its capacity of a company of public interest in accordance with the Law on the Independent Financial
Audit, an Audit Committee functions within the Bank. For further information on its functions and
responsibilities see section „Supervisory Board“.
PROTECTION OF SHAREHOLDERS’ RIGHTS
The corporate governance of First Investment Bank protects the rights of shareholders, depositors and
other customers of the Bank, treating all shareholders of the Bank equally, including minority and
foreign shareholders. The governing bodies of First Investment Bank provide shareholders and
investors with regular and timely disclosure of information about major corporate events related to
the operation and condition of the Bank, ensuring informed exercising of shareholders’ rights, and
informed investment decision-making by investors.
CONVENING OF GMS AND INFORMATION
The convening of the General Meeting of Shareholders is made by written notice to shareholders in
accordance with the Statute of the Bank in order to encourage their participation in the General
Meeting, and in such a way as not to impede the voting or make it unnecessarily expensive. The Bank
provides shareholders with timely and adequate information for decision-making, taking into account
the scope of competence of the General Meeting. The invitation, together with the written materials
related to the agenda of the General Meeting, are announced in the Commercial Register to the
Registry Agency, submitted to the Financial Supervision Commission, and made available to the public
through www.x3news.com at least 30 days before holding the General Meeting. They are also
published on the website of the Bank in Bulgarian and English from the time of the announcement
until the conclusion of the General Meeting. Upon request, the materials are provided to each
shareholder free of charge. As part of the invitation written rules for voting with proxy are included,
also requirements related to documents prepared in a foreign language, as well as information on
receiving and accepting notifications, warrants of attorney and other documents through electronic
means of communication were also laid down.
In cases where the Bank employees are also its shareholders, the same requirements regarding voting
rights that are currently applicable to the other shareholders are applied.
MAIN TRANSFER RIGHTS AND RESTRICTIONS
All shares issued by First Investment Bank AD are ordinary, dematerialized, registered, and each share
entitles its holder to one vote at the General Meeting of shareholders, and to a dividend and liquidation
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share in proportion with its nominal value. The Bank may not issue shares with different nominal
values.
The Bank's shares are freely transferable, subject to the requirements of applicable law. Under the
regulatory framework, natural or legal persons, or persons acting in concert, may not, without prior
approval of the BNB, acquire directly or indirectly shares or voting rights in the Bank if, as a result of
such acquisition, their holding becomes qualifying, or if such holding reaches or exceeds the thresholds
of 20, 33 or 50 percent of the shares or voting rights, or when the Bank becomes a subsidiary.
No restriction on the rights of individual shareholders holding shares of the same class is allowed, and
there are no shareholders of First Investment Bank with special voting rights. The Bank has no
knowledge of agreements between shareholders that could lead to restrictions on the transfer of
shares, or voting rights.
First Investment Bank maintains a special section on the rights of shareholders on its corporate website
at (https://www.fibank.bg/bg/investitori/korporativno-upravlenie/prava-na-akcionerite).
MINORITY SHAREHOLDERS AND INSTITUTIONAL INVESTORS
In accordance with good corporate governance practices, the Bank develops initiatives to engage
minority shareholders and institutional investors.
In an effort to maintain an open line of communication with shareholders and investors, First
Investment Bank maintains an Investors Club, by registering in which all stakeholders can receive e-
mail notifications of any investor information disclosed by the Bank to the public.
INFORMATION DISCLOSURE
Transparency and timely disclosure of information is a key principle in corporate governance. First
Investment Bank maintains a system of disclosure in accordance with current regulations, which is
aimed at providing timely, accurate and understandable information about significant events, allows
for objective and informed decisions, ensures equal access to information and prevents abuse of
insider information.
First Investment Bank has Disclosure policy adopted by the Managing Board and approved by the
Supervisory Board that outlines the framework for provision of information to stakeholders,
shareholders and investors in accordance with modern practices of good corporate governance and
provides an opportunity for making objective and informed decisions and assessments. In disclosing
information, the Bank is guided by the principles of accuracy, accessibility, equality, timeliness,
integrity and regularity.
In its capacity as a public company and issuer, Fibank discloses to the public (through
www.x3news.com) periodic information, including annual financial reports audited jointly by two
registered auditors, as well as interim financial and activity reports. The scope of periodic information
disclosed by First Investment Bank exceeds the requirements of national legislation, as the Bank has
decided to publicly disclose quarterly financial activity reports in compliance with Art. 100n
1
, par.7 of
LPOS and Art.15, par.2 of Ordinance 2 of the FSC, which have more detailed content than that of its
half-year reports, instead of the more concise public notifications for financial condition for the first,
third and fourth quarter.
First Investment Bank prepares its Annual Report in Bulgarian and English. It contains detailed
information on the development and competitive position of the Bank and its financial results,
implementation of objectives and review of business by type of activity, as well as information on the
management structure, the corporate governance framework (Corporate Governance Statement
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pursuant to the Public Offering of Securities Act and the Accountancy Act), risk management, non-
financial information, incl. related to sustainable development (Non-financial statement within the
meaning of the Accountancy Act) and remuneration policy and its implementation (Report on the
implementation of the remuneration policy under the meaning of the Public Offering of Securities Act).
With respect to the report the registered auditors shall gave their opinion whether it corresponds to
the financial statements and is prepared in compliance with the applicable regulatory requirements.
The Bank applies also the regulatory technical standards on the specification of a single electronic
reporting format as set out in Delegated Regulation (EU) 2019/815, according to which annual financial
reports and activity reports are disclosed in XHTML format, while specific parts of the consolidated
financial statements are marked by using the in-line XBRL format, which is a machine readable format.
As a large institution within the meaning of Regulation (EU) No. 575/2013, registered on the stock
exchange, the Bank discloses information in accordance with regulatory requirements on a quarterly,
semi-annual and annual basis, applying the uniform disclosure formats under Commission
Implementing Regulation (EU) 2021/637 laying down implementing technical standards with regard to
public disclosures by institutions of the information referred to in Titles II and III of Part Eight of
Regulation (EU) No 575/2013.
The Bank also immediately discloses ad hoc information on important events related to its activity.
Information is also published on the website of Fibank: www.fibank.bg, Investors section.
First Investment Bank maintains a corporate website, including an English-language version, with
established content and scope of the information disclosed therein. It provides information about the
products and services of the Bank, as well as essential trading and corporate information about the
Bank, including on shareholder structure, management and supervisory bodies and their committees,
financial reporting and activity reports, sustainable development and environmental, social and
governance (ESG) factors, as well as the other information required under the regulatory requirements
and the National Corporate Governance Code. A special, easily accessible Investors section is
maintained on the website, featuring detailed and updated corporate governance information, stock
information, financial information, news for investors, general meetings of shareholders, etc.
In addition, Fibank publishes information on the Bank in the form of presentations and interviews with
senior management, press releases, journals (e.g. Fibank News), discloses detailed information on the
products and services of the Bank, the applicable terms and conditions and the Tariff and any
amendments thereto, as well as non-financial information on events and initiatives conducted as part
of its sustainability policy.
INVESTOR RELATIONS DIRECTOR
With a view to establishing an effective relationship between First Investment Bank and its
shareholders and persons that have interest in investing in financial instruments issued by the Bank,
an Investor Relation Director is appointed within First Investment Bank Mrs. Vassilka Momchilova
Stamatova.
The Investor Relations Director of First Investment Bank has the necessary qualifications and
professional experience for performing her obligations and responsibilities. The director is responsible
for the timely disclosure of all needed reports, notifications and information the Bank is required to
disclose to the Financial Supervision Commission, the Bulgarian Stock Exchange, the Central Depositary
and the public, as well as to keep a register of all sent materials.
In execution of the applicable regulatory requirements, in June 2023 the Investor Relations director of
the Bank reported her activity during 2022 at the Annual General Shareholders’ Meeting and her report
was adopted by the shareholders unanimously.
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The business address of the Investor Relations Director is 111P, Tsarigradsko Shose Blvd., 1784 Sofia,
tel. +359 2 / 81 71 430, email: vasilka.stamatova@fibank.bg / ir@fibank.bg.
First Investment Bank has a mobile investor relations application providing quick access to financial
information, the financial calendar of the Bank, as well as other data and news of interest to investors.
STAKEHOLDERS
First Investment Bank applies a policy of providing information to stakeholders about its activity. Those
include persons who are not shareholders but are interested in the economic development of the
company, such as creditors, bondholders, customers, employees, the general public, and others.
Periodically, in accordance with legal requirements and best practices, First Investment Bank discloses
information of a non-financial nature, including on sustainable development taking into consideration
ecological, social and government (ESG) factors. The Bank supports ecological initiatives, aimed for
reducing the carbon footprint, as well as socially significant projects, provides sponsorship and
develops donation programs directed primarily towards disadvantaged people, talented children,
supporting Bulgarian sport, culture and education. For more information, see section Sustainable
development“.
First Investment Bank has maintained and developed a corporate blog which functions as a channel of
communication aimed at open dialogue in accessible language with customers, partners and other
stakeholders.
SHAREHOLDERS’ STRUCTURE
As at 31 December 2023 the shareholder structure of First Investment Bank included the following
shareholders: Mr. Tzeko Minev (31.36%), Mr. Ivailo Mutafchiev (31.36%), Bulgarian Development Bank
AD (18.35%) and Valea Foundation (7.87%).
The remaining 11.06% of the Bank’s issued share capital (BGN 16.5 million) was owned by other
shareholders, holding shares subject to free trade on the Bulgarian Stock Exchange (free-float). At the
end of the year the total number of shareholders was nearly 2,000 which include both individuals and
legal entities, including institutional investors.
SHAREHOLDERS’ STRUCTURE AT END-2023 ISSUED SHARE CAPITAL AT END- 2023
Shareholders’
structure, %
2023
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During the reporting period First Investment Bank did not acquire or transfer own shares, and at the
end of the reporting period the Bank did not have own shares.
SHARE PRICE AND MARKET CAPITALISATION
In 2023, the share price of the Bank fluctuated in the range between BGN 1.95 to BGN 3.10. The last
price of the shares of First Investment Bank for the reporting period was BGN 2,92 (2022: BGN 1,99)
and the market capitalization of the Bank, calculated on this basis, amounted to BGN 435,328
thousand. (2022: BGN 296,679 thousand). A total of 1,585 transactions were concluded with the shares
of the Bank on the regulated market BSE, amounting to a turnover of BGN 2,402 thousand, compared
to 2,915 transactions and BGN 4,615 thousand turnover a year earlier.
As at 31 December 2023, the shares of the Bank were traded on the Main Market BSE, Premium
Equities Segment of the Bulgarian Stock Exchange and were included in two stock exchange indices
SOFIX and BGBX40, which bring together the largest, most traded and most liquid companies on the
stock exchange in Bulgaria.
PRICE OF THE BANK'S SHARES FOR 2023
MAIN STOCK-EXCHANGE INDICES ON
BULGARIAN STOCK EXCHANGE
x
Q1’23 Q2’23 Q3’23 Q4’23
Q1’23 Q2’23 Q3’23 Q4’23
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REPORT ON THE IMPLEMENTATION OF THE
REMUNERATION POLICY
within the meaning of Art. 100n of the Public Offering of
Securities Act
In its capacity as a credit institution and a public company, First Investment Bank discloses
information regarding the remuneration policy and its implementation.
MAIN PRINCIPLES AND OBJECTIVES .................................................. Error! Bookmark not defined.
ENFORCEMENT AND CONTROL AUTHORITIES .............................................................................. 87
IDENTIFIED STAFF .......................................................................................................................... 87
FIXED REMUNERATION ................................................................................................................. 88
RATIO BETWEEN FIXED AND VARIABLE REMUNERATION ............................................................. 88
CRITERIA FOR EVALUATION AND IMPLEMENTATION OF THE ACTIVITY ....................................... 88
SPECIFIC REQUIREMENTS FOR DEFERRATION, PAYMENT IN INSTRUMENTS AND RETENTION OF
VARIABLE REMUNERATION ........................................................................................................... 88
LEAVE BENEFITS ............................................................................................................................. 89
SUMMARY OF QUANTITATIVE INFORMATION .............................................................................. 89
INTEGRATION OF SUSTAINABILITY RISKS ...................................................................................... 89
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REMUNERATION POLICY
In its capacity as a credit institution and a public company, First Investment Bank discloses information
regarding the remuneration policy and its implementation, and this section of this activity report
represent Report on the implementation of the Remuneration Policy within the meaning of Art. 100n
of the Public Offering of Securities Act.
MAIN PRINCIPLES AND OBJECTIVES
The remuneration principles of First Investment Bank are structured in such a way as to contribute to
sound corporate governance and risk management. The Bank implements a Remuneration Policy in
accordance with the regulatory requirements, which is consistent with the business and risk strategy,
goals, values and long-term interests of the Bank, promoting reliable and effective risk management
and does not stimulate risk-taking beyond the level acceptable to the Bank.
The main goal of the Policy is to attract and retain highly qualified staff, motivate them to achieve high
results at a moderate level of risk and in accordance with the long-term interests of the Bank and its
shareholders. It is based on the principles of avoiding conflicts of interest and equal treatment of all
employees, gender neutrality, documentation, objectivity, reliable risk management.
ENFORCEMENT AND CONTROL AUTHORITIES
The Managing Board of the Bank is responsible for the organization of the implementation and
application of the Remuneration Policy in First Investment Bank AD.
The Supervisory Board shall approve the Remuneration Policy on the proposal of the Managing Board
and after coordination with the Remuneration Committee, which as a body functioning within the
Supervisory Board, supports its activities in this area. For more information on the Remuneration
Committee, see the section "Supervisory Board".
The Remuneration Policy is a subject to regular review and update as necessary.
IDENTIFIED STAFF
The Remuneration Policy determines the categories of staff, incl. the identified staff, whose
professional activities have a significant impact on the risk profile of the Bank, incl. members of the
Supervisory Board and senior management staff, including members of the Managing and executive
directors; employees with managerial responsibility for independent control functions and those
whose activities involve risk-taking.
For 2023 the number of identified staff of First Investment Bank on an individual basis amounts to 37
employees, which include members of the Supervisory Board and the Managing Board, as well as other
persons, whose activities are related to risk-taking, incl. in the field of lending and the main business
lines, as well as those related to independent control and other corporate functions. They are
identified in accordance with the internal methodology for evaluation and determination of the
categories of employees by the identified staff, developed according to the qualitative and quantitative
criteria of Commission Delegated Regulation (EU) 2021/923 of 25 March 2021 supplementing Directive
2013/36/EU of the European Parliament and of the Council with regard to regulatory technical
standards setting out the criteria to define managerial responsibility, control functions, material
business units and a significant impact on a material business unit’s risk profile, and setting out criteria
for identifying staff members or categories of staff whose professional activities have an impact on the
institution’s risk profile.
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FIXED REMUNERATION
Individual permanent remuneration of identified staff is determined and developed by defining
remuneration levels for the specific position. A starting level is determined at which employees are
generally appointed, taking into account their expertise and relevant and proven managerial
experience, as well as a remuneration level after successfully passing the probationary period, defined
as a percentage increase over the starting level.
Permanent remuneration of employees within the category of identified staff is subject to annual
review, which is carried out as part of the process of planning and budgeting staff numbers and staff
expenses for the next year. The review of permanent remuneration and change decisions are based
on assessment of employees’ performance using a number of elements. They include performance
against specific pre-defined key indicators/targets reflecting the specific contribution of the position
and consistent with the targets and key priorities of the unit; indicators measuring the personal
productivity and efficiency of employees; current priorities of the Bank by individual business line;
general trends in the development of the labor market and/or data on current remuneration levels for
similar positions; approved levels for the specific position and levels and individual remuneration of
employees at similarly graduated positions; staff costs budgeted for the period.
RATIO BETWEEN FIXED AND VARIABLE REMUNERATION
The Remuneration Policy establishes the basic principles in determining of remuneration - fixed and
variable, and the aim is to provide an opportunity for an optimal ratio between fixed and variable
remuneration in accordance with the applicable provisions.
The amount of the variable remuneration may not exceed the amount of the permanent
remuneration, except in the cases when by a decision of the General Meeting of Shareholders of the
Bank a higher amount is determined, but not more than twice the amount of the permanent
remuneration.
CRITERIA FOR EVALUATION AND IMPLEMENTATION OF THE ACTIVITY
The variable remuneration shall be based on the results of the activity and the achieved goals, taking
into account the level and time horizon of the assumed risks, the price of the capital and the necessary
liquidity. The assessment shall be based on an appropriate combination of financial (quantitative) and
non-financial (qualitative) criteria, including a combination of the assessments of the employee's
performance, the structural unit in which the employee works and the Bank as a whole.
The quantitative criteria shall include indicators such as budget execution, achievement of target levels
of earning, capital adequacy and effectiveness, as well as other risk-adjusted indicators (e.g. economic/
internal capital), through which ex ante risk adjustment.
The quality criteria shall include achieving strategic goals, adherence to the Bank's policies and strategy
for risk management, customer satisfaction, compliance with internal rules, ethical norms and
corporate values, initiative, motivation, leadership, teamwork, cooperation with the other structural
units, etc.
SPECIFIC REQUIREMENTS FOR DEFERRATION, PAYMENT IN INSTRUMENTS AND
RETENTION OF VARIABLE REMUNERATION
In accordance with the current legislation and the Remuneration policy at least 50% of the variable
remuneration of the employees from identified staff, shall comprise of shares and other instruments
related to shares or equivalent non-cash instruments, as well as instruments within the meaning of
Art. 52 or Art. 63 of Regulation (EU) № 575/2013 or other instruments which can be fully converted
into Common Equity Tier 1 instruments or written down, as far as such instruments adequately reflect
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the credit quality of the Bank as a going concern and are appropriate to be used for the purpose of the
variable remuneration in line with Delegated Regulation (EU) № 527/2014.
The requirements regarding the instruments to determine an appropriate retention period are
included in order to comply with the incentives with the long-term interests of the Bank.
The remuneration policy shall provide a mechanism for a deferred payment of at least 40% of the
variable remuneration of the identified staff for a period of at least four to five years, depending on
the economic cycle, the nature of the activity and the associated risks, as well as by the position of the
respective employee. The deferral mechanism shall involve proportionate allocation of the deferred
variable remuneration or its gradual increase over the period of deferral.
Pursuant to Ordinance No. 4 of the BNB, the specific requirements for deferral, retention or payment
in instruments with regard to variable remuneration do not apply to banks that are not large
institutions within the meaning of Article 4(1)(146) of Regulation (EU) No 575/2013 and whose value
of assets on an individual basis in accordance with Regulation (EU) No 575/2013 has been less than or
equal to the BGN equivalent of EUR 5 billion on average for the last four years preceding the current
year, or to employees whose annual variable remuneration does not exceed the BGN equivalent of
EUR 50,000 and does not represent more than a third of their total annual remuneration.
LEAVE BENEFITS
According to the concluded contracts for management and control in case of unilateral termination by
the Bank, without notice, the members of the Managing Board are entitled to compensation in the
amount of up to 6 monthly remunerations under the contract, and the branch managers - 2 months.
According to the concluded agreements between the Bank and the members of the Supervisory Board,
upon termination of the contract the members of the Supervisory Board are due compensation up to
12 monthly remunerations, and in special cases the compensation is up to 24 monthly remunerations.
The employment contracts of the Bank's employees comply with the applicable provisions of the Labor
Code and do not contain clauses that differ from the provisions of the law and the usual practice.
In 2023, no severance pay was paid to the identified staff.
SUMMARY OF QUANTITATIVE INFORMATION
In 2023, the remuneration paid to senior management amounted to BGN 11,288 thousand (2022: BGN
12,068 thousand). During the year, no variable remuneration was paid to the identified staff under the
meaning of Ordinance No4 of the BNB for the requirements towards remunerations in banks.
In June 2023, the General Meeting of Shareholders amended its decision of 19.06.2019, which had
determined a total amount of remuneration for members of the Supervisory Board and Management
Board of the Bank of up to BGN 14,000 thousand per year, and determined a new total amount of up
to BGN 16,000 thousand per year.
For more information on Related party transactions and remuneration paid, see Note 35 Related Party
Transactions” of the Unconsolidated Financial Statements for the year ended 31 December 2023.
INTEGRATION OF SUSTAINABILITY RISKS
Pursuant to Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November
2019 on sustainability‐related disclosures in the financial services sector (Regulation (EU) 2019/2088),
First Investment Bank, as an investment firm managing individual customer portfolios and providing
investment advice, falls under the scope of harmonized requirements for transparency of
remuneration policies in relation to the integration of sustainability risks in the process of taking
investment decisions when providing services to customers.
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In this regard, the Bank publishes the required information on its corporate website at
(https://www.fibank.bg/bg/chastni-lica/spestjavanija-i-investicii/investicionni-uslugi-i-dejnosti).
Remunerations received by employees of the Bank for providing portfolio management services and
investment advice are not directly tied to investment performance. In addition, permissible risk
exposures are predetermined, thus avoiding the possibility of additional risks being taken at the
expense of sustainability, such risks having already been indirectly taken into account.
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NON-FINANCIAL DECLARATION
within the meaning of Art. 48 of the Accountancy Act
In accordance with legal regulations and good practices, First Investment Bank discloses in
its Annual Reports non-financial information that represents a Non-financial statement
within the meaning of Art. 48 of the Accountancy Act.
BUSINESS MODEL .............................................................................. Error! Bookmark not defined.
SUSTAINABLE DEVELOPMENT ....................................................................................................... 93
ENVIRONMENTAL ISSUES .......................................................................................................... 93
SOCIAL ISSUES ........................................................................................................................... 97
GOVERNANCE ISSUES .................................................................... Error! Bookmark not defined.
ETHICAL ISSUES ........................................................................................................................... 100
CODE OF ETHICS ............................................................................ Error! Bookmark not defined.
RESPONSIBILITY AND COMPLIANCE .............................................. Error! Bookmark not defined.
WHISTLEBLOWING ........................................................................ Error! Bookmark not defined.
HUMAN CAPITAL ......................................................................................................................... 102
POLICY FOR NOMINATION AND SUITABILITY ASSESSMENT ......... Error! Bookmark not defined.
INFORMATION TECHNOLOGY ........................................................... Error! Bookmark not defined.
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BUSINESS MODEL
First Investment Bank offers a universal business mix of products and services to individuals,
as well as to business clients, incl. strategic focus for development in the spheres of retail,
small and medium-sized enterprises.
BUSINESS PRINCIPLES
We believe that trust is the basis of long-term
relations.
We strive not only for the best practices and results,
but we have the goodwill and discipline to achieve
them.
We appreciate and respect our business partners.
We strive for development and proactive solutions.
We are engaged in social issues and we make our
contribution to their solution.
We bear responsibility for our decisions and actions.
COMPETITIVE ADVANTAGES
First-class customer service.
Well-recognised brand.
Deep knowledge of the market.
Wide branch network.
Innovative digital services.
Solid market positions.
Flexibility in decision-taking.
High professional standards.
Fibank successfully adapts the business model and business development to the challenges of the
external environment, including the processes of digitalization and automatization, as well as the
sustainable development trends. Contributing to this are its customer- and goals execution-oriented
strategy, conservative risk policy, experienced management, as well as high corporate governance
standards applied in practice.
Limited presence
Traditional banking products and services
Focus on Retail banking and SMEs
BUSINESS
MIX
CORPORATE
BANKING
FOREIGN
OPERATIONS
CYPRUS
branch
Consumer lending
Mortgage lending
Deposit and saving products
Private banking
Gold and Bullion coins
Investment services and activities
Factoring
Middle
business
banking
Large
business
banking
Small
business
banking
Trade financing Project financing
European programs
Payment services
RETAIL
BANKING
UNIVERSAL BUSINESS MIX OF PRODUCTS AND SERVICES
Digital banking
Card business
Microlending
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The strategic priorities of the Bank place an emphasis on responsible banking and on the development
of a sustainable business model that supports the green transition, focuses on digitization and
innovation, maintains high quality customer service and ensures stability and profitability for
shareholders:
DEVELOPMENT PRIORITIES
RESPONSIBLE BANKING FOR SUSTAINABLE FUTURE
UNIVERSAL BULGARIAN BANK, LEADING IN KEY SEGMENTS
HIGH QUALITY CUSTOMER SERVICE
FOCUS ON DIGITIZATION AND INNOVATION
STABLE AND SUSTAINABLE BUSINESS MODEL
RETURN FOR SHAREHOLDERS AND COST OPTIMISATION
For more information see section Development priorities“.
SUSTAINABLE DEVELOPMENT
The implementation of factors related to climate change and sustainable development (ecological,
social and governance - ESG) in all processes of First Investment Bank is fundamental for its long-term
development. It is extremely important also for adequate response to market expectations, support
of clients and the community as a whole. With respect to their introduction a comprehensive approach
was adopted through integration into the business operations, risk management framework,
corporate governance, credit process, decision-making, assessment of borrowers' creditworthiness
and investment activity.
Environmental factors Social factors
business
strategy and
strategic
development
goals
Sustainable
product
development
management
INTEGRATION OF SUSTAINABLE DEVELOPMENT IN THE ACTIVITY OF THE BANK
Governance factors
Risk strategy
and Risk
Appetite
Framework
Management
and monitoring
of ESG risks
Credit process
and decision
making
Assessment of
customer
creditworthine
ss
Investment
services and
activities
Valuation of
collateral for
credit
transactions
Commitment of
management
staff on ESG
factors
Developing a
culture of
sustainability
among
employees
Disclosure and
reporting
Remuneration
policy
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A specialized structure has been established in the Bank to ensure the integration of environmental,
social and governance factors in the overall activity, as well as to provide advice and support with
regard to strategic planning, risk framework and internal management. An ESG rating has also been
developed for business customers based mainly on taxonomy requirements and applicable standards
for assessment of environmental and social risks.
In 2023, in fulfillment of the roadmap for implementation of sustainability requirements and
addressing ESG risks, framework documents and policies have been developed, including:
A 10-year Sustainable Development Strategy taking into account applicable ESG factors, risks
associated with the transition to a sustainable economy and physical risks;
A Green Finance Framework setting the standards for green and environmentally friendly lending
according to the ICMA (International Capital Market Association) principles;
A Climate and Environmental Risk Management Policy of First Investment Bank AD.
According to its priorities and framework documents, First Investment Bank focuses on six of
the Sustainable Development Goals of the United Nations,
12
which have been identified as
most relevant to the Bank's business activity and its degree of influence on ESG risks:
UN SUSTAINABLE DEVELOPMENT GOALS
RESPONSIBLE BANKING FOR A
SUSTAINABLE FUTURE
Gender equality
Enforcing diversity, gender equality and gender neutral
remuneration policies.
Decent work and
economic growth
Contributing to the development of banking market and
economic activity in the country, with a focus on retail and
SME banking.
Industry, innovation
and infrastructure
Investing in sustainable sectors and eco-innovations,
supporting the green transition and creating opportunities
for a sustainable future.
Sustainable cities and
communities
Lending to the real estate sector with responsibility for the
creation of sustainable settlements.
Climate action
Financing smart innovation and sustainable investment to
reduce indirect climate and environmental impacts.
Peace, justice, and
strong institutions
Compliance and measures against money laundering and
terrorist financing, prevention of illicit financial flows and
any forms of corruption and bribery.
As a large institution within the meaning of Regulation (EU) No. 575/2013, registered on the stock
exchange, in 2023 the Bank began to disclose quantitative and qualitative information about
environmental, social and governance risks, structured according to the uniform disclosure formats
12
The Sustainable Development Goals are 17 global goals set by the UN General Assembly in 2015 for
implementation by 2030, aimed at combating poverty, inequality, climate change and environmental
degradation, and at achieving prosperity, peace and justice.
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under Commission Implementing Regulation (EU) 2021/637 laying down implementing technical
standards with regard to public disclosures by institutions of the information referred to in Titles II and
III of Part Eight of Regulation (EU) No 575/2013.
ENVIRONMENTAL ISSUES
The Bank's updated business strategy for the period 2023-2025 sets out target volumes for exposures
in the main business segments, meeting the "green" lending requirements of Regulation (EU) 2020/852
of the European Parliament and of the Council of 18 June 2020 on the establishment of a framework
to facilitate sustainable investment, and amending Regulation (EU) 2019/2088 (the Taxonomy
Regulation), including requirements for climate change mitigation and climate change adaptation.
Emphasis is placed on lending programs enabling decarbonization in sectors carrying risks to the
transition to a circular economy, as well as on programs to reduce the carbon footprint from the Bank’s
own activity.
Measures and actions were planned for management of greenhouse gas emissions in the Bank's
activities as follows:
Reduction of direct
emissions from fuel
combustion (Scope 1)
Switching to renewable energy sources for the buildings where
activity takes place.
Improving the energy efficiency of buildings and using energy-
efficient lighting and heating.
Gradual renewal of the car fleet with electric or hybrid vehicles.
Reduction of indirect
emissions from
purchased or acquired
energy like electricity or
heating (Scope 2)
Investment in green energy and purchase of energy from renewable
sources.
Participation in energy management initiatives and cooperation with
suppliers to reduce the overall footprint.
Reduction of indirect
value chain emissions
(Scope 3)
Further integrating ESG factors in lending, investment and risk
management processes at all levels.
Stimulating customers and partners to adopt and implement
sustainable practices.
Reduction of water consumption for own use.
Maintaining accountability in relation to emissions reduction
commitments.
The integration of ESG factors is intended to improve the understanding of businesses considered for
financing, promote low-risk behavior and increase awareness of their degree of preparedness for the
challenges of climate change, as well as determine individual support approaches during the transition
period.
The Business Process Management (BPM) system for processing credit transactions is adapted in line
with the requirements of the Taxonomy Regulation and the disclosure requirements, including with
respect to sectoral affiliation and Classification of Economic Activities (CEA-2008/NACE Rev.2), to
inclusion of information on potential physical and transition risk related to climate change, to
exposures excluded under Delegated Regulation (EU) 2020/1818 as having high carbon intensity, as
well as to the energy efficiency of collateral.
As of 31.12.2023 the exposures towards taxonomy eligible and non-eligible economic activities,
calculated in line with the requirements of Delegated Regulation (EU) 2021/2178 on the disclosures
with respect to ecologically sustainable economic activities (Delegated Regulation (EU) 2021/2178)
were, as follows:
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% of total assets
% of covered assets
13
Exposures
2023
2022
2021
2023
2022
2021
Taxonomy eligible economic
activities
15%
9%
9%
21%
13%
12%
Taxonomy non-eligible economic
activities
45%
50%
56%
63%
70%
72%
Total financial and non-financial
corporations
59%
59%
65%
84%
83%
84%
At the end of 2023, the Bank's securities investment portfolio included bonds backed by “green”
projects or by loans for mitigation of greenhouse gas emissions increased by totaling BGN 58,104
thousand (2022: BGN 49,207 thousand).
In addition, in compliance with applicable regulations, First Investment Bank discloses information for
its exposures to financial and non-financial corporations, which are/are not obliged to publish non-
financial declaration, as well as the exposures to central governments, central banks and supranational
issuers, derivatives and other as a share of the total assets of the Bank, as follows:
% of total assets
Exposures as of 31.12.2021
2023
2022
2021
Financial and non-financial corporations, which are obliged to
publish non-financial declaration/information
3%
4%
4%
Financial and non-financial corporations, which are not obliged to
publish non-financial declaration/information
56%
55%
61%
Total financial and non-financial corporations
59%
59%
65%
Central governments, central banks and supranational issuers
30%
29%
22%
Derivatives
0%
0%
0%
Other
11%
12%
13%
Total assests
100%
100%
100%
In line with the policies undertaken to reduce the carbon footprint and invest in sustainable
development, in 2023 two new credit products were launched:
Green Energy for Households a new retail credit product intended for financing installations for
energy production from renewable sources (e.g. photovoltaic systems or solar hot water systems);
Green Transport for Households a new retail credit product intended for financing the purchase
of electric vehicles. Loans cover up to 100% of the vehicle cost, plus up to BGN 10 thousand for
additional costs related to the purchase.
The Bank continued to offer the developed loan products to business clients: the Green Transport loan
intended for purchase of new electric and hybrid vehicles; the Green Energy - Free Market loan for
13
Covered assets total assets excluding exposures to central governments, central banks and supranational
issuers, and derivatives.
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companies wishing to invest in the construction of photovoltaic systems for production of electricity
for free market sale; and the Green Energy - Own Use loan for construction of photovoltaic systems
generating electricity for own consumption or for sale.
As at 31.12.2023, the portfolio of these lending products amounted to BGN 69,014 thousand.
First Investment Bank’s initiative for replacing the issued plastic debit and credit cards with new ones
made from a recyclable material continued. Thus cards can be fully recycled upon their expiration. In
addition to the eco-friendly material they are made of, cards also have a completely new design
inspired by the idea of supporting scientific efforts to preserve Bulgarian varieties of fruit and
vegetables.
In 2023, nearly 100,000 cards were replaced under the initiative.
As part of the initiatives to reduce carbon emissions from our own operations, resources were
allocated for gradual replacement of fluorescent lighting in the branch network with LED lighting, as
well as for modernization of air conditioning systems. The Bank's central office operates in a modern
building, certified Excellent under the BREEAM sustainability standard. The building is equipped with
a new generation microclimate management system providing individual settings for rooms and offices
which helps reduce carbon (CO2) emissions in the atmosphere.
The Bank's electricity consumption decreased by 3% on average for the period 2021-23, water
consumption for everyday needs by 2%, while paper consumption by 7%, driven by the
implemented initiatives for sustainability and digitization of the activity.
By prioritizing the development of digital services, First Investment Bank confirms its long-term
commitment and responsibility towards reducing the carbon footprint and the negative impact on the
environment. In 2023, the predominant share of transfers (over 90%) were executed through the
Bank's digital channels and innovative online payment solutions were offered. Become a Fibank
Customer was developed: a remote customer onboarding service through the My Fibank mobile app,
using a third-party authentication service provider.
SOCIAL ISSUES
First Investment Bank continued to strengthen its image as a socially responsible institution by
implementing various projects in the fields of corporate donation, education, culture and sports as
part of its corporate social responsibility program.
Fibank is actively involved in the financial
education of children and youths, and in
2023 it again set an emphasis on such
initiatives. In March 2023 the Bank
participated in the Children’s Financial
Literacy Week, during which training
events were held for over 5,000 students
in the age groups of 7-11 and 12-18 in
schools around the country. During
trainings, children were introduced to
concepts such as POS payments,
withdrawing and depositing money at
ATMs, PIN codes, debit and credit, family
and personal budget, shopping on the
Internet, digitizing cards, smartphone payments, etc. that are useful and practical in modern everyday
life.
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In the spring of 2023 Fibank, together with the University of National and World Economy and the
National Academy of Arts, organized open-door events. For 3 weeks, the Bank's employees introduced
students on site to various innovations in the area of digital banking, as well as to products and service
packages structured to support and facilitate young people.
During the reporting period, Fibank took part in the Webit conference one of the most important
technological events held in Bulgaria, dedicated to digital industries and entrepreneurship, as well to
the development of skills among young people consistent with the new digital era. The Bank also
participated in the Career and Life - Why in Bulgaria forum, held by Bulgaria Wants You, which took
place in dozens of cities in the country and abroad, mainly addressing talented young people who wish
to return and work in their homeland.
In 2023, Fibank's Smart Lady program celebrated its fifth anniversary. It supports women
entrepreneurs, mainly targeting micro enterprises run or owned by women, as well as businesses
whose products and/or services are aimed at women. During the year, the Women's Business Arena
was held, supported by the Sustainable Lady Fund of the First Investment Bank. Promising projects of
female entrepreneurs were awarded, and financial grants of BGN 5,000 were given to business ideas
that received the highest rating from the jury. The Bank also supported the Female Entrepreneur Day
event, organized by the Association of Women Entrepreneurs in Bulgaria.
Development of Bulgarian sports and support for young talents are among the important causes
underlying the social responsibility program of First Investment Bank. In October 2023, Fibank
supported the Sofia Marathon organized with the aim to promote sports in urban conditions. Awards
were provided for the mass 5 km Fibank Run event, as well as entertaining games and prizes for
children and families at the specially built fan zone.
Fibank provided support to the
Federation for children deprived of
parental care, assisting their adaptation
through sports. Organized athletic
events and competitions during the
period attracted over 1,000 children
aged between 13-18 years from 70 social
institutions across the country, and
winners in six different disciplines were
announced.
The Bank continued to champion initiatives in its capacity as general sponsor of the Bulgarian Olympic
Committee (BOC) and sponsor of the Bulgarian Athletics Federation (BAF), the Bulgarian Rhythmic
Gymnastics Federation (BRGF) and others. In 2023, the achievements of young talents were awarded
in the Rhythmic Gymnastics World Cup and the International Rhythmic Gymnastics Tournament held
in March and April 2023.
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For yet another year, Fibank presented its charity calendar. The 2024 calendar was prepared in support
of the Bulgarian Rhythmic Gymnastics Federation and features the idea of sustainability, focusing on
the theme of water and its conservation, as well as on its meaning to people as an irreplaceable natural
resource. The aim is to combat climate change by educating the general public about the importance
of water supplies and their protection for the benefit of all.
As an institution dedicated to supporting the country’s culture, during the reporting period Fibank
contributed to initiatives in the fields of music, theater and fine arts, including projects of the Musical
Theater in Sofia, the Varna Summer 2023 festival, the International Jazz Festival in Bansko, as well as
a documentary about the violinist Vasko Vassilev.
Fibank continued its support for the social
program of the Union of Bulgarian Actors and the
fund specially created by UBA through annual
donations and social initiatives, as well as
granting scholarships to talented disadvantaged
students in the field of theater. In March 2023, at
the IKAR National Performing Arts Awards
organized by UBA, the Bank’s CEO awarded
deserving actors.
In 2023, the total value of funds donated by
Fibank for various social initiatives and sponsorships exceeded BGN 300 thousand.
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GOVERNANCE ISSUES
For First Investment Bank AD good corporate governance is a key element for ensuring long-term and
sustainable development, and successful business model. The corporate policy of the Bank is based on
professional and transparent governance in accordance with internationally recognized standards and
principles of good corporate governance, taking into account changes in the regulatory and economic
environment as well as the financial markets in the country and abroad. For more information see
Corporate Governance Declaration.
DISCLOSURES REGARDING CUSTOMER PORTFOLIO MANAGEMENT AND PROVISION
OF INVESTMENT ADVICE
Pursuant to Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November
2019 on sustainability-related disclosures in the financial services sector (Regulation (EU) 2019/2088
SFDR), First Investment Bank, as an investment firm managing individual customer portfolios and
providing investment advice, falls under the scope of harmonized requirements for public disclosure
of information regarding the integration of sustainability risks into its investment decision-making.
The Bank publishes the required information on its corporate website at:
https://www.fibank.bg/bg/chastni-lica/spestjavanija-i-investicii/investicionni-uslugi-i-dejnosti.
Information includes the Bank's policy for integrating sustainability risks, the consideration of adverse
sustainability impacts, the sustainable investment objectives, and the environmental and social
incentives in investment decision-making. The information is subject to periodic review and
compliance assessment, taking into account the nature and scope of the activity, as well as the type of
financial products offered by the Bank.
ETHICAL ISSUES
CODE OF ETHICS
In order to establish the professional and ethical standards required and applicable to the Bank as a
business entity, place of work and credit institution, First Investment Bank has a Code of Ethics which
defines the basic principles, ethical norms and corporate values on which the policies and business
plans, rules, procedures and daily operations are built.
The activity of the Bank is based on the following principles:
Knowledge and observance of current legislation, moral norms and customs, respect for human
rights;
Loyalty and commitment to the mission and values of the Bank;
Responsible attitude towards work obligations, good faith, transparency and impartiality;
Correctness, high ethics, care and respect in customer relations;
Observance of office hierarchy, proper execution of management orders, mutual respect and
tolerance in relations with peers and subordinates, teamwork;
Avoidance of personal or political biases in the performance of official duties.
RESPONSIBILITY AND COMPLIANCE
First Investment Bank operates in accordance with the current national and European regulations and
other regulatory requirements, according to the established standards of practice and in accordance
with the internal regulations. The Bank takes all necessary measures to ensure that in the performance
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of their duties the members of the management and supervisory bodies of the Bank and all employees
act in accordance with the applicable regulatory requirements and the adopted moral and ethical
standards of behavior so as to minimize risks associated with the activities of the institution.
In accordance with the effective legislation the banks in the Republic of Bulgaria implement measures
to prevent the use of the financial system for the purposes of money laundering and terrorist financing.
The measures applied by First Investment Bank aimed at ensuring reliable prevention in accordance
with the regulatory requirements in cooperation with other organizations and government bodies. In
addition, the principle "Know your client" is a condition for offering appropriate service tailored to the
individual needs of each client, as well as contributes to managing risks from illegality operations.
First Investment Bank applies written rules and policies to identify, assess, manage and mitigate
current and potential conflicts of interest. The organization of working process in the Bank is meant to
minimize the possibility of situations relating to conflicts of interest, as in line with the Code of Conduct
of Fibank the employees are obliged to put the interests of the Bank and its clients above their own
interests, while keeping confidentiality of information and protection of personal data. Measures and
actions are also structured for preventing frauds and corruption practices.
WHISTLEBLOWING
The Bank, led by the understanding that following a lawful and ethical conduct in relations between
managerial staff, employees, customers and partners of the Bank is an important aspect underlying its
overall activity, has in place a whistleblowing policy.
The Policy aims to systematize the means and procedures for internal sharing of information where
there are suspicions of unlawful actions, or problems related to the work process, thereby ensuring
their transparent and fair consideration and resolution, while securing needed care and protection of
the rights of the persons submitting the signals. In 2023, the Bank updated the policy in compliance
with the provisions of the new Whistleblower Protection Act.
The creation of conditions for reporting in an environment of trust and respect, as well as for carrying
out consistent and impartial actions to verify the received reports, is a key element in preserving the
Bank's high corporate spirit and reputation.
In accordance with legal regulations and good practices, First Investment Bank discloses in its Annual
Reports non-financial information that represents a Non-financial statement within the meaning of
Art. 48 of the Accountancy Act, including with regard to sustainable development and the related
ecological, social and government issues, the human capital and the diversity policies in place,
description of business development and products, corporate governance practices and ethical issues,
as well as information on business model, products and development priorities for more information
see also sections Mission and development priorities“, Fibank profile“, Highlights 2023“,
Distribituion channels“, Information technology“, Human capital“, Corporate governance“,
Business review“, „Development priorities“.
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HUMAN CAPITAL
In 2023, human capital management activities at Fibank were carried out with a view to achieving
operational efficiency of main internal processes for people management and providing quick and
adequate response to the ongoing business needs the Bank, while keeping in mind the specifics of the
dynamically changing labor market. Projects, initiatives and programs aimed at maintaining and
developing a productive and positive work environment were launched, aimed at supporting the
development of work performance, motivating teams and employees to achieve high results, and
further confirming Fibank's reputation as a preferred employer.
In 2023 г., the implementation of a new labor performance management module in the personnel
management information system continued. The module was successfully integrated and during the
year it was tested in real conditions, with the participation of a significant part of employees and
attesting managers in the Bank.
Activities were carried out within the framework of the long-term strategic Employer Branding project
of the Bank. Those included active communication and advertising media campaigns, as well as
participation in forums with the aim of positive positioning for different audiences in Bulgaria and
abroad.
During the year, the new Fibank High Tech Pro corporate program was
launched. It is designed to provide training, professional guidance and career
development for young talents in the fields of information technology and
cyber security. Those include college and university students with
IT/technological orientation, specializing in application software development,
communication infrastructure, system administration, information security, IT
audit and digital banking. The program combines training, work in the Fibank team, as well as
motivational incentives for the selected participants and for experts from the Bank's IT units who serve
as their personal mentors.
A start was given to the new Health and Body Modeling Fi Pro corporate
program a sports initiative for support to Fibank employees in the
development of a healthy lifestyle and good physical shape, ensuring
harmonious balance at the workplace and quality relaxation, as well as
developing an even more positive work environment.
In 2023, the implementation of the
Solidarity Fund continued a corporate mutual aid and support
program for Fibank employees. The Fund is formed by voluntary
contributions of employees, which the Bank matches by its own
contribution at the end of each month. The program provides assistance to participating members and
to their families, thus ensuring maximum efficiency and financial support to the widest possible range
of people.
The corporate Referral Program to attract well prepared and highly motivated staff to the Bank was
successfully conducted. The results of the program so far have proven that the Bank's employees have
excellent judgment in recommending some of the most suitable job candidates. New recruits have
shown expertise, reliability and motivation to work for the Fibank cause, contribute to team
development and achieve the high goals and standards of the Bank.
In 2023, nearly 75% of Fibank’s employees enrolled for various forms of training in one or more areas.
The more significant training projects and initiatives, having a long-term impact on motivation and
performance, included:
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Training in skills for effective communication, sales and conducting commercial negotiations. A
practically oriented training project for managers and specialists, mainly engaged in business
banking in the large corporate and SME segments. The training places an emphasis on development
of attitudes and skills for successful and proactive customer-oriented communication, effective
offering and sales, and conducting commercial negotiations.
Digital banking training. Intended for all front office employees and managers at Fibank branches
and aimed at upgrading their knowledge and skills in relation to digital banking platforms such as
My Fibank and the mobile application. The training discusses current topics and issues related to
high quality customer service and successful offering of Fibank digital banking products.
Training in investment and debt products. Aimed at developing the skills of front office employees
and managers at Fibank branches to offer and sell well tailored product solutions to Fibank
customers, in line with current trends and challenges in the banking sector.
Training for updating and developing knowledge in the field of mortgage lending. Intended for loan
officers, branch and office managers and designed to ensure successful offering of Fibank's
mortgage products for individuals, as well as to improve customer service in connection with loan
transactions.
Microlending - credit products and credit process. Training for employees at the Bank's branches
engaged in microlending. Designed to expand their potential for attracting new customers by
implementing new products and programs, as well as to increase sales and improve credit process
efficiency by upgrading skills for analysis and use of the internal IT systems.
Introductory trainings for new employees have proven their importance and continue to be held.
They cover all the main areas and topics necessary for introduction to the work specifics and the
Bank’s operations, including corporate governance, ethical requirements and code of conduct,
internal control functions (risk management, compliance and internal audit), measures against
money laundering and terrorist financing, systems, business activities, etc.
The successful practice continued of conducting multiple electronic distance learning courses.
During the year, over 1,850 employees received distance training in various areas including
information security, operational risk, outsourcing policy, financial instruments and investment
intermediation, prevention of money laundering and terrorist financing, and introductory training
for new employees.
The Bank continued to invest in the professional development of
its staff by financing the participation of 10 employees in the
master’s program in Banking Management and Investment
Activity carried out jointly with the Higher School of Insurance and
Finance (HSIF), with a focus on building partnerships and
integrating business with education.
As at 31.12.2023, the number of staff of First Investment Bank on an individual basis amounted to
2,408 employees compared to 2,454 a year earlier. At the end of the year, 24% of the Bank's employees
were under the age of 35, and 57% were under the age of 45.
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The predominant part (73%) of the Bank's employees were women. The share of women with
managerial functions (department directors, branch managers, unit leaders) amounted to 50%.
POLICY FOR NOMINATION AND SUITABILITY ASSESSMENT
In 2023, the Policy for nomination and assessment of the suitability of members of the managing and
supervisory bodies and persons holding other positions was updated, mainly with respect to changes
in the key function holders. The internal framework in this sphere is in line with the requirements and
good practices, incl. the Law on Credit Institutions, Ordinance No 20 of the BNB on Issuance of
Approvals to Members of the Management Board (Board of Directors) and Supervisory Board of a
Credit Institution and Performance Requirements for Their Duties and the joint EBA and ESMA
Guidelines on the assessment of the suitability of members of the management body and key function
holders (EBA/GL/2021/06).
The Policy sets out the basic requirements, principles, guidelines and criteria for selection and
assessing the individual and collective suitability of members of the bodies of First Investment Bank
who have management and supervisory functions, as well as with regards to the key function holders
within the Bank. The Policy structures and identifies the essential fit and proper requirements and
criteria (incl. with respect to needed knowledge, skills and experience; reputation, honesty and
integrity; independence and allocation of enough time for performing of duties; as well as the practices
for encouraging diversity, succession planning and training), so that they to a maximum extent meet
the high standards applied by the Bank with a view to making an adequate contribution to the
realization of its objectives and strategy.
The Bank applies a policy for encouraging diversity with respect to Supervisory Board and Managing
Board in order to maintain a diverse group of board members and to provide diverse views and
experience to facilitate independent opinions/decisions and sound governance, which includes various
aspects such as work experience, educational qualifications, gender, age, geographical diversity. With
respect to the composition of the bodies, the Bank seeks to maintain a target level of 30% of the
members of the Supervisory Board and of the Managing Board to be from the underrepresented
gender, as if necessary rounding off (down) to an integer. As of 31 December 2023, the Bank fulfilled
the set target in the policy. For further information regarding diversity, see sections Supervisory Board
and Managing Board.
NUMBER OF STAFF STRUCTURE OF STAFF
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INFORMATION TECHNOLOGY
Developing information technology and maintaining a modern infrastructure, information and
technology environment is among First Investment Bank’s strategic priorities. Over the years, the Bank
has systematically and consistently invested in technologies in line with the latest trends in banking,
enabling it to offer innovative products and multifunctional solutions to customers. In 2023, Fibank
strengthened its position among the most technological and innovative institutions in the Bulgarian
banking market.
Following high-tech trends, during the year the Bank worked on a program to build a new and modern
data center. Purchasing an up-to-date Oracle Exadata computing platform enabled renewal and
upgrading of banking systems, which in turn optimized speed and guaranteed quality in data
processing. The implementation of an Acronis backup solution ensured the backup and recovery of
data in the main and backup center, minimizing the risk of data loss.
During the period, the Bank took part in a joint pilot project of BORICA AD to upgrade instant payments
in BGN, successfully launching the Mobile Lookup service which enables the execution of P2P Blink
instant credit transfers.
In March 2023, Fibank successfully integrated in its systems the new Eurosystem Single Market
Infrastructure Gateway platform of the European Central Bank (ECB), which ensured continuous
processing and settlement of payments in euros.
The Bank successfully adapted its payment systems to the new ISO 20022 messaging standard for
budget payments.
In 2023, a number of additional functionalities were implemented at the system level, including an
entirely new process for entering requests to unblock accounts in the front office system, a new
process for entering and approving business trips in the Business Process Management system, as well
as an additional module to optimize the labor performance evaluation process in the HR management
system.
Taking into account the growing cyber security risks, the Information Technology and Information
Security departments worked together to improve and upgrade the Bank's IT infrastructure with a
number of software solutions and minimize vulnerabilities following the best practices in the field.
The core banking information system Oracle Flexcube version 12 features universal modules for retail
banking, corporate and investment banking, and an integrated BPM module used for processing and
approval of loan applications, acceptance and registration of currency transfers and authorization of
other payment transactions. The system is built in compliance with all risk control principles, including
the four eyes principle applied in day-to-day operations. Through its centralized and integrated IT
infrastructure, the Bank aims to provide first-class service and high level of security in the execution of
banking transactions, as well as to maintain reliable databases, networks and systems ensuring
continuity of services and key processes.
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Taking into consideration the importance attached by the Bank to information technology, the activity
is managed by Chief Information Technology and Operations Officer. In addition, there is an IT
committee functioning as an auxiliary body to the Management Board. It monitors the IT strategic
program implementation, the IT project portfolio, the targeted use of resources and the spending of
the approved budget. The committee is chaired by the Chief Executive Officer, the remaining members
including the Chief Retail Banking Officer, the Chief Information Technology and Operations Officer, as
well as the directors of the Information Technology, Information Security, Digital Banking, Small
Enterprises Banking, and Finance departments.
Tellers
Mobile
App
Web
ATMs
Kiosks
Security / routing
Reporting
Other services
Third party providers
Basic accounting
system
Lending
Retail banking
Teller
FX operations, letters
of credit and others
BPM Payment services
FLEXCUBE
Issuing Acquiring
Risk
management
Dispute
management
CARD SYSTEM
CORE BANKING INFORMATION SYSTEM
SYSTEMS MAP
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BUSINESS REVIEW
RETAIL BANKING
DEPOSITS
In 2023, attracted funds from individuals increased and reached BGN 7, 772,234 thousand compared
to BGN 7,260,749 thousand a year earlier, mainly driven by the 17.3% increase in current accounts
which reached BGN 3,355,008 thousand (2022: BGN 2,859,322 thousand). Such results were
determined by the consistent policy of the Bank for establishing long-term customer relationships,
while developing cross-selling and transaction business. At the end of the 2023 they increase their
shares and formed 43.2% of the of attracted funds from individuals (2022: 39.4%).
Fibank offers a wide range of current accounts, including the IQ current account, as well as accounts
tailored to the specific needs of certain customer groups such as condominiums, notaries, insurance
brokers and agents, private enforcement agents, etc. The Bank offers banking packets and programs,
inlc. My Choice, My Choice Online, Digital Me, Digital Me+. Among the saving accounts is also the Gold
Account , an innovative product for purchase, sale and keeping of dematerialized gold (XAU).
The Bank's policy is aimed at building a stable deposit base by offering a variety of flexible deposit
products, while maintaining high standards of customer service. Fibank maintained the interest rates
on its savings products in line with the market conditions and the competitive environment, as well as
the high liquidity levels.
By the end of the 2023, term deposits and savings accounts were in the amount of BGN 4,417,226
thousand (2022: BGN 4,401,427 thousand), with borrowings from individuals retaining a major share
at 56.8% (2022: 60.6%). With a view to diversifying its sources of funds.
In terms of attracted funds from individuals First Investment Bank was placed fifth among banks in the
country as at the end of December 2023 (2022: fifth). As at the same date the market share of the
Bank amounted to 9.41% on an individual basis (2022: 9.77%).
As an alternative to deposit products, the conditions of the Perspective+ term product were optimized
during the year. This is a senior unsecured debt product with a fixed yield, intended for individuals and
business customers offered in fulfillment of the minimum requirements for eligible obligations (MREL).
DEPOSITS TO INDIVIDUALS
DEPOSITS TO INDIVIDUALS
BY CURRENCY
5%
3%
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During the year, Fibank organized acceptance of applications for free issuance of European Health
Insurance Cards throughout its branch network, which contributed to cross-selling.
From September 2023, amendments were made to the Payment Services and Payment Systems Act
concerning basic payment accounts (BPA), envisaging special regime, provided that the funds received
on the accounts come from labor remunerations and social payments.
LOANS
The gross loan portfolio of retail banking increased by 9.2% to BGN 2,547,968 thousand compared to
BGN 2,334,010 thousand for the previous year, as a result of an increase in mortgage and consumer
loans.
In BGN thousand / % of total
2023
%
2022
%
2021
%
Mortgage loans
1,277,742
50.2
1,128,416
48.4
986,104
46.5
Consumer loans
1,139,711
44.7
1,063,724
45.6
982,976
46.4
Credit cards
130,515
5.1
138,855
5.9
148,037
7.0
Other programs and secured
financings
-
-
3,015
0.1
3,017
0.1
Total loans to individuals
2,547,968
100
2,334,010
100
2,120,134
100
MORTGAGE LOANS
As at the end of December 2023, mortgage loans increased by 13.2% to BGN 1,277,742 thousand
compared to BGN 1,128,416 thousand a year earlier, increasing their share to 50.2% of the retail loan
portoflio (2022: 48.4%). As at 31 December 2023, the market share of the Bank in this segment was
5.88% (2022: 6.23%), as Fibank was placed fifth among banks in the country on an individual basis
(2022: sixth).
During the year, promotional campaigns were organized with the aim of stimulating sales in the retail
banking segment. A promotional mortgage loan is offered financing up to 90% of the market value of
the property. The option for online loan application through My Fibank electronic banking was
provided, as well as the Video Consultation service. The mortgage products were successfully offered
for residents with income from abroad, and for financing the purchase of real estate with high energy
efficiency class.
From April 2023, an additional financing option was offered for repair and finishing works of purchased
property, applicable to the Right of Choice mortgage loans.
Fibank will put efforts for additional development of its distributional channels for its credit products
and will continue to develop and offer flexible credit products for individuals with the aim at attracting
new clients and offering supplementary products and services.
CONSUMER LOANS
Consumer loans increased by 7.1% to BGN 1,139,711 thousand (2022: BGN 1,063,724 thousand),
contributors being the competitive terms offered by the Bank, the easy loan application procedures,
incl. via the digital channels and the development of new products and programs in line with customer
needs and market necessities. They formed 44.7% of the gross retail banking portfolio (2022: 45.6%).
In order to increase the contribution to environmental protection and ecological sustainability, two
new retail loans were developed during the year:
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Green Energy for Households a new retail credit product intended for financing installations for
energy production from renewable sources (e.g. photovoltaic systems or solar hot water
systems).
Green Transport for Households a new retail credit product intended for financing the purchase
of electric vehicles. Loans cover up to 100% of the vehicle cost, plus up to BGN 10 thousand for
additional costs related to the purchase.
The successful offering continued, including through promotional campaigns, of the Career Start
consumer loan, designed for university graduates up to the age of 30, without requirements for income
or minimum work experience.
As part of the strategy for development and digitization of services, Become a Fibank Customer was
developed: a remote customer onboarding service through the My Fibank mobile app, using a third-
party authentication service provider.
First Investment Bank’s market share in this segment amounted to 7.57% (2022: 8.02%) at the end of
December 2023, and Fibank was fifth (2022: fifth) in terms of consumer loans among banks in the
country on an individual basis.
CREDIT CARDS
The utilized limits on credit cards were in the amount of BGN 130,515 thousand at the end of the
period (2022: BGN 138,855 thousand). Fibank develops various and innovative card products and
services, including thematic campaigns to promote and attract new customers, which were organized
in implementation of the Bank’s consistent and long-term policy for stimulating these non-cash
payments. The relative share of loans utilized through credit cards in the total retail loan portfolio
amounted to 5.1% (2022: 5.9%).
There were new card products and promotional offers started during the year, such as the new metal
credit card World Elite Mastercard, including a new opportunity for deferral of payments with credit
cards via the digital channels of the Bank.
In pursuance of its strategic plans, the Bank continued to develop its operations with a view to more
effective management of the customer portfolio and targeting individual customer groups, as well as
identifying additional cross-selling opportunities. For further information see section Card payments.
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CORPORATE BANKING
DEPOSITS
Attracted funds from corporates and institutions in 2023 increased by 5.2% to BGN 3,721,930 thousand
(2022: BGN 3,537,701 thousand). The increase in volume reflected mainly in the term accounts
reaching BGN 556,046 thousand at the end of 2023 (2022: BGN 379,809 thousand) and forming 14.9%
of the attracted funds from business customers and public institutions (2022: 10.7%). First Investment
Bank offers a variety of savings products for business customers wich adapts to market conditions and
specific company requirements.
Current accounts amounted to BGN 3,165,857 thousand at the end of 2023 (2022: BGN 3,157,892
thousand) and forming 85.1% of the attracted funds from business customers and institutions (2022:
89.3%). Fibank constantly develops the package programs and services, giving opportunities for
optimization of costs and procedures in using different banking services.
In 2023 in order to expand possibilities to business customers, the Bank continued to offer alternative
saving products - products “Perspective+, in fulfillment of the minimum requirements for eligible
liabilities (MREL).
As at 31 December 2023, funds attracted by the thirty biggest non-banking clients represented 11.85%
of the total amount due to other customers (2022: 12.43%).
LOANS
The portfolio of loans to enterprises increased by 12.2% to BGN 4,975,228 thousand at the end of
2023, compared to BGN 4,433,299 thousand a year earlier, as result mainly of increasing the business
goals and strategy.
The structure of the loans portfolio stays balanced and the exposures to micro, small and medium
sized enterprises forms 4.4% (2022: 4.5%), 20.5% (2022: 19.8%) and 23.7% (2022: 24.5%) or all
together 48.6% (2022: 48.8%), and the share of large enterprises is 51.4% (2022: 33.6%) of all business
loans. The customer segmentation, applied by the Bank, corresponds to the European requirements
for defining micro, small and medium-sized enterprises, which were transposed by the Law on Small
DEPOSITS FROM BUSINESS CUSTOMERS
DEPOSITS FROM BUSINESS CUSTOMERS
BY CURRENCY
24%
24%
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and Medium-sized Enterprises. Criteria for annual sales revenue
14
and/or assets, number of staff and
maximum exposure to the customer are applied.
In BGN thousand / % of total
2023
%
2022
%
2021
%
Micro enterprises
216,593
4.4
198,538
4.5
182,625
3.9
Small enterprises
1,021,711
20.5
878,135
19.8
878,125
18.9
Medium-sized enterprises
1,179,493
23.7
1,085,974
24.5
1,123,631
24.1
Large enterprises
2,557,431
51.4
2,270,652
51.2
2,474,806
53.1
Total loans to enterprises
4,975,228
100
4,433,299
100
4,659,187
100
As at 31.12.2023, a leading share in the portfolio structure had the loans to manufacturing sector
(2023: BGN 1,246,137 thousand, 2022: BGN 1,263,715 thousand), the trade sector (2023: BGN
1,142,686 thousand, 2022: BGN 691,864 thousand,) and the services sector (2023: BGN 632,773
thousand; 2022: BGN 602,983 thousand), forming respectively 16.6%, 15.2% and 8.4% of total loans
(2022: 18.7%, 10.2% and 8.9%). Such dynamics reflected the economic activity in the country, as well
as the development goals and diversification of the activity.
Loans in tourism increased to BGN 388,899 thousand (2022: BGN 302,557 thousand) contributed by
the development of the tourist services and recovery in the sector after the COVID-19 pandemic.
Increase was registered in loans in construction (2023: BGN 413,143 thousand; 2022: BGN 386,055
thousand) and infrastructure (2023: BGN 419,674 thousand; 2022: BGN 366,385 thousand), as a result
of the positive dynamics in the construction sector and started infrastructure projects.
Decrease was registered in loans in transport (2023: BGN 179,416 thousand; 2022: BGN 224,795
thousand), finance (2023: BGN 140,139 thousand; 2022: BGN 178,683 thousand) and communication
(2023: BGN 77,502 thousand; 2022: BGN 107,859 thousand). Similar to previous levels registered loans
in agriculture (2023: BGN 227,553 thousand; 2022: BGN 231,850 thousand).
14
Annual sales revenue/assets as follows: micro-enterprises up to BGN 3.9 million; small enterprises up to BGN
19.5 million; medium enterprises up to BGN 97.5 million/ BGN 84 million.
140
BUSINESS LOAN PORTFOLIO PORTFOLIO BREAKDOWN BY SECTOR
3%
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As at the end of December 2023 the market share of Fibank amounted to 9.62% of loans to enterprises
in the banking system (2022: 9.24%), taking fifth place (2022: fifth) among banks in the country on an
individual basis.
For processing business loans the Bank uses the advanced BPM (New Workflow) system. It covers all
steps of accepting loan applications, preparing opinions, approval and disbursement of new loans, as
well as renegotiation of existing loans. The applicable limits and authority levels for approval/
renegotiation of various types of credit exposures are integrated in the system.
LARGE ENTERPRISES BANKING
In 2023, loans to large enterprises amounted to BGN 2,557,431 thousand compared to BGN 2,270,652
thousand a year earlier, forming 51.4% of the total loans to enterprises and 34.0% of the gross portfolio
(2022: 51.2% and 33.6%).
First Investment Bank provides various financing for large enterprises under the form of working
capital loans, investment loans, guarantees, financing under the programs and funds of the EU, under
the National Guaranteed Fund, BDB, Fund of funds, factoring services and others.
The Bank offers factoring services to existing and potential business customers, including companies
delivering of goods or providing services with deferred payment in the country or abroad. First
Investment Bank is a member of Factors Chain International (FCI), a global network of leading
commercial finance companies and can provide export factoring without recourse, as well as import
factoring. The Bank maintains cooperation with leading financial institutions in factoring insurance.
In the area of commercial finance, First Investment Bank has a framework agreement in place with the
Taiwan export insurance agency Eximbank Taiwan for financing deliveries of goods from Taiwanese
suppliers to customers of Fibank in Bulgaria or abroad.
The Bank maintains cooperation with the Bulgarian Export Insurance Agency (BEIA), with which it has
agreement for portfolio insurance, used as part of the techniques for mitigating credit risk. In 2023, it
was expanded by signing a new agreement for financing business customers with an insurance
mechanism providing coverage against financial losses on loans granted.
LARGE ENTERPRISES BANKING
SHARE OF LOANS TO LARGE ENTERPRISES IN
THE GROSS LOAN PORTFOLIO IN 2023
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SMALL AND MEDIUM-SIZED ENTERPRISES BANKING
In 2023, loans to small and medium enterprises
15
amounted to BGN 2,201,204 thousand (2022: BGN
1,964,109 thousand) or 44.2% of the business loans, from which to small enterprises were BGN
1,021,711 thousand (2022: BGN 878,135 thousand), and loans to medium-sized enterprises at BGN
1,179,493 thousand (2022: BGN 1,085,974 thousand). For the Bank’s policy on this segment
contributed the developed loan products and competitive terms offered in the products for SME
clients, as well as the various solutions related to the programs and funds of the EU and the other
guarantee schemes and financing.
During the year, Fibank actively offered its POS Overdraft product to small businesses: a revolving
credit facility based on the volume of realized POS transactions. Successfully are offered credit
products in the field of sustainable financing: the Green Transport loan intended for purchase of new
electric and hybrid vehicles by business customers (financing up to 90% of the vehicle price and term
of up to 7 years); the Green Energy - Free Market loan for companies wishing to invest in the
construction of photovoltaic systems for production of electricity for free market sale (investment loan
with a long term: up to 15 years and a grace period until commissioning of the photovoltaic
installation); and the Green Energy - Own Use loan for construction of photovoltaic systems generating
electricity for own consumption or for sale (financing up to 100% of construction costs and term of up
to 10 years). For more information see the Sustainable Development section.
In 2023, First Investment Bank continued with granting loans under the Financing in Rural Areas
instrument based on an agreement with the Fund Manager of Financial Instruments in Bulgaria under
the Program for the Development of Rural Areas, financed through the European Agricultural Fund for
Rural Development. The program is intended for farmers, agro-processors, as well as micro, small and
medium-sized enterprises from all sectors operating in rural areas, the application deadline being 31
December 2023. Loans cover both new private investments and co-financing of projects supported by
grants. The instrument offers investment loans (with term up to 10 years), as well as and working
capital loans (up to 5 years) that complement the investment and are related to it. Investment loan
amount is up to BGN 2 million, while the maximum amount of supplementary working capital loans is
15
According to business segments of the Bank, incl. criteria for annual turnover/assets, as well as:
microenterprises up to BGN 3.9 million; small enterprises up to BGN 19.5 million; medium-sized enterprises
up to BGN 97.5 million/BGN 84 million.
LOANS TO SME ENTERPRISES
SHARE OF LOANS TO SMEs
IN THE LOAN PORTFOLIO IN 2023
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30% of the total investment or BGN 391,166, subject to compliance with requirements and restrictions
for state aid.
At the beginning of the year, Fibank offered SME lending at more favorable terms regarding loan
collateral, under a portfolio guarantee agreement with the National Guarantee Fund. The agreement
covers both investment and working capital loans. For SME financing, First Investment Bank maintains
cooperation with other institutions, including the National Agricultural Fund and the Bulgarian Export
Insurance Agency. For more information see section External Programs and Guarantee Schemes“.
During the period, Visa Platinum Business Debit was launched: a new high-class card product for
business customers, designed to manage company funds, with additional concierge services included.
In implementation of the strategy for digitalization of products and services, customers were provided
the option to submit online applications for business credit cards through My Fibank electronic
banking.
MICROLENDING
In 2023, the microlending portfolio grew up to BGN 216,593 thousand compared to BGN 198,538
thousand a year earlier. The Bank continued its targeted efforts for development in this segment.
The Microlending Program
16
of First Investment Bank covers a wide range of retailers, manufacturers,
farmers, freelancers, including start-ups and companies with less market experience. The Bank offers
specialized products for micro enterprises including investment loans, working capital loans, business
credit cards and overdraft facilities at competitive terms.
In 2023, Fibank's Smart Lady program celebrated its fifth anniversary. It supports women
entrepreneurs, mainly targeting micro enterprises run or owned by women, as well as businesses
whose products and/or services are aimed at women. Over 1,140 projects worth around BGN 130
million were financed during the period, enabling women entrepreneurs to create new or develop
existing businesses in areas such as education, advertising, production, agriculture and services. As
part of the program, the Sustainable Lady fund was created jointly with Mastercard in support of
16
According to business segments of the Bank, incl. criteria for annual turnover/assets, as well as:
microenterprises up to BGN 3.9 million; small enterprises up to BGN 19.5 million; medium-sized enterprises
up to BGN 97.5 million/BGN 84 million.
MICROLENDING
SHARE OF MICROLENDING
IN THE LOAN PORTFOLIO IN 2023
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innovative green projects of female entrepreneurs. For more information see the Sustainable
Development section.
During the period continued the provisioning of investment and working capital loans at more
favorable terms under the Microcredit with Shared Risk program funded by the Human Resource
Development Operational Program and co-financed by the European Social Fund and the Youth
Employment Initiative. The instrument is in support of start-ups and businesses that develop social
activities or offer services generating positive social impact.
The Bank has policy for supporting agricultural producers, as well as tailored financing solutions
towards individual sectors or business areas with high development potential, incl., IT companies,
medical and dental practices.
EXTERNAL PROGRAMS AND GUARANTEE SCHEMES
First Investment Bank offers a wide range of products and services related to participation in external
programs and guarantee schemes, including ones financed under EU operational programs.
In 2023, a new SME Financial Partners framework agreement was signed with the Bulgarian Export
Insurance Agency (BEIA). SME Financial Partners is an insurance product providing financial institutions
with coverage against financial losses in connection with loans granted by them. The product is aimed
at supporting micro, small and medium-sized enterprises from various sectors in the country, by
allowing them to take working capital loans with relaxed collateral requirements..
During the year, Fibank continued the implementation of its agreements with the Fund of Funds along
three separate positions of the Financing in Rural Areas instrument, funded under the Program for the
Development of Rural Areas, as well as along the program for financing start-ups and social enterprises
of the Risk-Sharing Micro-Finance Facility, funded under the Human Resources Development
operational program.
The Bank has existing agreements with the National Guarantee Fund under two guarantee schemes:
for financing micro, small and medium-sized enterprises in Bulgaria through a risk sharing mechanism,
as well as for financing agricultural producers from the Livestock and Crop Growing sectors under a
program with the Ministry of Agriculture and Food.
PAYMENT SERVICES
In 2023 First Investment Bank was a member and participant in payment systems and agent of other
payment service providers, as follows:
Bank Integrated System for Electronic Transactions (BISERA 6);
Real-Time Gross Settlement System (RINGS);
System for Servicing of Clients Transfers in Euro (БИСЕРА7-EUR);
Wholesale payment system of the Eurosystem (T2), carrying out real-time gross settlement
(RTGS);
Pan-European system for payments in Euro (STEP2 SEPA Credit Transfer), as a direct participant
through EBA Clearing;
Bank Organisation for Payments Initiated by Cards (BORICA);
Agent of Western Union;
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Agent of Easypay.
In accordance with digitalization trends the usage of online payments continued to grow in 2023, as
the shares of transfers via the digital channels (e-banking and mobile banking) increased to over 90%
of all outgoing transfers of the Bank (2022: 86%; 2021: 80%; 2020: 75%; 2019: 67%).
In March 2023, the Bank successfully migrated to the new T2 real-time gross settlement (RTGS) system
owned and operated by the Eurosystem. During the year, a migration project bringing budget
payments in line with the new SEPA standard (ISO 20022 XML) was also successfully implemented.
At the beginning of the year, First Investment Bank offered an innovative service for instant payments
Blink P2P (using a mobile phone number) in the My Fibank mobile application. For more information,
see the Digital banking section.
OPEN BANKING
First Investment Bank has constantly developed its “Open Banking” related services deriving from the
Law on Payment Services and Payment Systems (LPSPS) and Ordinance No 3 of BNB, implementing the
requirements of Directive (EU) 2015/2366 for the payment services within the internal market (PSD2).
The Bank maintains test and production environment, providing opportunity for testing the access to
the special interface (API), as well as providing by the Third Party Providers (TPPs) of the Payment
Initiation and Account Access Information services. Aiming on providing wider awareness for the
customers an actual Terms for Access and Use of First Investment Bank’s API Portal are being
maintained, as well as General Terms and Conditions for securing access for Third Party Providers to
accounts of customers held in Fibank.
Aiming to expand and integrate the services offered to clients, First Investment Bank provides the
usage of this type of services through the Mobile Application My Fibank. This option secures quickness
and convenience for clients when accessing consolidated information for their account serviced at
another payment service provider or when initiating payment from such accounts.
CARD PAYMENTS
In 2023, First Investment Bank developed its card business in line with customer needs, modern
technologies and digitization processes, as well as in compliance with the regulatory requirements,
aiming to increase the security of card transactions.
During the period, issuance of virtual credit cards was developed through the My Fibank mobile
application. Virtual credit cards are intended for making payments over the Internet and, when
digitized, also by other remote means of communication like smartphones. Cards may be digitized by
adding them to My Fibank mobile application, or to third-party applications. The Bank continues to
develop the security of card digitization through all channels.
Visa Platinum Business Debit was launched: a new high-class card product for business customers,
designed to manage company funds, with additional features such as cash back, travel insurance when
traveling abroad, and access to business airport lounges with the Lounge Key program.
During the year, the card service hardware infrastructure was further modernized by purchasing a new
machine with advanced card personalization capabilities.
Fibank continues to develop the functionalities and quality of its ATM network. Voice menus are
gradually introduced, starting from major cities of the country, to assist people with impaired vision
when withdrawing money. By year-end over 60 ATMs already had such menus, and in 2024 their
number is expected to reach 100. The Bank‘s ATM network consisted of 585 devices the at the end of
the year (2022: 604), and the POS network of 9,436 devices (2022: 9,082).
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As part of its sustainable banking policies, during the period Fibank actively replaced all its plastic debit
and credit cards with new ones made from a recyclable material and featuring a new design, associated
with sustainable development ideas. For more information see the Sustainable Development section.
In 2024, Fibank will continue to develop its card payment services by implementing innovative projects
in several areas:
Upgrading the platform for servicing online merchants by introducing a self-service portal where
merchants can monitor and manage their transactions.
Applying an innovative approach to card design. A special Olympic design for Visa Debit and Visa
Gold cards, inspired by the 2024 Olympic and Paralympic Games in Paris.
Development of the ATMs and POS network. Installing 100 new ATMs, as well as modernization
of the software and hardware of POS devices with new functionalities for cash register
connectivity.
INTERNATIONAL PAYMENTS
First Investment Bank is among the leading banks in Bulgaria in the sphere of international payments
and trade financing. Fibank is a popular, reliable and fair business partner which has built a good
reputation over the years among international financial institutions and has gained valuable
experience and know-how from its numerous international business partners, investors, customers,
and counterparties.
In 2023, the Bank reported an increase of 7% in incoming and 25% in outgoing foreign currency
transfers due to the conditions of the environment and the competitive conditions offered by the Bank,
as well as the high quality of customer service.
First Investment Bank has a wide network of correspondent banks, through which it carries out
international payments and trade financing operations in almost all parts of the world. The Bank
executes cross-border currency transfers through SWIFT, a Fibank executes transfers through the
following payment systems: T2, BISERA7-EUR and STEP2 operated by EBA Clearing. Fibank operates in
receiving and issuing of checks and performing various documentary transactions.
In June 2022, First Investment Bank joined the updated STEP2-T Continuous Gross Settlement (CGS)
system ope rated by EBA Clearing which optimized the execution of SEPA credit transfers. In March
2023, the Bank successfully migrated to the new T2 real-time gross settlement (RTGS) system owned
and operated by the Eurosystem. It is part of the new consolidated TARGET Services platform, which
combines on a technical and functional level the TARGET2 payment system, the securities settlement
platform TARGET2-Securities (T2S) and the service for instant transfers in euro TIPS.
The Bank has framework agreement with the Taiwan export insurance agency Eximbank Taiwan for
financing deliveries of goods to clients of First Investment Bank in Bulgaria or other countries where
the Bank has branches or subsidiaries. Under the agreement, Fibank can provide financing under
amount of every individual credit - up to 100% of the value of the contract but not exceeding USD 2
million, with a period of utilization up to 6 months after the first shipment and a repayment term of 6
months to 5 years irrespective of the type of the goods (consumer or non-consumer).
In support of its clients with international business First Investment Bank continued to cooperate in
issuing internationally acknowledged guarantees and letters of credit, incl. through a wide network of
partner banks and institutions. During the reporting period, the letters of credit and bank guarantees
in foreign currency issued by the Bank to guarantee the performance of its customers to third parties
amounted to BGN 94,895 thousand (2022: BGN 86,758 thousand), forming 8.0% of the off-balance
sheet commitments of the Bank (2022: 8.5%).
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GOLD AND COMMEMORATIVE COINS
In 2023, First Investment Bank confirmed its leading position in Bulgaria in terms of transactions and
investment advice in the area of precious metals. Interest in the bars and coins offered at the Bank's
offices and in the online Gold & Silver store continued to grow due to the uncertainties of the external
environment and the macroeconomic conditions.
Revenues from the sale of investment gold and other precious metal products amounted to BGN 1,559
thousand for 2023, compared to BGN 2,070 thousand a year earlier. The reported increase in the
number of transactions and volume of sales mainly came from stronger investor demand and the
increase in gold price on the international markets.
First Investment Bank offers its customers products of investment gold and other precious metals since
2001. Over the years, it has built successful cooperation with a number of leading financial institutions
from around the world: the renowned Swiss refinery MKS PAMP (Produits Artistiques de Métaux
Précieux), the banks UBS and Credit Suisse, the New Zealand Mint, the, the Austrian Mint, The Royal
Mint, and others.
Jointly with the New Zealand Mint, a new Year of the dragon silver coin
was designed, exclusively available at Fibank offices. As part of the
same collaboration, a medal dedicated to the 100th anniversary of
Bulgarian Ski Federation was created in limited circulation. During the
period, gold and silver bars of the Swiss refinery PAMP were offered
celebrating the Lunar New Year.
In continuation of its long-standing policy of supporting Bulgarian
production, Fibank, by agreement with the BNB, successfully
distributes all Bulgarian commemorative coins and coin sets issued by the National Bank. Demand
increased segnificatly in 2023, with the Bank attracting a number of new collectors and investors as
customers.
In carrying out transactions in gold and precious metals, First Investment Bank invariably complies with
all quality criteria of the London Metal Exchange and international ethical trading standards.
For 2024, the creation of new and unique coins is planned, based on successful cooperation with a
number of leading financial institutions from around the world.
PRIVATE BANKING
First Investment Bank has offered private banking to individuals
since 2003, and to corporate customers since 2005. Private
banking features servicing by a designated personal officer, who
is responsible for the overall banking solutions provided to a
customer.
In 2023, the EGO Portfolio private banking service was developed. Building upon previous services, it
features not only a personal banker but also a personal investment consultant providing advice in
connection with structuring and management of portfolios and investments in various assets. This
enables customers to benefit from the financial asset trust management services offered by Fibank
and to have personalized financial strategies built for them by professional portfolio managers with
experience in international financial markets, with a proven approach adapted to customers financial
situation and preferences.
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A highlight in the activity for the year was the improvement of the Premium Banking service. Aimed
at a separate customer segment, it features an efficient and useful digital solution that enjoys a high
level of user satisfaction. Premium Banking includes the Premium and Premium Plus packages which
offer preferential terms on traditional banking products and services. In addition, customers can count
on constant availability of the Premium Banking specialists who provide them with fast and competent
assistance in performing all banking transactions.
For the reporting period, the number of Private Banking business customers increased by 5% YoY,
while the monthly income from membership fees increased by 29%. The reported growth of
customers' portfolio of investment and savings products was nearly 40%.
CAPITAL MARKETS
In 2023 net trading income amounted to BGN 23,295 thousand (2022: BGN 19,717 thousand), mainly
as a result of the higher income from trade operations related to exchange rates. The interest income
related to the Bank’s portfolio of debt instruments increased to BGN 71,060 thousand, against BGN
24,520 thousand a year earlier.
The securities portfolio at the end of the year amounted to BGN 2,583,949 thousand, compared to
BGN 2,598,137 thousand a year earlier, of which BGN 1,077,079 thousand measured at fair value
through other comprehensive income (2022: BGN 468,247 thousand), BGN 1,263,279 thousand
measured at amortized cost (2022: BGN 1,862,203 thousand) and BGN 243,591 thousand measured at
fair value through profit or loss (2022: BGN 267,687 thousand).
First Investment Bank applies the business model requirements and criteria for classifying financial
assets in the Bank's portfolios according to IFRS 9. Depending on the purpose of financial asset
management, those include: 1) a business model whose objective is to hold assets in order to collect
the contractual cash flows (hold to collect); 2) a business model whose objective is to both collect
contractual cash flows and sell of financial assets (hold to collect and sell); 3) another business model,
where the purpose is different from the two above business models (other business model), where
assets held for trading are also included.
The Bank's activity is organized in accordance with the regulatory requirements arising from the
European legal framework in the field of financial markets: Regulation (EU) No 600/2014 of the
NET TRADING INCOME
INTEREST INCOME FROM
DEBT INSTRUMENTS
23%
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European Parliament and of the Council on markets in financial instruments (MiFIR), Commission
Delegated Regulation (EU) 2017/565 supplementing Directive 2014/65/EU of the European Parliament
and of the Council as regards organizational requirements and operating conditions for investment
firms, and Regulation (EU) No 1286/2014 of the European Parliament and of the Council on key
information documents for packaged retail and insurance-based investment products (PRIIPS), as well
as in compliance with the requirements of the Markets in Financial Instruments Act and its
implementing regulations, the regulations in the field of measures against market abuse of financial
instruments, and other applicable legislation.
In pursuance of the requirements arising from Regulation (ЕС) 648/2012 of the European
Parliament and of the Counsel on OTC derivatives, central counterparties and trade repositories
(EMIR), the Bank has a Legal Entity Identifier (LEI) code 549300UY81ESCZJ0GR95, issued by the Global
Markets Entity Identifier (GMEI) Utility.
In its capacity as an investment intermediary and a primary dealer of government securities, First
Investment Bank carries out transactions with financial instruments in the country and abroad
including transactions in government securities, shares, corporate and municipal bonds, compensatory
instruments as well as money market instruments. The Bank also offers trust portfolio management,
investment consultation, as well as depositary and custodian services to private individuals and
corporates, including maintaining accounts of securities, income payments and servicing payments
under transactions in financial instruments, as well as registration services. As part of the Compliance
function, the Bank has a specialized unit “Compliance Investment Services and Activities” which
controls and ensures observance of the requirements related to Fibank’s activity as an investment
intermediary.
Orders for the subscription/redemption of units in four mutual funds (FIB Garant Mutual Fund, FIB
Classic Mutual Fund, FIB Avangard Mutual Fund and FFBH Vostok Mutual Fund, managed by the
Management company FFBH Asset Management AD) can be accepted in Fibank’s offices which are
registered with the Financial Supervision Commission. At these locations, distribution is also carried
out of four mutual funds managed by Erste Asset Management (ERSTE-SPARINVEST
Kapitalanlagegesellschaft m.b.H), as well as of E.I. STURDZA STRATEGIC MANAGEMENT LIMITED.
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MEETING THE 2023 GOALS
N
Goals
Fulfilled
1
A UNIVERSAL BULGARIAN BANK, LEADING IN
KEY SEGMENTS
Set a priority on the development of retail
and SME banking segments.
Offer new and creative products,
providing convenience and security to
customers.
Upgrade cross selling and transactional
business models.
In 2023, the retail, micro, and SME loan portfolios
registered an increase, their combined share reaching
66.0% of the total loan portfolio (2022: 66.4%), This was
mainly driven by retail and small enterprise loans which
grew by 9% and 16% respectively during the period.
Fibank retained its leading position among banks in the
country: fifth in deposits, fifth in corporate loans, fifth in
consumer loans, and fifth in mortgage loans.
Two new retail loans were launched: Green Energy for
Households and Green Transport for Households,
intended for financing solar systems and purchase of
electric vehicles.
A new agreement was signed with BEIA, providing
insurance coverage against financial losses on loans
granted to micro, small and medium-sized enterprises.
Fibank became the institution accepting applications for
issuance of European Health Insurance Cards in Bulgaria,
through its branch network in the country.
For more information, see the Business Review and 2023
Highlights sections
2
HIGH QUALITY CUSTOMER SERVICE
Maintain highest quality of customer
service by developing motivational
programs and training for employees.
Speed up customer service by improving
IT systems and applying customer
oriented approaches.
Develop personalized services and loyalty
programs.
The deposit base grew to BGN 11,494,164 thousand at the
end of the period (2022: BGN 10,798,450 thousand), and
the total loan portfolio to BGN 7,158,309 thousand (2022:
BGN 6,384,541 thousand).
The awards received serve as recognition for the
achievements during the period: Bank of the Year and
Employer Branding at the Company of the Year ceremony,
as well as Mystery Customer Bank for best customer
service in Bulgaria, received at the Bank of the Year
competition organized by the Bank of the Year
Association.
The exclusive metal World Elite Mastercard® credit card
was launched, offering a number of additional features.
The Bank successfully migrated to the new T2 (TARGET2)
real-time gross settlement (RTGS) system of Eurosystem
for processing large-value payments.
For more information, see the Business Review and Awards
2023 sections
3
FOCUS ON DIGITIZATION AND INNOVATION
Implement technological innovations and
digitize the branch network.
First Investment Bank launched the innovative Blink P2P
service for making instant transfers by mobile phone
number using the My Fibank mobile application.
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Develop digital services, mobile
applications and e-banking.
Optimize IT and business processes and
automate activity in line with innovation in
banking.
Remote onboarding for retail customers was introduced
in My Fibank mobile application, using a third-party
authentication service provider.
A new virtual credit card was developed, issued entirely
online through the mobile application.
New functionalities were added to My Fibank electronic
banking, including detailed reference information on
loans.
The Bank successfully adapted its payment systems to the
new ISO 20022 messaging standard for budget payments.
For more information, see the Business Review, Distribution
Channels and Awards 2023 sections.
4
STABLE AND SUSTAINABLE BUSINESS MODEL
Ensure sound levels of own funds and
eligible liabilities (MREL).
Effective management of liquidity and
funding risk.
Maintain optimal asset structure and
reduce loan portfolio risk.
At the end of 2023, the Bank reported stable capital ratios
as follows: common equity Tier 1 (CET1) ratio 17.60%, Tier
1 capital ratio 21.09% and total capital adequacy ratio
21.09%, well above the minimum regulatory
requirements..
Fibank maintained high liquidity, with liquidity coverage
ratio (LCR) and net stable funding ratio (NSFR) of 278,55%
and 150,48% respectively at the end of the period.
Non-performing exposures decreased by 18.9% net or by
BGN 229,936 thousand YoY, in line with the strategy for
their reduction and due to measures implemented such as
increased loan collection and write-offs.
Other borrowed funds increased to BGN 439,634
thousand (2022: BGN 116,487 thousand), mainly as a
result of obligations under loan agreements which the
Bank actively raised during the period in order to meet the
MREL requirements.
Balance sheet equity increased by 10.9% to BGN 1,472,926
thousand (2022: BGN 1,328,209 thousand), as a result of
an increase in other reserves and retained earnings which
reached BGN 1,035,102 thousand at the end of the period
(2022: BGN 900,061 thousand).
For more information, see the Financial Review, Risk
Management and Sustainable Development sections.
5
RESPONSIBLE BANKING FOR A SUSTAINABLE
FUTURE
Offer products and finance projects that
are consistent with green transition and
sustainable development.
Implement environmentally efficient
internal processes.
Support socially significant projects and
initiatives.
Framework documents and policies were developed in
the area of sustainability and ESG risks, including a 10-year
Sustainable Development Strategy, a Green Finance
Framework and a Climate and Environmental Risk
Management Policy.
New retail loans were developed: Green Energy for
Households and Green Transport for Households,
intended for financing solar systems and purchase of
electric vehicles.
A number of social initiatives were carried out in the field
of education, culture and sports, including the Children's
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Financial Literacy Week and the Women's Business Arena
under the Smart Lady program. Support was provided to
the Federation for children deprived of parental care, the
Bulgarian Rhythmic Gymnastics Federation, and the
Union of Bulgarian Actors. A charity calendar was created
focusing on conservation of water as an irreplaceable
natural resource.
6
SHAREHOLDER RETURN AND COST
OPTIMIZATION
Achieve a high return on equity.
Maintain optimal cost-to-income ratio.
Invest in profitable securities and diversify
income.
The reported return on equity (after tax) for 2023 was
9.60%, well above the long-term target of 8%.
For 2023, the cost/income ratio on an individual basis
stood at 42.25% (2022: 47.57%), in line with the target
level of below 50% set in the Development Strategy.
Total operating income increased to BGN 517,554
thousand (2022: BGN 444,167 thousand). Growth was
reported in all main income sources, especially in net
interest income.
The investment securities portfolio amounted to BGN
2,583,949 thousand (2022: BGN 2,598,137 thousand) at
year-end, managed according to market conditions with
the aim of generating profitability while maintaining a
balanced risk-return ratio. Net interest income from debt
instruments increased to BGN 71,060 thousand (2022:
BGN 24,520 thousand), serving as an additional income
source.
For more information see the Financial Review and Risk
Management sections.
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SUBSEQUENT EVENTS
At an extraordinary General Meeting of Shareholders of First Investment Bank AD held in January
2024, a new Head of Internal Audit was elected for a 5-year term.
In February 2024, a General Meeting of Shareholders of Diners Club Bulgaria AD, a subsidiary of
First Investment Bank AD, was held at which a decision was taken to terminate the activity of Diners
Club Bulgaria AD as a payment institution, respectively to terminate its activity as a franchisee of
Diners Club International. Following a procedure under the Payment Services and Payment Systems
Act, the plan for termination of the activity proposed by the company, as well as the invalidation
of its license as of April 15, 2024, were approved by the BNB by decision dated 15.02.2024.
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DEVELOPMENT PRIORITIES
UNIVERSAL BULGARIAN BANK, LEADING IN KEY SEGMENTS
Priority focus on the development of retail and SME segments.
Offering new and creative products, providing customers with convenience and security.
Upgrading the cross-selling and transactional business models.
HIGH QUALITY CUSTOMER SERVICE
Maintaining highest quality of customer service by developing motivational programs and training
for employees.
Speed in customer service by improving IT systems and applying customer-oriented approaches.
Development of personalized services and loyalty programs.
FOCUS ON DIGITIZATION AND INNOVATION
Implementation of technological innovations and branch digitalisation.
Development of digital services, mobile applications and e-banking.
Optimization of IT and business processes in line with innovation in banking and automation of
activities.
STABLE AND SUSTAINABLE BUSINESS MODEL
Ensure sound capital position and MREL.
Effective management of liquidity and financing risks.
Maintain optimal asset structure and reduce loan portfolio risk.
RESPONSIBLE BANKING FOR SUSTAINABLE FUTURE
Offer products and finance projects aimed at sustainability and supporting the green idea.
Implement environmentally friendly internal processes.
Support responsible projects and initiatives with social impact.
RETURN FOR SHAREHOLDERS AND COST OPTIMISATION
Achieve high return on equity.
Maintain maximum efficient cost-to-income ratio.
Invest in profitable securities and revenue diversification.
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OTHER INFORMATION
MEMBERS OF THE SUPERVISORY BOARD
Evgeni Lukanov - Chairman of the Supervisory Board
Mr. Lukanov joined First Investment Bank AD in 1998 as Deputy Director, and later as Director and
General Manager of the Tirana Branch, Albania. From 2001 to 2003 he was Director of the Bank’s
Vitosha Branch (Sofia).
Mr. Lukanov has occupied a number of senior positions with First Investment Bank AD. From 2003 to
2007 he was Director of the Risk Management Department and Member of the Managing Board. From
2004 to 2012 - Executive Director and Member of the Managing Board of First Investment Bank AD.
During his years of work in First Investment Bank AD, Mr. Lukanov has been Chairman of the Credit
Council and the Liquidity Council of the Bank. He has been in charge of the following departments: Risk
Management, Impaired Assets and Provisioning, Loan Administration, Specialized Monitoring and
Control, Retail Banking, Methodology, and Liquidity.
Mr. Lukanov has also been member of the Managing Board of First Investment Bank Albania Sh.a.
At the beginning of February 2012, Mr. Lukanov was elected as Chairman of the Supervisory Board of
First Investment Bank AD. For the period 2012-2019 he was Chairman of the Risk Committee to the
Supervisory Board of the Bank and since May 2019 was elected as Chairman of the Remuneration
Committee to the Supervisory Board of the Bank.
Mr. Lukanov holds a Master’s Degree in Economics from the University of National and World
Economy, Sofia. Prior to joining First Investment Bank AD, Mr. Evgeni Lukanov worked as currency
broker with First Financial Brokerage House OOD.
Besides his position on the Supervisory Board of the Bank, Mr. Lukanov is also Chairman of the Board
of Directors of Fi Health Insurance AD.
Maya Georgieva - Deputy Chair of the Supervisory Board
Prior to joining First Investment Bank, Ms. Maya Georgieva worked with the Bulgarian National Bank
for 19 years where she gained considerable experience in international banking relationships and
payments, banking statistics and firm crediting. Her last appointment with BNB was as Head of the
Balance of Payments Division.
Ms. Maya Georgieva joined First Investment Bank AD in 1995 as Director of the International
Department. From 1998 to 2012 she served as Executive Director of First Investment Bank and
Member of the Managing Board. During her years of work in the Bank she has been responsible of the
following departments: International Payments, Letters of Credit and Guarantees, SME Lending,
Human Capital Management, Administrative Department, Sales Department, Retail Banking,
Marketing, Advertising and PR, Branch Network, Private Banking and the Vault.
Alongside her responsibilities at the Bank, Ms. Georgieva has also occupied a number of other senior
executive positions. From 2003 to 2011 she chaired the Supervisory Board of CaSys International - a
Northern Macedonia-based card processing company servicing card payments in Bulgaria, Northern
Macedonia and Albania.
From 2009 to 2011 she was Chair of the Board of Directors of Diners Club Bulgaria AD - a franchise
company of Diners Club International, owned by First Investment Bank. In this capacity, she inspired
the launch of a number of products, including the first female-oriented credit card. From 2006 to 2011
she was also member of the Managing Board of First Investment Bank - Albania Sh.a., a subsidiary of
First Investment Bank.
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In the beginning of February 2012, Ms. Georgieva was elected as Deputy Chair of the Supervisory Board
of First Investment Bank AD and Chair of the Presiding Committee to the Supervisory Board of First
Investment Bank AD.
Ms. Georgieva holds a Masters Degree in Macroeconomics from the University of National and World
Economy in Sofia and has post-graduate specializations in International Payments and Balance of
Payments with the International Monetary Fund and Banking from Specialized postgraduate course of
BNB joint with the Bulgarian Union of Science and Technology.
She was granted several times with the "Banker of the Year" award of the Bulgarian financial weekly
"Banker" - in 2001 and 2011, as well as in 2018 for overall contribution to the development of the
banking system.
Radka Mineva - Member of the Supervisory Board
Prior to joining First Investment Bank AD, Ms. Mineva worked as a capital markets dealer at the
Bulgarian National Bank where she gained considerable experience in banking. During the time spent
with the Central Bank, she specialized at the Frankfurt Stock Exchange and the London Stock Exchange
as a capital markets dealer.
Ms. Mineva started her career with the foreign trade enterprise Main Engineering Office, where she
worked for 9 years; she also spent three years as an expert at RVM Trading Company.
Since 2000, Ms. Mineva has been a Member of the Supervisory Board of First Investment Bank AD.
Since May 2019, she was elected as Member of the Presiding Committee to the Supervisory Board of
First Investment Bank.
She is a graduate of the University of National and World Economy in Sofia, with a degree in Trade and
Tourism.
Besides her position on the Supervisory Board of the Bank, Ms. Mineva is Manager of Balkan Holidays
Services EOOD - a company with activities in the sphere of tourism, transportation, hotel business,
tour operation, and tour agency services. Ms. Mineva is also Manager of Balkan Holidays Partners OOD
- a company engaged in international and domestic tourism services, foreign economic transactions,
and financial management. Ms. Mineva owns more than 25% of the capital of Balkan Holidays Partners
OOD. She is also Member of the Managing Board of the non-profit organization “National Board of
Turism” and of the non-profit organization “Union of investors in tourism”.
Jordan Skortchev - Member of the Supervisory Board
Before joining First Investment Bank AD, Mr. Jordan Skortchev worked for two years with the Central
and Latin America Department of the foreign trade organization Intercommerce, followed by five years
with First Private Bank, Sofia as an FX Dealer and Head of the Dealing Division.
Mr. Skortchev joined First Investment Bank in 1996 as Chief Dealer, FX Markets. From 2001 to 2012
Mr. Skortchev was Member of the Managing Board and Executive Director of the Bank. During his
years of work in the Bank, Mr. Skortchev has been responsible for the following departments: Card
Payments, Operations, Gold and Numismatics, Internet Banking, Dealing, Security and Office Network-
Sofia.
Alongside his responsibilities at the Bank, Mr. Skortchev has also occupied other senior executive
positions. Mr. Skortchev has been Chairman of the Supervisory Board of UNIBank AD, Republic of
Northern Macedonia, member of the Supervisory Board of CaSys International, Republic of Macedonia,
member of the Board of Directors of Diners Club Bulgaria AD, member of the Board of Directors of
Bankservice AD, member of the Board of Directors of Medical center FiHealth AD, and Manager of
FiHealth OOD.
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In the beginning of February 2012, Mr. Skortchev was elected as a Member of the Supervisory Board
of the Bank. For the period 2012-2019, he was Chairman of the Remuneration Committee to the
Supervisory Board of First Investment Bank AD. Since May 2019, Mr. Skortchev was elected as
Chairman of the Nomination Committee to the Supervisory Board of First Investment Bank AD.
Mr. Skortchev holds a Masters Degree in International Economic Relations from the Higher Institute of
Economics (now the University of National and World Economy) in Sofia. He has specialized in banking
in Luxembourg, in swap deals at Euromoney, and in futures and options at the Chicago Stock Exchange.
Mr. Skortchev holds more than 10% of the capital of Investment intermediary Delta Stock AD.
Jyrki Koskelo Member of the Supervisory Board
Mr. Jyrki Koskelo was elected as member of the Supervisory Board of First Investment Bank AD in June
2015. In his capacity as an independent member Mr. Koskelo supports the Supervisory Board in setting
up the business objectives and the strategy of the Bank, the corporate culture and values, as well as in
overseeing good corporate governance practices and effective risk management. Since the end of
2019, he has been Chairman of the Risk Committee to the Supervisory Board of First Investment Bank
AD. Mr. Koskelo has long-term experience in banking and global financial markets, as well as wide
professional practice in different geographical regions.
Mr. Koskelo worked in the International Finance Corporation (IFC - a member of the World Bank Group)
for 24 years, from 1987 to late 2011. The first 13 years he worked as an Investment Officer covering
the Central and Eastern Europe and Africa regions. In 2000, he was appointed as Director Work-out
Loans and in 2004 he became Director Global Financial Markets. In 2007, he was appointed as Vice
President (reporting to the CEO) and a member of the IFC’s Management Committee. Mr. Koskelo led
the formulation and implementation of the IFC’s investment strategy, policies, and practices across
industries and regions, including in Central and Eastern Europe, Latin America and Africa. His major
legacies include IFC’s entry to Global Trade Finance Programs, decentralization of the organization with
significant staffing across emerging markets, IFC’s leading role in private sector side of Vienna Initiative
to support Central Europe banks after Lehman Crisis and establishment of IFC’s Asset Management
subsidiary’s first $3 billion fund for capitalization of weak banks in poor countries.
Prior to joining the IFC, he spent close to 10 years in senior management positions in the private sector
in the Middle East and in USA.
Mr. Koskelo currently holds senior positions in European and African organizations and institutions
including: Member of the Board of Directors of Gulf Marine Services PLC (GMS International), UK and
Member of the Board of Directors of Serengeti Energy Ltd, Mauritius.
During the period 2012 up to 2023 Mr. Koskelo acted in multiple Supervisory Board and advisory
positions including in the Africa Development Corporation, Germany; African Banking Corporation,
Botswana; RSwitch, Rwanda; EXPO Bank, Latvia, AtlasMara Co-Nvest LLC, UK, Al Jaber Group, UAE,
EXPO Bank, Czech Republic and AATIF (a KfW & EU sponsored Africa Agriculture and Trade Investment
Fund), Luxemburg.
Mr. Koskelo holds a Master of Science (M.Sc.) degree in Civil Engineering from the Technical University
of Helsinki, Finland and a Master of Business Administration (MBA) in International Finance from the
Massachusetts Institute of Technology (MIT), Sloan School of Management in Boston, USA.
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MEMBERS OF THE MANAGING BOARD
Nikola Bakalov Chief Executive Officer (CEO) and
Chairman of the Managing Board
Mr. Nikola Bakalov has extensive experience in the banking and insurance sector in Bulgaria, combined
with proven professional and managerial skills. From December 2000 to September 2011, he worked
at First Investment Bank AD, taking increasing responsibilities from Card Services Specialist to Director
of the Card Payments Department, which position he held for almost 6 years. During this period he
was also elected as member of the executive committees of Mastercard Bulgaria and VISA Bulgaria.
In the period December 2011 - August 2012, Mr. Bakalov was member of the Managing Board of Allianz
Bank Bulgaria AD, where he served as Executive Director, and subsequently as Chief Executive Officer.
From 2013 to August 2020, Mr. Bakalov was Executive Director of FiHealth Insurance AD, where he
expanded significantly the activity of the company and transformed it in a leading company in the
sphere of health insurance.
At the beginning of 2020, he was elected as Chief Retail Banking Officer (CRBO), Member of the
Managing Board and Executive Director of First Investment Bank AD, responsible for the retail banking
business lines within the Bank.
Since April 2020 Mr. Bakalov has been elected as Chief Executive Officer (CEO) and Chairman of the
Managing Board of First Investment Bank AD.
Responsibilities in the Bank Compliance function, Legal Department, Corporate Communications
Department, Marketing and Advertising Department, Human Capital Management Department,
Administrative Department, Asset Management Department, Information Technologies Department,
Sustainable Development Department, Protocol and Secretariat Department and Specialised Unit
Project Management.
Mr. Bakalov holds a Master’s degree in International Economic Relations from the University of
National and World Economy in Sofia, and has additional specializations in card payments, finance
retail services and corporate governance.
Apart from his position at the Bank, Mr. Bakalov is Deputy chairman of the Board of Directors of
FiHealth Insurance AD, Member of the Board of Directors of BORICA AD, Member of the Management
Board of Association of Banks in Bulgaria, Manager of International Banking Institute EOOD and
Member of the Trustees Council of the University of National and World Economy (UNWE).
Svetozar Popov Chief Risk Officer (CRO), Member of the Managing Board
and Executive Director
Mr. Svetozar Popov joined First Investment Bank AD in 2004 as part of the Risk Management
Department, and was shortly thereafter promoted to Head of the Credit Risk Division. From 2006 to
2008 he was Deputy Director of Risk Management, during which period he also chaired the Bank's
Credit Council. From 2016 to 2017, Mr. Popov held the office of Chief Compliance Officer (CCO), and
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in May 2017 he was appointed as Chief Risk Officer (CRO), Member of the Management Board and
Executive Director of First Investment Bank AD.
From 2008 to 2015, Mr. Popov was member of the Managing Board and Executive Director of UNIBank
AD, Northern Macedonia, where he gained significant management experience and was responsible
for the areas of risk management, credit administration, and finance. Prior to joining First Investment
Bank AD, Mr. Popov worked at Raiffeisenbank (Bulgaria) EAD as an SME loan officer.
Mr. Popov holds a Masters degree in Finance from the University of National and World Economy in
Sofia, and has obtained additional qualifications in the field of financial analysis from the European
Bank for Reconstruction and Development (EBRD) and other internationally recognized institutions, as
well as practical experience in foreign banks.
In the Bank he is responsible for the Risk Analysis and Control Department, the Credit Risk
Management, Monitoring and Provisioning Department, the Impaired Assets Department, the Loan
Administration Department, Security Department, Information Security Department and the
specialized unit Strategic Risk Management.
Besides his position in the Bank, Mr. Popov is a Chairman of the Supervisory Board of UNIBank,
Republic of Northern Macedonia, Chairman of the Board of Directors of MyFin EAD and a Manager of
Debita OOD.
Chavdar Zlatev - Chief Corporate Banking Officer (CCBO), Member of the
Managing Board and Executive Director
Mr. Chavdar Zlatev joined the team of First Investment Bank AD in 2004 as Chief specialist in the SME
Lending Department. Soon afterwards he was promoted to Deputy Director of the Department. From
2006 to 2009 he was manager of the Vitosha branch of First Investment Bank AD. He was subsequently
appointed Deputy Director of the Branch Network Department, and in 2010 promoted to Director of
the Department. In early 2011, he was appointed Director of the Corporate Banking Department, and
has participated in the development and implementation of a number of banking products. In
November 2014 Mr. Zlatev was elected member of the Managing Board of First Investment Bank AD,
and from February 2018 was appointed as Chief Corporate Banking Officer (CCBO), Member of the
Managing Board and Executive Director.
Alongside his responsibilities in the Bank for the period during 2011-August 2020 he was member of
the Board of Directors of FiHealth Insurance AD.
Prior to joining First Investment Bank AD, Mr. Zlatev worked in CB Unionbank AD as a senior bank
officer, Corporate clients. He holds a Master‘s degree in Macroeconomics from the University of
National and World Economy in Sofia. He has specialized loan products and practices in Bank of Ireland,
as well as contemporary banking practices in Banco Popolare di Verona.
Responsibilities in the Bank Large Enterprises Banking Department, Medium-sized Enterprises
Banking Department, Corporate Sales and Public Procurements Department, Financial Analysis unit,
Loan Facility Management unit, Trade Financing unit and Factoring and Leasing unit.
Besides his position with the Bank, Mr. Zlatev is a Chairman of the Management Board of First
Investment Bank Albania Sh.a.
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Ralitsa Bogoeva Chief Retail Banking Officer (CRBO),
Member of the Managing Board and Executive Director
Ms. Ralitsa Bogoeva has been Chief Retail Banking Officer, Member of the Managing Board and
Executive Director of First Investment Bank AD since May 2020. She has extensive professional
experience in various fields of banking.
Ms. Ralitsa Bogoeva joined the team of First Investment Bank AD in 2002 as a Retail Loan Officer and
a year later was promoted to Deputy Director of the Retail Banking Department, a position she held
for eight years. From 2011 to 2018 she was Director, Internal Audit of Fibank. From June 2018 to 2020,
Ms. Bogoeva held the position of Chief IT and Operations Officer at the Bank. During her professional
career, Ms. Bogoeva has managed various projects in the fields of finance, the development and
administration of products for individuals and businesses, as well as innovative projects in the field of
information technology and digitalization of banking.
Ms. Bogoeva has a Master's degree in Accounting and Control from the University of National and
World Economy in Sofia, as well as a number of additional qualifications in the areas of banking,
international auditing standards, planning and project management.
Responsibilities in the Bank Retail Banking Department, Private Banking Department, Digital Banking
Department, Card Payments Department, Branch Network Department, Organisation and Control of
Customer Service Department, Gold and Commemorative Coins Department, the Vault.
In addition to her position in the Bank, Ms. Bogoeva is a member of the Board of Directors of Diners
Club Bulgaria AD, a member of the Board of Directors of MyFin EAD and a member of the Supervisory
Board of UNIBanka AD, Northern Macedonia. She owns 25% of the capital of Raya Homes OOD.
Ianko Karakolev Chief Financial Officer (CFO) and
Member of the Managing Board
Mr. Ianko Karakolev was elected Chief Financial Officer (CFO) and Member of the Managing Board of
First Investment Bank AD in June 2020. He is a longtime financial analyst and staff member of First
Investment Bank AD.
Mr. Karakolev joined the Bank's team in 1999 as an accountant-controller in the Financial and
Accounting Department and soon became Director of the Internet Branch. In the period 2002-2007 he
was promoted from Head of the Financial Statements, Analyzes and Budgeting unit to Deputy Chief
Accountant. After that, until 2011, he held the position of Deputy Director of the Finance and
Accounting Department. From 2011 to 2014 he was Chief Financial Officer and Director of the Finance
and Accounting Department, and in the period 2014-2020 was Director of the Finance Department.
During his professional career, Mr. Karakolev has participated in the management of many innovative
projects contributing to the implementation of international standards and the development of
banking, as well as in corporate actions such as the acquisition of MKB Unionbank and its subsequent
merger with First Investment Bank AD.
Prior to joining the team of First Investment Bank AD, Mr. Karakolev worked at Bulgarian Commercial
and Industrial Bank AD as an accountant. He holds a Master's degree in Finance from the University of
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National and World Economy in Sofia and has professional certificates and qualifications in the fields
of international financial and accounting standards, the European regulatory framework on banking
and reporting, management and business planning.
Responsibilities in the Bank Finance Department, Accounting Department, Treasury Department,
Investor Relations Department, Financial Institutions and Corresponding Banking Department and
Intensive Loan Management Department.
In addition to his position in the Bank, Mr. Karakolev is a member of the Steering Council of First
Investment Bank - Albania Sh.a. and member of the Supervisory Board of UNIBanka AD, Northern
Macedonia.
Nadia Koshinska Member of the Managing Board and Director of Small
Enterprises Banking Department
Ms. Nadia Koshinska joined Fibank in 1997 as a corporate loan expert. In 2002, she was appointed
Deputy Director Loan Administration and held this position until 2004. In 2004 Nadia Koshinska was
appointed Director SME Lending Department responsible for increasing the market share of the Bank
through implementing special programs and dedicated products for SMEs. Also in 2004, she was
appointed as a member of the Credit Council. At the end of 2015, Ms. Koshinska was elected as Chief
Retail Banking Officer (CRBO) and Member of the Managing Board, while since September 2017 is a
Member of the Managing Board and Director of SME Banking Department.
Prior to joining First Investment Bank AD she worked in the balance of payments and foreign debt
division in Bulgarian National Bank.
Ms. Nadia Koshinska holds a Masters degree in Accounting and Control from the University of National
and World Economy in Sofia.
In the Bank she is responsible for the Small Enterprises Banking Department.
Ms. Koshinska does not hold outside professional positions.
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LIST OF ABBREVIATIONS
AD
Joint Stock Company
ALCO
Asset, liability and Liquidity management Council
AML
Anti Money Laundering
ATM
Automated Teller Machine
BAF
Bulgarian Athletics Federation
Bank/Fibank
First Investment Bank AD
BEIA
Bulgarian Export Insurance Agency
BISERA
Bank integrated system for electronic payments
BISERA 7-EUR
System for servicing customer transfers in euros
BNB
Bulgarian National Bank
BOC
Bulgarian Olympic Committee
BORICA
Banking organization for payments using cards
BRGF
Bulgarian Rhythmic Gymnastics Federation
BPM
Business Process Management
BRRD II
Bank Recovery and Resolution Directive II (Directive (EU) 2019/879 of the
European Parliament and of the Council of 20 May 2019 amending Directive
2014/59/EU as regards the loss-absorbing and recapitalisation capacity of
credit institutions and investment firms and Directive 98/26/EC)
CAGR
Compound Annual Growth Rate
CEO
Chief Executive Officer
СЕТ1
Common Equity Tier 1
CCBO
Chief Corporate Banking Officer
CFO
Chief Financial Officer
CGS
Continuous Gross Settlement
CO2
Carbon footprint
CRBO
Chief Retail Banking Officer
CRO
Chief Risk Officer
CSRBB
Credit Spread Risk in the Banking Book
DvP
Delivery versus Payment (Доставка срещу плащане)
DPO
Data Protection Officer
EAD
Еxposure at Default
EAD
Sole-owned joint stock company
EBA
European Banking Authority
EEA
European Economic Area
EC
European Commission
ECB
European Central Bank
EOOD
Sole-owned limited liability company
ЕP
European Parliament
ERM
Exchange Rate Mechanism
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ЕSG
Environmental, Social, Governance
ESMA
European Securities and Markets Authority
ЕU
European Union
FDI
Foreign Direct Investments
FSC
Financial Supervision Commission
GDP
Gross domestic product
GDPR
General Data Protection Regulation
GVA
Gross value added
HIC
Health insurance company
HHI
Herfindahl-Hirschman Index
ICAAP
Internal Capital Adequacy Assessment Process
IFRS
International Financial Reporting Standards
ILAAP
Internal Liquidity Adequacy Assessment Process
IFC
International Finance Corporation
IRRBB
Interest Rate Risk in the Banking Book
IT
Information Technology
ITP
Internal-transfer prices
LCR
Liquidity Coverage Ratio
LIFO
Law on independent financial audit
LGD
Loss Given Default
LPOSA
Law on public offering of securities
LR
Leverage Ratio
LRE
Leverage Risk Exposure
MB
Managing Board
MiFIR
Markets in Financial Instruments Regulation (Regulation (EU) No 600/2014 of
the European Parliament and of the Council of 15 May 2014 on markets in
financial instruments and amending Regulation (EU) No 648/2012)
MREL
Minimum requirements for own funds and eligible liabilities
MRR
Minimum Required Reserved
NАТО
North Atlantic Treaty Organization
NFC
Near Field Communication
NPE
Non-performing exposures
NPL
Non-performing loans
NSFR
Net Stable Funding Ratio
OECD
Organization for Economic Cooperation and Development
OOD
Limitied liability company
OSII
Other Systemically Important Institution
PAMP
Produits Artistiques de Métaux Précieux
PD
Probability of Default
Activity Report 2023
on an individual basis
FIRST INVESTMENT BANK
135/142
PRIIPS
Packaged Retail Investment and Insurance Products (Regulation (EU) No
1286/2014 of the European Parliament and of the Council of 26 November
2014 on key information documents for packaged retail and insurance-based
investment products)
RCSA
Risk Control Self Assessment
RINGS
Real-time Interbank Gross Settlement System
ROA
Return-on-assets
ROE
Return-on-equity
SB
Supervisory Board
SCA
Strong Customer Authentication
SEPA
Single Euro Payments Area
SME
Small and medium-sized enterprises
SP
Sole proprietor
SPPI
Solely Payments of Principal and Interest
SRM
Single Resolution Mechanism
SSM
Single Supervisory Mechanism
ТСR
Тotal Capital Ratio
TPPs
Third party providers
TREA
Total Risk Exposure Amount
UAB
Union of Artists in Bulgaria
UN
United Nations
VaR
Value-at- Risk
Activity Report 2023
on an individual basis
FIRST INVESTMENT BANK
136/142
LIST OF BRANCH NETWORK
HEAD OFFICE
Sofia 1784, 111P, Tsarigradsko shose Blvd.
Phone: 02/817 1100, fax: 02/817 1101
SWIFT CODE: FINVBGSF
REUTERS DEALING CODE: BFIB
e‐mail: fib@fibank.bg, www.fibank.bg
Contact centre: 0800 11 011
BRANCHES IN SOFIA
Aleksandar Stamboliyski
Sofia 1301, 20, Aleksandar Stamboliyski Blvd.
phone: (+359 2) 817 1493
Bulgaria
Sofia 1404, 81G Bulgaria Blvd.
phone: (+359 2) 800 2501, fax: (+359 2) 800
2500
Business Park Sofia
Sofia 1712, 1, Business Park Sofia St.
phone: (+359 2) 800 2535
Dragalevtsi
Sofia 1415, Zh.k. (Quarter) Dragalevtsi
20A, Krushova gradina St.
phone: (+359 2) 800 2601
Evropa
Sofia 1528, 7, Iskarsko shose Blvd.
phone: (+359 2) 817 1454
Generali
Sofia 1000, 79‐81, Dondukov Blvd.
phone: (+359 2) 817 1437
Hadzhi Dimitar
Sofia 1510, 28‐30, Doncho Vatah St.
phone: (+359 2) 817 1576
Hristo Botev
Sofia 1000, 28 Hristo Botev Blvd.
phone: (+359 2) 800 2645
Iliyantsi
Sofia 1268, 31, Rozhen Blvd.
phone: (+359 2) 800 2973
Journalist
Sofia 1164, 44, Hristo Smirnenski Blvd.
phone: (+359 2) 800 2939
Krasna Polyana
Sofia 1330, Nikola Mushanov Blvd., bl. 31A,
floor 1
phone: (+359 2) 800 2665
Krasno selo
Sofia 1612, 107 A, Tsar Boris III Blvd.
phone: (+359 2) 800 25 84
Lyulin
Sofia 1324, 70, Tsaritsa Yoanna Blvd.
phone: (+359 2) 817 1483
Mall – Sofia
Sofia 1303, 101, Aleksandar Stamboliyski Blvd.
phone: (+359 2) 817 1672
Maria Luisa
Sofia 1202, 67, Maria Luisa Blvd.
phone: (+359 2) 817 1463
Mladost
Sofia 1784, 11, Andrey Saharov Blvd.
phone: (+359 2) 817 1641
Mall – Serdika
Sofia 1505, 48, Sitnyakovo Blvd.
phone: (+359 2) 800 2550
Nadezhda 2
Sofia 1220, 7, Strazhitsa St., 1st floor
phone: (+359 2) 800 2521
Narodno sabranie 1
Sofia 1000, 12, Narodno sabranie Sq.
phone: (+359 2) 817 1559
Narodno sabranie 2
Sofia 1000, 3, Narodno sabranie Sq.
phone: (+359 2) 817 1359
National Theatre
Sofia 1000, 7, Dyakon Ignatiy St.
phone: (+359 2) 817 1421
NDK (National Palace of Culture)
Sofia 1000, 110, Vitosha Blvd.
phone/fax: (+359 2) 800 2641
Activity Report 2023
on an individual basis
FIRST INVESTMENT BANK
137/142
Nevski
Sofia 1504, 1, Yanko Sakazov Blvd
phone: (+359 2) 800 2542
Obelya
Sofia 1387, 58A, Akademik Dimitri Lihachov Blvd.
phone: (+359 2) 800 2091
Ovcha kupel
Sofia 1632, 51, Montevideo St.
phone: (+359 2) 800 2525
Paradise Center
Sofia 1407, 100, Cherni vrah Blvd.
phone: (+359 2) 800 2545
Park Center
Sofia 1421, 2, Arsenalski Blvd.
phone: (+359 2) 817 1666
Patriarch Evtimiy
Sofia 1000, 36, Patriarch Evtimiy Blvd.
phone: (+359 2) 800 2622
Shipchenski prohod
Sofia 1111, 49, Shipchenski prohod Blvd.
phone: (+359 2) 800 2958
Slatina
Sofia 1574, Satinska St., bl. 20
phone: (+359 2) 800 2839
Sofia Mega Mall
Sofia 1324, 15, Tzaritza Yoanna Blvd.
phone: (+359 2) 800 2510
Sofia Ring Mall
1434 Sofia, 214, Okolovrasten pat St.
Phone: (+359 2) 800 2583
Sofia Theatre
Sofia 1527, Yanko Sakazov Blvd.
phone: (+359 2) 800 2825
The Mall
Sofia 1784, 115, Tsarigradsko Chaussee Blvd. „Z“
phone/fax: (+359 2) 800 2538
Vitosha
Sofia 1408, 4, Mayor Parvan Toshev St.
phone: (+359 2) 942 6666
Yuzhen park (South Park)
Sofia 1404, Gotse Delchev Blvd., bl. 1
phone: (+359 2) 800 2975
Zaharna Fabrika
Sofia 1309, 127, Slivnitsa Blvd.
phone: (+359 2) 817 1586
BRANCHES IN THE COUNTRY
Asenovgrad
Asenovgrad 4230, 3, Nikolay Haytov Sq.
phone: (+359 331) 20 092
Bansko
Bansko 2770, 68, Tsar Simeon St.
phone: (+359 749) 86 183, fax: (+359 749)
88 112
Strazhite – Bansko
Bansko 2770, 7, Glazne St.
phone: (+359 749) 86 986
Belene
Belene 5930, 2, Ivan Vazov St.
phone: (+359 658) 38 411
Belitsa
Belitsa 2780, 12 Georgi Andreichin str.
Phone: (+359 749) 86 199
Blagoevgrad
Blagoevgrad 2700, 11, St.St. Kiril i Metodiy Blvd.
phone: (+359 73) 827 709
GUM – Blagoevgrad
Blagoevgrad 2700, 6, Trakia St.
phone: (+359 73) 827 756
Rila Hotel – Borovets
Borovets 2010, Rila Hotel
phone: (+359 2) 800 2549
Botevgrad
Botevgrad 2140, 5, Osvobozhdenie Sq.
phone: (+359 723) 69 046
Burgas
Burgas 8000, 58, Aleksandrovska St.
phone: (+359 56) 800 138
Bratya Miladinovi – Burgas
Burgas 8000
Zh. k. (Quarter) Bratya Miladinovi, bl. 117, entr. 5
phone: (+359 56) 804 463
Activity Report 2023
on an individual basis
FIRST INVESTMENT BANK
138/142
Kiril i Metodiy – Burgas
Burgas 8000, 71, Slavyanska St.
phone: (+359 56) 804 482
Meden rudnik – Burgas
Burgas 8011
Zh. k. (Quarter) Meden rudnik, zone B, bl. 192
phone: (+359 56) 804 442
Slaveykov – Burgas
Burgas 8005
Zh. k. (Quarter) Slaveykov, bl. 107, entr. 2
phone: (+359 56) 804 472
IRM PZ Devnya
9160 Devnya, Industrial Zone South
phone: (+359 52) 662 755
Dimitrovgrad
Dimitrovgrad 6400, 6, Tsar Simeon St.
phone/fax: (+359 391) 67 008
Dobrich
Dobrich 9300, 1, Nezavisimost Sq.
phone: (+359 58) 838 590
Dulovo
Dulovo 7650, 6, Vasil Levski St.
phone: (+359 864) 21 180
Dupnitsa
Dupnitsa 2600, 19, Hristo Botev St.
phone: (+359 701) 59 153
Gabrovo
Gabrovo 5300, 5, Vazrazhdane Sq.
phone: (+359 66) 819 444
Gorna Oryahovitsa
Gorna Oryahovitsa 5100, 1, St. Knyaz Boris I St.
phone: (+359 618) 61 766
Gotse Delchev
Gotse Delchev 2900, 41, Targovska St.
phone: (+359 751) 69 642
FC Harmanli
Harmanli 6450, 1, Vazrazhdane Sq.
phone: (+359 373) 88 684
Haskovo
Haskovo 6304, 7, San Stefano Blvd.
phone: (+359 38) 661 848
Kardzhali
Kardzhali 6600, 52, Bulgaria Blvd.
phone: (+359 361) 21 629
Karlovo
Karlovo 4300, 6, General Kartsov St.
phone: (+359 335) 90 799
Kazanlak
Kazanlak 6100, 11, Sevtopolis Sq.
phone: (+359 431) 67 078
AER – Kozloduy
Kozloduy 3321, Nuclear Power Station,
phone: (+359 973) 89 320
Kozloduy
Kozloduy 3320, 1V, Vasil Vodenicharski St.
phone: (+359 973) 85 020
Kyustendil
Kyustendil 2500, 147, Tsar Osvoboditel Blvd.
phone: (+359 78) 558 144
Levski
Levski 5900, 40, Aleksandar Stamboliyski St.
phone: (+359 650) 88 909
Lovech
Lovech 5500, 12, Targovska St.
phone: (+359 68) 689 612
Montana
Montana 3400, 74, 3‐ti Mart Blvd.
phone: (+359 96) 399 516
Nesebar
Nesebar 8230, 9, Ivan Vazov St.
phone: (+359 554) 46 055
Novi pazar
Novi pazar 9900, 4, Rakovski Sq.
phone/fax: (+359 537) 25 222
FC Omurtag
Omurtag 7900, 1, 28 January St.
phone: (+359 605) 61 043
Pazardzhik
Pazardzhik 4400, 11, Bulgaria Blvd.
phone: (+359 34) 403 644
Activity Report 2023
on an individual basis
FIRST INVESTMENT BANK
139/142
Pernik
Pernik 2300, 1, Rayko Daskalov St.
phone: (+359 76) 688 613
FC Peshtera
Peshtera 4550, 13, 3rd March St.
phone: (+359 350) 60 702
Petrich
Petrich 2850, 11A, Tsar Boris III St.
phone: (+359 745) 69 577
Pleven
Pleven 5800, 138, Doyran St.
phone: (+359 64) 893 101
Vasil Levski – Pleven
Pleven 5800, 126, Vasil Levski St.
phone: (+359 64) 893 141
6th september – Plovdiv
4002 Plovdiv, 35, 6th september Blvd.
Phone: (+359 32) 270 783
Mall – Plovdiv
Plovdiv 4002, 8, Perushtitsa St.
phone: (+359 32) 270 630
Mall Trakia – Plovdiv
Plovdiv 4023, 41, Saedinenie Blvd.
phone: (+359 32) 270 580
Plovdiv
Plovdiv 4000, 95, Maritsa Blvd.
phone: (+359 32) 270 510
Skopie – Plovdiv
Plovdiv 4004, Skopie St., bl. 1519
phone: (+359 32) 270 590
Sveti Mina – Plovdiv
Plovdiv 4000, 56, Kapitan Raycho St.
phone: (+359 32) 270 560
Primorsko
Primorsko 8180, 82A, Treti mart St.
phone: (+359 550) 31 000
Radnevo
Radnevo 6260, 3, Georgi Dimitrov St.
phone: (+359 426) 98 764
Razgrad
Razgrad 7200, 3, Vasil Levski St.
phone: (+359 84) 631 065
FC Razlog
Razlog 2760, 6, Sheynovo St.
phone: (+359 747) 80 177
Aleksandrovska – Ruse
Ruse 7000, 10, Aleksandrovska St.
phone: (+359 82) 889 534
Ruse
Ruse 7000, 11, Rayko Daskalov St.
phone: (+359 82) 889 541
Tezhko mashinostroene – Ruse
Ruse 7000, 100, Tutrakan Blvd.
phone: (+359 82) 889 551
Tsar Osvoboditel – Ruse
Ruse 7000, 1, Tsar Osvoboditel Blvd.
phone: (+359 82) 889 498
Sevlievo
Sevlievo 5400, Svoboda Sq.
phone: (+359 675) 31 053
Shumen
Shumen 9700, 67, Simeon Veliki Blvd.
phone: (+359 54) 856 611
Silistra
Silistra 7500, 3, Geno Cholakov St.
phone: (+359 86) 871 320
Simitli
Simitli 2730, 27, Hristo Botev St.
phone: (+359 747) 89 051
Slanchev bryag (Sunny Beach)
Slanchev bryag (Sunny Beach) 8240, Central Alley
phone: (+359 554) 23 335
Central – Sliven
Sliven 8800, 2, Hadzhi Dimitar Blvd.
phone: (+359 44) 610 954
Sliven
Sliven 8800, 50, Tsar Osvoboditel Blvd.
phone: (+359 44) 610 708
Activity Report 2023
on an individual basis
FIRST INVESTMENT BANK
140/142
Smolyan
Smolyan 4700, 80V, Bulgaria Blvd.
phone: (+359 301) 67 020
Sozopol
Sozopol 8130, 7, Republikanska St.
phone: (+359 550) 25 191
FC Stara Zagora 2
74, Tsar Simeon Veliki Blvd.
phone: (+359 42) 611 964
Stara Zagora
Stara Zagora 6000, 104, Tsar Simeon Veliki Blvd.
phone: (+359 42) 698 813
Trayana – Stara Zagora
Stara Zagora 6000, 69, Tsar Simeon Veliki Blvd.
phone: (+359 42) 698 771
Tsar Simeon – Stara Zagora
Stara Zagora 6000, 141, Tsar Simeon Veliki Blvd.
phone: (+359 42) 698 752 ,
fax: (+359 42) 266 021
Svilengrad
Svilengrad 6500, 58, Bulgaria Blvd.
phone: (+359 379) 74 440
Svishtov
Svishtov 5250, 1, Nikola Petkov St.
phone: (+359 631) 61 171
Targovishte
Targovishte 7700, 46, Hristo Botev St.
phone: (+359 601) 69 530
FC Troyan
14, Vasil Levski St.
phone: (+359 670)60 443
Troyan
Troyan 5600, 108, Vasil Levski St.
phone: (+359 670) 60 040
8‐mi Primorski polk – Varna
Varna 9000, 128, 8‐mi Primorski polk Blvd.
phone: (+359 52) 662 624
Breeze – Varna
Varna 9000, 80‐82, 8‐mi Primorski polk Blvd.
phone: (+359 52) 662 731
FC Mall Varna
Varna 9009, 186 Vladislav Varnenchik Blvd.
phone: (+359 52) 662 699
Rayonen sad (Regional Court) – Varna
Varna 9000, 57, Vladislav Varnenchik Blvd.
phone: (+359 52) 662 666
Tsaribrod – Varna
Varna 9000, 2, Dunav St.
phone: (+359 52) 662 721
Varna
Varna 9000, 113, General Kolev Blvd.
phone:(+359 52) 662 600
Bacho Kiro – Veliko Tarnovo
Veliko Tarnovo 5000, 5, Bacho Kiro St.
phone: (+359 62) 682 436
Veliko Tarnovo
Veliko Tarnovo 5005, 18, Oborishte St.
phone: (+359 62) 614 464
Vidin
Vidin 3700, 17, Gradinska St.
phone: (+359 94) 605 522
Vratsa
Vratsa 3000, 1, Nikola Voyvodov St.
phone: (+359 92) 669 310
Yambol
Yambol 8600, 10, Osvobozhdenie Sq.
phone: (+359 46) 682 363
Zlatitsa
Zlatitsa 2080, 2, Medet St.
phone: (+359 728) 68 046
BRANCHES OUTSIDE BULGARIA
Cyprus International Banking Unit
130 Limassol Ave., CY‐2015 Nicosia, Cyprus
P.O.Box 16023, CY‐2085 Nicosia, Cyprus
phone: (+357 22) 376 454
fax: (+357 22) 376 560
SWIFT CODE: FINVCY2N
Activity Report 2023
on an individual basis
FIRST INVESTMENT BANK
141/142
The present Individual Activity report for 2023 was approved by the Managing Board of First
Investment Bank AD in accordance with the Bank’s internal regulations at a meeting dated
12 March 2024.
Signed Signed
Nikola Bakalov
Chief Executive Officer,
Chairman of the Managing Board
Signed
Svetozar Popov
Executive Director,
Chief Risk Officer,
Member of the Managing Board
Signed
Chavdar Zlatev
Executive Director,
Chief Corporate Banking Officer,
Member of the Managing Board
Ralitsa Bogoeva
Executive Director,
Chief Retail Banking Officer,
Member of the Managing Board
Signed
Ianko Karakolev
Chief Financial Officer,
Member of the Managing Board
Chavdar Zlatev
Executive Director,
Chief Corporate Banking Officer,
Member of the Managing Board
Chavdar Zlatev
Executive Director,
Chief Corporate Banking Officer,
Member of the Managing Board
Activity Report 2023
on an individual basis
FIRST INVESTMENT BANK
142/142
DECLARATION
under Art. 100о, para. 4(4) of the Public Offering of Securities Act (POSA)
The undersigned Nikola Hristov Bakalov, Chief Executive Officer and Chairman of the
Managing Board of First Investment Bank AD, Svetozar Alexandrov Popov, Executive Director
and Member of the Managing Board of First Investment Bank AD, Chavdar Georgiev Zlatev,
Executive Director and Member of the Managing Board of First Investment Bank AD, Ralitsa
Ivanova Bogoeva, Executive Director and Member of the Managing Board of First Investment
Bank AD and Ianko Angelov Karakolev, Chief Financial Officer and Member of the Managing
Board at First Investment Bank AD, hereby declare that to the best of our knowledge:
The financial statements of First Investment Bank AD as at 31 December 2023, prepared
in accordance with the applicable accounting standards, give a true and fair view of the
assets and liabilities, financial position and profit of First Investment Bank AD.
The annual report of First Investment Bank AD as at 31 December 2023 contains a fair
review of the development and results from the activities of First Investment Bank AD.
Signed Signed
_____________________ _____________________
Nikola Bakalov Svetozar Popov
Chief Executive Officer Executive Director
Chairman of MB Member of MB
Signed Signed
_____________________ _____________________
Chavdar Zlatev Ralitsa Bogoeva
Executive Director Executive Director
Member of MB Member of MB
Signed
_____________________
Ianko Karakolev
Chief Financial Officer
Member of MB
12 March 2024
Sofia
INFORMATION
ON
FIRST INVESTMENT BANK AD
FOR 2023
The present information is prepared pursuant to Art.10, p.2 from Ordinance No.2 of the Financial
Supervision Commission from 09.11.2021 on the initial and subsequent disclosure of information
when securities are offered to the public or admitted to trading on a regulated market.
Information on
FIRST INVESTMENT BANK AD
for 2023
Page 2 of 3
1. Information on the securities, which are not admitted to trade on a
regulated market in the Republic of Bulgaria or another Member State.
As at 31.12.2023 First Investment Bank had issued one hybrid instrument (bond issue) with original
principal in the amount of EUR 10 million (ISIN: XS2488805461), included in the additional Tier 1
capital of the Bank, which is not admitted to trade on a regulated market in the Republic of Bulgaria
or another Member State. As at 31.12.2023 the amortised cost of the issued hybrid instrument
amounted to BGN 19,603 thousand.
2. Information on the direct and indirect holding of 5 per cent or more of the
voting rights in the general meeting of the company, including information
on the shareholders and the number of shares held.
The shareholders holding 5% or more of the share capital of First Investment Bank as at 31 December
2023 are, as follows:
number / % of total
Number of
shares
% held
Mr. Ivailo Dimitrov Mutafchiev
46,750,000
31.36%
Mr. Tzeko Todorov Minev
46,750,000
31.36%
Bulgarian Development Bank AD
27,350,000
18.35%
Valea Foundation
11,734,800
7.87%
At 31 December 2023 16,500,000 shares (11.06% of share capital) are traded freely at the Bulgarian
Stock Exchange AD (free-float).
3. Information on shareholders with special controlling rights and description
of such rights.
No shareholders have special controlling rights.
4. Agreements between shareholders which are known to the company and
may lead to restrictions in the transfer of shares or voting rights.
No such agreements are known to the company.
Information on
FIRST INVESTMENT BANK AD
for 2023
Page 3 of 3
5. Significant contracts signed by the company which require action or which
are amended or terminated due to a change in control of the company when
carrying out a mandatory tender offer, and the consequences thereof,
except where the disclosure of such information may cause serious damage
to the company; this exception shall not apply where the company is
obliged to disclose such information by law.
No such contracts exist.
Scorecard / Evaluation form for Corporate governance in Bulgaria
Evaluation's method for the companies with two tier governance structure
Based on the Methodology, developed by Christian Strenger
Notes about the methodology
Based on the National code for corporate governance in its' version from April 2016
The detached criterias refer to the corresponding chapters of the code
The execution's degree of every point is determined by marking in the field column (1)
Weight of the questions: Standart evaluation is checked in column (2)
The summarized results are described as a value of different criteria with common result in (3)
In case of need the source of information should be noticed in column "Source of information"
The astonishings before every criteria disappear, when it is marked the corresponding field in column (1)
The card has to be signed by personality with representing authority in the company
Name of the issuer: First investment bank AD
Date of completion 12 March 2024
Chose the governance system of the company One tier system
Two tier system
The card is developed in 2 types depending on the governance system, as the company fulfills the type, which corresponds to its governance system
Scorecard / Evaluation form for Corporate governance in Bulgaria
Evaluation's method for the companies with two tier governance structure
Source of information
1 0.5 0
Please, point the way of the requirement's execution
yes partial no
When the execution is not in full compliance, please point the reasons
I.
10%
I.1
Do the structure and the distribution of the tasks to the members on
the Management Board guarantee the effective performance of the
company?
1
10%
10.0%
The members and functions of MB are structured according to the statutes and
Corporate governance code. First investment bank functions with an organizational
structure, built in accordance with the good international standards in the area of
corporate governance, the EBA Guidelines and the principles of Basel commitee in
this area.
I.2
Do the compliance principles observed for competence level of the
candidates, by offer of choise of new members of the Management
Board, with the character of the company' s activity?
1
15%
15.0%
First investment bank has a Policy for nomination and assessment of the suitability
of the members of the managing and supervisory bodies and persons holding
other positions, which is in compliance with the regulatory requirements, activities
of the bank and development plans. In the bank works a Nomination Commitee,
which assists the Supervisory Board in assessing the individual and collective
suitability of members of the Supervisory Board and Managing Board, as well as
assesses the suitability of the key function and other holders in the Bank, in
compliance with the applicable legal provisions in this sphere.
I.3
In the contracts for assignment of the management, concluded with
the members of the Management board are determined their
obligations and tasks, the criteria of the size of their remuneration,
their obligations for loyality to the company and the reasons for
release?
1
15%
15.0%
In the contracts are included the total obligations, stipulated is the fixed
remuneration, as well as the payed expense in connection with the activity, incl.
such as health insurance, insurance, compensations and with respect to the
additional remunerations they are referred to the internal policies and rules of the
Bank. There are stipulated also the principles of loyalty, as well as the reasons for
termination of the contract.
I.4
Does the remuneration of the members of the Management Board
consist of basic salary and variable incentives?
1
15%
15.0%
First investment bank applies a Remuneration policy in compliance with the
regulating requirements, where the main principles in formation of remunerations
are regulated, as the goal of the Bank is the optimal structuring in accordance with
the functions and depending on the staff categories.
I.5
Are the additional incentives for the members of Management board
concrete appointed / appointable?
1
15%
15.0%
The principles for formation of remunerations in the Bank are structured so, that
they contribute to resonable and prudent corporate governance and reliable and
effective risk management.
I.6
Are the additional incentives for the members of Management board
bound by clear and concrete criteria and indicators for the results of
the company and / or by the achievement of preliminary
determinated by the Supervisory board goals? Describe the
connection between the additional incentives for the members of the
Management board and the achieved results of the company or other
criteria and/or aims determined by the Supervisory board.
1
15%
15.0%
In compliance with the Remuneration policy the variable remuneration, if such is
payed, is based on the results of the activity and achieved goals, having in mind
the economic cycle, the level of time horizon of the undertaken risks, the price of
capital and the necessary liquidity. It is given on the base of evaluation criteria for
the execution of the activity, which includes the appropriate combination of
financial (quantitative) and non-financial (qualitative) criteria, incl. execution of the
budget, achievement of purpose levels of profit, capital adequacy and
effectiveness, achievement of strategic goals, hold up to the Bank risk
management policy, customers satisfaction, observing of internal rules, initiative,
motivation and others.
Number of
points (3) = (1)
× (2)
Standart note
Criteria
Execution (1)
Standart note
(2)
Management board
© Scorecard for Corporate Governance of Bulgaria (according to the Bulgarian National Code of Corporate Governance 2007)
Page 2 of 10
I.7
Is provided to the share holders approach to the information for deals
between the company and the members of Management board and
connected with it persons? Indicate the concrete place and the
order, eventual - the web page of the company, on which it can
obtain the above described information.
1
15%
15.0%
Information for deals with connected persons, incl. persons that control or manage
the Bank is published in the financial reports, which are published on the corporate
webpage of the Bank: www.fibank.bg
100%
100%
II.
10%
II.1
Is regulated in the organization acts the number of independent
members and the tasks' distribution between them?
1
10%
10.0%
The requirements for independent members of Supervisory board are regulated in
the Statute, Corporate governance code and Rules for the activity of Supervisory
board, as the requirement for 1/3 of the members of the Supervisory Board to be
independent members, which is applicable to significant banks and public
companies is met.
II.2
Are there appointed requirements for suitable knowledge and
experience for the members of Supervisory board, corresponding to
the position, which they hold? Indicate the specific place and order,
possibly - the webpage of the company, in which are determinated
the requirements for suitable knowledge and experience to the
members of Management board.
1
10%
10.0%
The requirements for suitable knowledge and experience, reliability and suitability
to the members of Supervisory board are regulated in the Statute, Corporate
governance code, Policy for nomination and assessment of the suitability of the
members of the managing and supervisory bodies and persons holding other
positions and Rules for the activity of Supervisory board in compliance with the
regulatory requirements. The Statute and Corporate governance code are
published on the corporate webpage of the Bank: www.fibank.bg
II.3
Do exist any determinated requirements for observing the principles
of continuity and stability of work of Supervisory board by the
elections of its members?
1
5%
5.0%
The requirements for continuity and stability in the elections of members of SB are
regulated in the Policy for nomination and assessment of the suitability of the
members of the managing and supervisory bodies and persons holding other
positions and the Rules for the activity of SB. In succession planing the Bank
takes into account the principles for avoiding simultaneous replacement of too
many members, applying phasing out practices, compliance with temporary
appointment requirements and taking into account the diversity policy.
II.4
Is limited the number of consecutive mandates of the independent
members?
1
5%
0.0%
Pursuant to the Bank's Statute, the members of SB could be re-elected for next
mandates without restrictions.
II.5
Is there at least one member of the Supervisory bord, who has
financial competence? Point the webpage of the company, where
could be found information for the competency of every member of
the supervisory board.
1
10%
10.0%
The SB members have high professional, incl. financial competences. Information
for the professional experience and competences of the members of Supervisory
board is included in the Annual activity report, as well as on the corporate webpage
of the Bank: www.fibank.bg
II.6
Is there established praxis the new members of the Supervisory
board to be introduced with the basic legal and financial questions,
connected with the activity of the company?
1
10%
10.0%
Pursuant to the Rules for activity of Supervisory board when elected, every
member of the Supervisory Board participates in introducing program, which
includes the common financial and legal questions, the financial reporting on
behalf of the Bank, concrete specifics for the Bank and its economic activity, as
well as the responsibilities of every member of Supervisory Board. The Bank has in
place Program for introductory and training of the members of the MB and SB,
which is integral part of the Policy for nomination and assessment of the suitability
of the members of the managing and supervisory bodies and persons holding
other positions. It includes information on the adopted governance policies and
internal rules, incl. on the Bank's structure, business model and risk profile and is
presented to each new member of MB or SB up to 1 month after election.
Supervisory board
© Scorecard for Corporate Governance of Bulgaria (according to the Bulgarian National Code of Corporate Governance 2007)
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II.7
Does the education of the members of Supervisory board
encouraged? Indicate the actions, connected with increasing
qualification of someone or every members of the Supervisory board
during the last year?
1
10%
10.0%
In accordance with the Program for introductory and training of the members of the
MB and SB (integral part of the Policy for nomination and assessment of the
suitability of the members of the managing and supervisory bodies and persons
holding other positions), based on suitability assessment (individual and collective)
the areas with need of training shall be targetted, as well as taken into account the
changes in management, strategic changes, new products and technologies,
changes in applicable regulations and market development. During 2023
presentations have been organized related to changes in regulatory requirements,
incl. on capital and prudential requirements, interest rate risk in the banking book,
digital operational resilience, ESG stress tests.
II.8
Is in the organizational acts of the company regulated the number of
companies in which the members of Supervisory board could hold
management positions? Point the document and the specific text, in
which are determinated the requirements for the number of
companies, in which the members of the Supervisory board hold
management positions.
1
10%
10.0%
As per the Rules for the activity of SB, the members of Supervisory Board shall
limit the holding of other positions, so to guarantee, that they can fulfill their
obligations as members of the Supervisory Board. Without the approval of the
Supervisory Board they shall not have the right to have more than a specific
number of memberships in boards in other companies. Pursuant to the Policy for
nomination and assessment of the suitability of the members of the managing and
supervisory bodies and persons holding other positions, limitations are included on
the number od directorship positions as specified in the Ordinance No 20 of the
BNB on Issuance of Approvals to Members of the Management Board (Board of
Directors) and Supervisory Board of a Credit Institution and Performance
Requirements for Their Duties.
II.9
Do the independent members of Supervisory board receive only
basic remuneration without additional incentives?
1
5%
5.0%
Pursuant to the Remuneration policy, the members of Supervisory board receive
predominantly fixed remuneration.
II.10
Does the remuneration of the independent members of Supervisory
board influence their participation in meetings, the fulfillment of their
tasks to control the actions of executive management and their
effective participation in the activity of the company? Indicate the
specific place and order, possibly the webpage of the company,
describing the connection between the remuneration of independent
directors and the functions executed by them.
1
5%
5.0%
The remuneration of the members of Supervisory Board is defined by the General
meeting of the shareholders in compliance with the Remuneration policy of the
Bank, as the participation in committees and the execution of the duties is taken
into account when determining of individual remunerations.
II.11
Does the company follows the principle of non-compensation of the
members of Supervisory board with shares and options?
1
5%
5.0%
The remuneration of the members of Supervisory Board is structured in
compliance with the applicable regulations for credit institutions and the
Remuneration policy of the Bank, with the members of the Supervisory Board
receiving predominantly fixed remuneration.
II.12
Is ensured access for the shareholders to information for deals
between the company and the members of Supervisory board and
connected persons with it? Describe the procedure and the place,
possibly the webpage of the company, where could be obtained
information for the deals between the company and the members of
Supervisory board and the connected with it persons.
1
10%
10.0%
The information for deals with connected persons, incl. the persons that control or
manage the Bank, is published in the financial reports, which are published on the
corporate webpage: www.fibank.bg
II.13
Does the procedures for elections of new members report the
requirements for continuity and stability of functioning of Supervisory
board?
1
5%
5.0%
The requirements for continuity and stability in the elections of members of SB are
regulated in the Policy for nomination and assessment of the suitability of the
members of the managing and supervisory bodies and persons holding other
positions and the Rules for the activity of SB. In succession planing the Bank
takes into account the principles for avoiding simultaneous replacement of too
many members, applying phasing out practices, compliance with temporary
appointment requirements and taking into account the diversity policy.
100%
95%
© Scorecard for Corporate Governance of Bulgaria (according to the Bulgarian National Code of Corporate Governance 2007)
Page 4 of 10
III.
10%
III.1
Are there any incide for the company rules, regulating the regular,
timely and comprehensive exchange of information between the
Management and Supervisory board?
1
20%
20.0%
In compliance with the principles for good corporate governance, an opened
dialogue is maintained between SB and MB. Except for the regular reporting on the
execution of the assigned goals, general meetings are carried out. The members
of Supervisory Board have the right to direct contact with the management and the
Bank employees. The secretary has a key role for the entire support of this
process. The interaction between the SB and MB is regulated in the Corporate
governance code and the Rules for the activity of the MB and SB.
III.2
Did the Corporate governances establish policy of the company
regarding the disclosure of information and the connections with the
investors? Indicate the specific place and order, possibly the
webpage of the company, where could be an access to the above
described information. Indicate the date on which last are inspected
and / or updated the accepted policy.
1
20%
20.0%
First investment bank applies a Disclosure policy as a document, which is publicly
available on the corporate webpage www.fibank.bg
. The Disclosure policy was last
updated with a decision of MB of 12.03.2024, approved by a decision of SB of
12.03.2024.
III.3
Are the procedures of run away or disclose of conflict of interests
regulated in the regulation acts of the company? Indicate the specific
place and order, possibly the webpage of the company, where could
be an access to the above described information. Indicate the date
on which last are inspected and / or updated the accepted
procedures.
1
20%
20.0%
The requirements for avoiding and disclose of conflict of interests are regulated in
the Corporate governance code (last amended 23.03.2022), the Code of conduct
(last amended 24.08.2022), the Statute of the Bank (last amended 16.06.2022),
the Policy for managing of conflicts of interest (last amended 26.07.2023). The
Statute and the Corporate governance code are published on the corporate
webpage: www.fibank.bg
III.4
Are there definite requirements for observing the principles of
continuity and stability in the work of Management board, when
nominating and dismissing its members?
1
20%
20.0%
The requirements for continuity and stability in the elections of members of MB are
regulated in the Policy for nomination and assessment of the suitability of the
members of the managing and supervisory bodies and persons holding other
positions and the Rules for the activity of SB. In succession planing the Bank
takes into account the principles for avoiding simultaneous replacement of too
many members, applying phasing out practices, compliance with temporary
appointment requirements and taking into account the diversity policy.
III.5
Did the corporate directions accepted and observe the Ethic code?
Indicate the specific place and order, possibly the webpage of the
company, where could be an access to the above described
information. Indicate the date on which last are inspected and / or
updated the accepted the code and describe if there are cases in the
last year, requiring the execution of the principles, set in the code.
1
20%
20.0%
Aiming at recognition of professional and ethic standards, applicable and
executable towards the Bank as a company, working environment and credit
institution, Fibank has a Code of Conduct, which defines the main principles, ethic
norms and corporate values, on which are build the policies and business plans,
rules, procedures and daily operative work. The Code of conduct is last updated
with a decision of MB of 14.06.2022, approved with a decision of SB on
24.08.2022.
100%
100%
IV.
20%
IV.1
Has the company build up a system for internal control, which
including to identify the risks, concomitant the activity of the company
and to support their effective management?
1
25%
25.0%
First Investment Bank builds up and develops a sound and comprehensive internal
control framework, which includes independent control functions (the functions of
risk management, compliance and internal audit) structured in line with the
principle of "three lines of defence". The requirements in this area are regulated in
the Corporate governance code, the Policy of internal audit, the Rules for internal
audit and the Ethical code of the internal auditor in Fibank, the Policy for risk
management and capital adequacy, the Rules for applying risk management
function, the Compliance policy, the Charter for implementing the compliance
function.
Audit and internal control
Collaboration between the Management and Supervisory board
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IV.2
Does the system for internal control guarantee the effective
functioning of the systems for book-keeping and disclosure of
information?
1
25%
25.0%
The system for internal control includes control functions with the necessary rights
and access for independend execution of obligations, as well as control bodies,
incl. Audit committee, which observes the financial reporting and the independent
financial audit. The control functions and bodies contribute to the effective
management of the Bank, as they give reasonable confidence, that the normative
regulations, rules and procedures are strictly adhered to and there are appropriate
and timely correcting actions undertaken, as in this way it helps for minimizing risk
of losses and achiving the business goals of the Bank.
IV.3
Is the corporate management supported for its activity by the audit
committee?
1
25%
25.0%
In its capacity of a company of public interest, pursuant to the Law on the
independent financial audit, an Audit committee functions within the Bank, which is
responsible for the observing of the financial reporting and independent financial
audit, as well as the effectiveness of the internal audit function and the systems for
control and risk management in the Bank. The committee recommends the
selection of the external registered auditor, which is to execute an independent
financial audit of the Bank and observes its independance in compliance with the
requirements of the law, Regulation 537/2014 and the Ethical code of the
professional accountants.
IV.4
Does the principle for rotation implies by the proposals and the
election of external auditor? Point the external auditors of the
company in the last three years.
1
25%
25.0%
First investment bank applies the requirements for rotation of the registered
auditors, applicable to the companies of public interest pursuant to the Law on the
independent financial audit. The registered auditors of the Bank in the last three
years are as follows: for 2021 joint audit by two audit companies - BDO Bulgaria
OOD and Ecovis odit BG OOD, for 2022 and 2023 - joint audit by two audit
companies - Ecovis Odit Bulgaria OOD and Mazars OOD.
100%
100%
V.
20%
V.1
Are all shareholders treated equally, incl. the minority shareholders
and foreign?
1
10%
10.0%
The requirements for equal treatment of the shareholders, incl. minority and foreign
are regulated in the Corporate governance code of Fibank and Statute of FIBank.
V.3
Has the corporate bodies developed rules for the organizing and the
conducting of regular and extraordinary General meetings of the
shareholders of the company, which guarantee the equal treatment
of all shareholders and the right of every shareholder to express his
opinion on the items of the agenda of the General meeting? Indicate
the specific place and order, possibly the webpage of the company,
where the above described information could be accessed. Indicate
the date on which are inspected and updated the accepted rules.
1
15%
15.0%
The requirements for calling and conducting General meetings of the shareholders
are regulated in the Statute of the Bank and in the Corporate governance code of
Fibank. The documents are published on the corporate webpage www.fibank.bg.
The Statute is last updated by the General meeting of the shareholders on
16.06.2022. The corporate governance code is last updated with a decision of MB
of 17.03.2022 and is approved by SB with a decision of 23.03.2022.
V.4
Do the corporate bodies organize procedures and order for conduct
of General meeting of shareholders in a way, which does not
encumber or make more expensive and unnecessary the voting?
1
10%
10.0%
The place of conducting the General meeting is easy accessible for the majority of
shareholders. The registration procedures are convenient and enable fast and
easy approach. The Bank makes the necessary efforts to ensure easier
participation in the voting of the items in the agenda of the General meeting of the
shareholders.
V.5
Do the corporate bodies undertake actions for encouragement the
participation of the shareholders in the General meeting of the
shareholders and what?
1
10%
10.0%
The Bank has undertaken a number of initiatives for additional enagagement of the
shareholders, incl. maintenance of an Investors' club, with registration in which all
interested persons could receive notification on their e-mail about every disclosed
information by the Bank to the public, concerning the investors. A mobile IR Fibank
application is developed for investors.
Protection of shareholders' rights
© Scorecard for Corporate Governance of Bulgaria (according to the Bulgarian National Code of Corporate Governance 2007)
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V.6
Are there presented in the materials of General meetings of the
shareholders all proposals about the basic corporate events as
separate points in the agenda of the General meeting (incl. the
proposals for distribution of the profit)? Indicate the address of the
section on the webpage of the company, where the above described
information and documents represented to the shareholders on the
last General meeting of the company could be found.
1
10%
10.0%
Each proposal is structured in a separate point. The information on the General
meeting of shareholders is in section Investors / General meetings of the
shareholders on the corporate webpage www.fibank.bg
V.7
Does the company maintains on its corporate website a special
section on shareholders' rights and their participation in the General
meeting of shareholders? Please, specifiy the address of the section
of this information is presented.
1
10%
10.0%
The section on shreholders' rights is in section Investors/ Corporate governance/
Shareholders' rights at the corporate website www.fibank.bg
V.8
Is there a mechanism ensured for supprting shareholders with rights
in accordance with the effective legislation to include additional
questions and propose decisions on already included questions in
the agenda of the General meeting? Please describe the
mechanism.
1
10%
10.0%
The shareholders are provided with an information on their rights, incl. to propose
additional questions in the agenda of the GMS. The information is structured in the
section Investors/ Corporate governance/ Shareholders' rights at the corporate
website www.fibank.bg.
Information on shareholders' rights is included also in the
Invitation for convening of GMS.
V.9
Are shareholders informed on the results from the general meeting of
shareholders through internet in the specified term? Please, indicate
the section in which the relevant information is present at the website
of the company.
1
15%
15.0%
The results from the general meeting of shareholders are in section Investors/
General meeting of shareholders at the corporate website www.fibank.bg
V.10
Are all members of the corporate bodies present at the General
meeting of shareholders of the company? Specify how many
members were present at the last GMS of the company.
1
10%
10.0%
An opportunity is ensured for the members of the Manging Board and the
Supervisory Board to be present at the General meeting of shareholders (unless
important reasons require their absence). At the last Regular GMS five members of
the Managing Board and two members of the Supervisory Board were present,
incl. the chairs of the SB and MB.
100%
100%
VI.
20%
VI.1
Does the corporate bodies have adopted internal rules which ensure
timely disclosure of each material periodic and ad-hoq information for
the company, its management, corporate bodies, operating activity
and shareholders' structure?
1
10%
10.0%
First Investment Bank applies a Disclosure policy that outlines the framework for
provision of information to stakeholders, shareholders and investors and provides
an opportunity for making objective and informed decisions and assessments,
while complying with the principle of equaly treatment of addressees.
VI.2
Does the information disclosure system ensures equally treatment of
addressees (shareholders, stakeholders, investment community) and
avoids inside information abuse? Describe the main characteristics
of the maintained information disclosure system and the way it
guarantees equaly treatment of addressees.
1
10%
10.0%
In compliance with the Disclosure Policy of Fibank, the Bank discloses information
to the public through the electronic X3News system (www.x3news.com), which
ensures effective dissemination of information to the widest possible audience,
simultaneously and in a non-discriminatory manner. The information is also
published at the corporate website of the Bank www.fibank.bg
VI.3
Does the information disclosure system ensures full, timely, fair and
understandable information for taking objective and well informed
decisions and assessments?
1
5%
5.0%
Fibank discloses information in its capacity of a credit institution, public company
and investment intermediary in compliance with its Information Disclosure Policy
and ots Corporate Governance Code, the applicable regulatory requirements and
good practices in this sphere. The Bank maintains also a financial calendar
included in the Disclosure Policy of Fibank, which is publicly accessible at the
Corporate governance section of the website of the Bank www.fibank.bg
VI.4
Does the corporate bodies adopted and control the compliance of
internal rules for preparing the annual and interim reports and way of
disclosing information?
1
10%
10.0%
The requirements are regulated in the Disclosure Policy and the Corporate
Governance Code of the Bank, as in addition the Bank has adopted internal Rules
on the requirments for disclosure of information that regulate the internal
organisation on information disclosure within the Bank.
Disclosure of information
© Scorecard for Corporate Governance of Bulgaria (according to the Bulgarian National Code of Corporate Governance 2007)
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VI.5
Does the company has an updated corporate website? Please, give
the address.
1
10%
10.0%
First Investment Bank has a corporate website www.fibank.bg, with established
content, scope and periodicity of the information disclosed therein in compliance
with the regulatory requirements and good corporate practices .
VI.6
Does the company discloses on its corporate website the whole
information pursuant to Chapter 4, p. 34 of the Code? In case the
company does not comply with any of the reccomendations please
describe the reasons.
1
15%
15.0%
The requested information is publicly accessible through the corporate website
www.fibank.bg
VI.7
Does the company has english version of its website with content
pursuant to Chapter 4, т. 34 from the Code?
1
15%
15.0%
First Investment Bank has an English version of its corporate website
www.fibank.bg,
with established content and scope of the information disclosed
therein.
VI.8
Does the company informs regularly in accordance with regulatory
norms and good international practices information of non-financial
character, for economical, social, ecological questions related to
stakeholders (e.g.: fight with corruption, work with employees,
clients, suppliers, social responsibility, environment protection?
1
10%
10.0%
Fibank has special sections in the Annual activity report on disclosing information
of non-financial character (non-financial declaration under the meaning of art.48 of
the Accountancy Act), incl. ecological, social, governance and ethical issues,
human capital management, business model description, etc.
VI.9
Is there an easy access for shareholders to the company's
remuneration policy and information on the Board's annual
remunerations and additional stimuluses?
1
10%
10.0%
Information on the Bank's Remuneration Policy and its execution (Report on the
execution of the Remuneration policy under the meaning of art.100m of LPOS) is
disclosed in the Annual activity reports, as well as quantitative information on the
remuneration of the key management personnel received during the year - in the
Annual Financial Statements, which are publicly available i.a. through the
corporate website www.fibank.bg
VI.10
Does the corporate bodies disclose in a timely manner the structure
of capital and agreements that lead to excercise of control in
accordance with its rules for disclosure of information?
1
5%
5.0%
The requested information is disclosed in a timely manner and regularly in
accordance with the Bank's Disclosure policy and applicable regulatory
requirements. The information is disclosed through X3News system as well as on
the corporate website www.fibank.bg
100%
100%
VII.
10%
VII.1
Does the company has identified who are the stakeholders with
relation to its activity based on their spheres of influence, role and
attitute to its sustainable development?
1
20%
20.0%
The requirement is regulated in the Corporate Governance Code and the
Disclosure Policy of Fibank.
VII.2
Does the corporate bodies ensure effective cooperation with
stakeholders?
1
20%
20.0%
First Investment Bank applies a policy of providing information to stakeholders
about its activity. Those include persons who are not shareholders but are
interested in the economic development of the company, such as creditors,
bondholders, customers, employees, the general public, and others. Periodically,
in accordance with the legal requirements and best practices, First Investment
Bank discloses information of a non-financial nature, as well as maintains and
develops a corporate blog which functions as a channel of communication aimed
at open dialogue in accessible language with customers, partners and other
stakeholders.
VII.3
Does the compnay has specific rules for taking into consideration the
interests of the stakehodlers, which to ensure their attraction for
deciding on certain questions that require their position?
1
20%
20.0%
The rules for cooperation with stakeholders are regulated in the Corporate
Governance Code of Fibank, the Disclosure Policy and the Code of Conduct of the
Bank.
VII.4
Does the corporate bodies ensure enough information to all
stakeholders on their legal rights and if yes, how?
1
20%
20.0%
Fibank applies a policy of providing information to stakeholders in compliance with
applicable regulations as well as the Bank publishes additional information in the
form of presentations and interviews with senior management, press releases,
specialised journals (e.g. Fibank News), and detailed information on the products
and services of the Bank.
Corporate governance - engagement (incl. stakeholders)
© Scorecard for Corporate Governance of Bulgaria (according to the Bulgarian National Code of Corporate Governance 2007)
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VII.5
Does the corporate bodies guarantee the right of regular and timely
access to relevant, sufficient and reliable information on the company
when the stakeholders take part in the process of corproate
governance and if yes, how?
1
20%
20.0%
The requirements are met with adopted by the Bank written policies which
application is monitored in accordance with the applicable regulatory and internal
requirements.
100%
100%
10%
VIII. 1
Does the corporate bodies ensure effective cooperation between the
company and its shareholders - institutional investors, as well as with
the regulated markets in financial instruments and the investment
intermediaries on those markets and if yes, in what way?
1
20%
20.0%
With a view to creating an effective relation between First Investment Bank and its
shareholders and the persons interested in investing in financial instruments
issued by the Bank, First Investment Bank has appointed Investor Relation
Director. In compliance with best corporate governance practices, the Bank
develops initiatives for further engaging with minority shareholders and institutional
investors. In addition, in an effort to maintain an open line of communication with
shareholders and investors, First Investment Bank maintains an Investors Club.
The Bank has in place a mobile application for investor relations ensuring fast
access to financial information and the financial calendar of the Bank, as well as to
other data and news related to investors.
VIII. 2
When choosing investment intermediaries and respectively operators
of markets on which the financial instruments are traded, does the
corporate bodies take into consideration to what extent the actions of
these entities are based on market information and principles?
1
20%
20.0%
The Bank acts in relation to these requirements in a way that is compliant with
regulatory requirements and good practices.
VIII. 3
Does the corporate bodies coordinate with its investment
intermediaries and institutional investors the company's corporate
governance policy and practices?
1
20%
20.0%
The reporting on corporate governance policies and procedures are regularly
disclosed, incl. the goals for development for the next year and their execution.
VIII. 4
Does the company requires disclosure and limiting conflict of interest
from advisors, analysers, brokers, rating agencies and other persons
that provide consultations?
1
20%
20.0%
The Bank's policies on avoiding and disclosure of conflicts of interest is in
compliance with the regulatory requirements, applicable to the Bank in its capacity
of a credit institution, public company and investment intermediary.
VIII. 5
If the company is admitted to trade in a jurisdiction, different from the
one it is incorporated in, does it disclose the applicable for this
jurisdiction corporate governance rules?
1
20%
20.0%
Fibank conforms its information disclose with the requirements, applicable to the
place at which the Bank and its financial instruments are admitted for trade.
100%
100%
VIII. Institutional investors, markets in financial instruments and other intermediaries
© Scorecard for Corporate Governance of Bulgaria (according to the Bulgarian National Code of Corporate Governance 2007)
Page 9 of 10
Corporate Governance Self-evaluation Scorecard
©
Standard
Standard
Share: 10%
Standard
Share: 20% Partial score: 100% Share: 10%
Partial score: 100% Partial score: 100%
Standard Standard score
100%
Standard
Share: 20% Share: 10%
Partial score: 100% Partial score: 100%
Standard Standard
Share: 10%
Standard
Share: 10%
Partial score: 100% Share: 10% Partial score: 95%
Partial score: 100%
Institutional investors, markets in
financial instruments and other
internediaries
Scorecard/Evaluation form for Corporate governance in Bulgaria
Corporate governance - engagement
(incl. Stakeholders)
Protection of shareholders' rights
Cooperation between the Managing
and Supervisory Boards
General results for companies with two-tier governance system
Information disclosure
Overall assessment Corporate
Governance
Managing Board
Supervisory BoardAudit and internal control
© Scorecard for Corporate Governance of Bulgaria (according to the Bulgarian National Code of Corporate Governance 2007)
Page 10 of 10
Corporate governance code
of First Investment Bank AD
CORPORATE GOVERNANCE CODE OF FIRST INVESTMENT BANK AD 2
Table of Contents:
Introduction ...................................................................................................................................... 3
Corporate status and profile ............................................................................................................. 4
Mission .................................................................................................................................... 4
Scope and application ....................................................................................................................... 5
Organizational framework ................................................................................................................. 7
Principal bodies and functions in corporate governance .................................................................. 8
Supervisory Board ................................................................................................................... 8
Managing Board .................................................................................................................... 12
Remuneration policy in the Bank .......................................................................................... 15
Control Environment and Processes ..................................................................................... 16
Risk Management and Risk Control ...................................................................................... 17
Compliance ........................................................................................................................... 18
Internal audit ......................................................................................................................... 19
External Auditors (Registered Auditors) ................................................................................ 20
Audit Committee ................................................................................................................... 20
Shareholders’ rights and equitable treatment ................................................................................ 21
Convening of the General Meeting of Shareholders ............................................................. 22
Conducting of the General Meeting of Shareholders ............................................................ 23
Results .................................................................................................................................. 23
Disclosure of information and transparency ................................................................................... 24
Disclosure policy and disclosure practices ............................................................................ 24
Additional provisions ....................................................................................................................... 25
Transitional and Final provisions ..................................................................................................... 27
CORPORATE GOVERNANCE CODE OF FIRST INVESTMENT BANK AD 3
Introduction
The corporate policy of First Investment Bank AD /Fibank, the Bank/ shall be based on professional
and transparent governance in line with the internationally recognized standards and principles
for good corporate governance and sustainable development, taking into account the changes in
regulations and economic environment, as well as the importance of First Investment Bank to the
financial market in the country.
First Investment Bank shall develop and enhance corporate governance as a means to improve
efficiency, successfully attain the strategy and plans for long-term development, incl. with respect
to sustainability, as well as affirm its reputation.
The purpose of the present Corporate Governance Code /the Code/ shall be to define the main
principles and requirements for maintaining and furthering the organization and governance methods
of First Investment Bank, aiming at:
Responsible, accountable and value-based management;
Effective oversight of management and control;
Executive body and senior management that act in the best interests of the Bank and seek to
enhance shareholder value;
Timely financial and non-financial information disclosure and transparency;
Effective system of risk management and internal control.
The purpose of the Code shall be also to outline the governance framework and to structure the
key components, functions and responsibilities of the corporate governance system of the Group of
First Investment Bank. Following the Code shall contribute to attaining the goals and plans, which
are in the interests of the Bank as a whole, the customers, shareholders, creditors, stakeholders
in the country and abroad, as well as to facilitate effective oversight, thus fostering more efficient
usage of resources.
The present Code shall comply with the National Corporate Governance Code, as well as with the
effective legislation in the Republic of Bulgaria, incl. the specific requirements applicable to credit
institutions.
The Code shall reflect also the Corporate governance principles for banks of the Basel Committee,
the European Banking Authority /EBA/ Guidelines on internal governance, as well as the Organisation
for Economic Co-operation and Development /OECD/ Principles of corporate governance.
CORPORATE GOVERNANCE CODE OF FIRST INVESTMENT BANK AD 4
Corporate status and profile
First Investment Bank is a joint-stock company registered with Sofia City Court pursuant to a ruling
dated 8 October 1993. Since 28 February 2008 the Bank has been registered in the Commercial
Register at the Registry Agency.
First Investment Bank is a public company registered in the Commercial Register of Sofia City Court
by a decision dated 4 June 2007 and in the register of public companies and other issuers held by
the Financial Supervision Commission by a decision dated 13 June 2007.
The Bank owns a universal banking license for domestic and international operations.
First Investment Bank is a licensed primary dealer in government securities and is a registered
investment intermediary.
In pursuance of the applicable requirements, the Bank has a Legal Entity Identifier (LEI) code
549300UY81ESCZJ0GR95, issued by the Global Markets Entity Identifier (GMEI) Utility.
First Investment Bank has a two-tier governance system consisting of a Supervisory Board and a
Managing Board.
First Investment Bank offers a wide range of services in the sphere of corporate banking, lending
to companies, servicing individuals, card payments, payment and trade operations on the local and
international markets.
The Bank operates mainly on the Bulgarian financial market, as well as performs banking activity in
abroad throughout its branch in Cyprus and the subsidiary bank in Albania /First Investment Bank –
Albania Sh.a./.
First Investment Bank is among the leading credit institutions in the Republic of Bulgaria.
Mission
First Investment Bank AD aspires to continue to be one of the best banks in Bulgaria, recognized as
a rapidly growing, innovative, customer-oriented bank, offering outstanding products and services
to its customers, ensuring excellent careers for its employees, and contributing to the community.
The Bank shall continue to develop high-technological solutions providing its customers with
opportunities for banking from any place around the world at any time.
CORPORATE GOVERNANCE CODE OF FIRST INVESTMENT BANK AD 5
Scope and application
The corporate governance of First Investment Bank shall be a system of policies, rules, procedures
and practices, through which the Bank is managed and controlled under clearly defined functions,
rights and responsibilities at all levels – General Meeting of Shareholders, Supervisory Board and
committees to it, Managing Board and committees and councils to it, Internal Audit, structures in
the Head Office, branches and offices.
The corporate governance of First Investment Bank shall be based on the corporate governance
principles of the Basel Committee on Banking Supervision /the Basel Committee/, of the European
Banking Authority /EBA/ and of the Organisation for Economic Co-operation and Development /
OECD/, including the principles for:
transparency;
publicity;
objectivity;
fairness;
trustworthiness;
independence;
sustainability.
The risk governance system shall be organized in line with “the three lines of defence”:
The business units shall be the first line of defence, which shall acknowledge and manage
the risks that they incur in conducting their activities.
The Risk management function and the Compliance function shall comprise the second
line of defence, which shall be responsible for further identifying, measuring, monitoring and
reporting risk on a Bank-wide basis, independently from the business units.
The Internal audit function shall be charged with the third line of defence, conducting
risk-based audits and reviews to provide assurance to the Supervisory Board that the overall
corporate governance framework of the Bank, including the risk governance framework, is
effective and that appropriate policies, systems and processes are in place and consistently
applied.
The members of the Supervisory Board and of the Managing Board, the senior management and
all employees shall accept the present Code as a joint responsibility and apply the requirements set
forth and its spirit in fulfilling their obligations.
CORPORATE GOVERNANCE CODE OF FIRST INVESTMENT BANK AD 6
Application at group level. The competent management bodies of the subsidiary companies shall
follow the guidelines and principles of the present Code, unless any legal or supervisory acts require
otherwise.
Aiming at exercising adequate control over subsidiary companies, the corporate governance
structure of First Investment Bank shall adopt and apply appropriate instruments for monitoring of
all risks that may affect the group. The Bank shall apply policies on internal governance at a group
level, thus contributing to effective control over the subsidiary companies, clear levels of reporting
and securing the necessary resources for applying the group and local governance standards.
CORPORATE GOVERNANCE CODE OF FIRST INVESTMENT BANK AD 7
Organizational framework
According to the principles of the Basel Committee
The Supervisory Board should define appropriate governance structures and practices for
its own work, and put in place the means for such practices to be followed and periodically
reviewed for ongoing effectiveness.
The following governance bodies and key structures shall function within the Bank:
General Meeting of Shareholders - the highest governance body, allowing the shareholders to take
decisions on principle matters relating to the existence and the activity of the Bank.
Supervisory Board /SB/ - shall define the strategy for development and exercises oversight of the
management of the Bank. The Supervisory Board shall be supported in its activity by committees.
Managing Board /MB/ - shall manage the Bank by resolving all issues within its scope of activity,
except those within the exclusive competence of the General Meeting of Shareholders or the
Supervisory Board. It shall carry out the strategy for development of the Bank, adopted by the
Supervisory Board. The Managing Board shall be supported in its activity by committees and councils.
Risk management function – shall identify, measure and manage all material risks to the Bank in
compliance with the policies adopted by the Supervisory Board and the Managing Board.
Compliance function - shall manage the risk from non-compliance or violation of legal regulations,
ethical standards, rules and procedures in accordance with the policies adopted by the Supervisory
Board and the Managing Board.
Internal audit - shall support the Supervisory Board and the Managing Board by providing an
independent and objective assessment on the effectiveness of the risk management, control and
governance processes.
CORPORATE GOVERNANCE CODE OF FIRST INVESTMENT BANK AD 8
Principal bodies and functions in corporate
governance
Supervisory Board
According to the principles of the Basel Committee
The Supervisory Board exercises supervision and where necessary advices the Managing
Board, and provides oversight of the general activity of the Bank, including approving and
overseeing the implementation of the Bank’s strategic objectives, corporate governance
framework and corporate culture.
The Supervisory Board of First Investment Bank shall function in line with the principles of the
Basel Committee and with the EBA guidelines. In the By-Laws of the Bank the following principal
functions are defined:
Functions
Exercises supervisory functions and represents the Bank in its relations with the Managing
Board;
Defines the general objectives of the Bank activity, as well as the attainment strategy, incl. in
the context of sustainable development;
Approves decisions of the Managing Board that are within the competence of the Supervisory
Board in compliance with the By-Laws of the Bank, the By-Laws of the Supervisory Board and
the law;
Approves the general corporate governance framework of the Bank.
Setting corporate culture, sustainability and ethical values
By applying high ethical standards and corporate values for business behavior, the Supervisory
Board shall establish high corporate culture and business ethics by applying “tone at the top”. The
Supervisory Board shall ensure the exercise of control over the compliance of ethical standards, set
forth in the Code of Conduct of the Bank, as well as for establishing a sustainability culture within
the Bank.
CORPORATE GOVERNANCE CODE OF FIRST INVESTMENT BANK AD 9
Risk tolerance/appetite, management and control
The Supervisory Board shall be responsible for overseeing the risk governance framework, the risk
appetite; the internal system for management and control of all types of risk, including ESG risks, by
demanding strong risk culture among its employees.
Oversight of Managing Board activity and of senior management
The Supervisory Board shall exercise oversight of the collective and individual performance of
Managing Board members and senior management, as well as of attaining the targeted objectives
in a sustainable way.
Committees
The Supervisory Board shall be supported in its activity by a Presiding Committee, a Risk Committee,
a Remuneration Committee, and a Nomination Committee which shall function according to written
competencies, rights and responsibilities.
The Presiding Committee shall be responsible for overseeing the activities of the Managing Board
on important strategic decisions, including the issue of new shares, bonds, hybrid instruments,
the adoption of programs and budgets relating to the activity of the Bank, as well as overview and
control over the activity of the subsidiaries.
The Risk Committee shall assist the supervision over the risk management activities of the
Managing Board, as well as the broad strategic and tactical supervision of the risk management
function in the Bank. The committee shall advise the Supervisory Board regarding the overall current
and future strategy on the compliance with risk policy and risk limits, risk appetite and the control
over its performance by the senior management.
The Remuneration Committee shall assist the Supervisory Board in the implementation of the
Remuneration policy of the Bank and its subsequent amendments, as well as in any other matters
concerning remuneration, in accordance with the regulatory requirements and best practices in the
area.
The Nomination Committee shall assist the Supervisory Board in assessing the suitability of
candidates or active members of the Supervisory Board and of the Managing Board, as well as of
the key function holders in the Bank, in compliance with the applicable regulatory provisions and
internal regulations in this sphere.
CORPORATE GOVERNANCE CODE OF FIRST INVESTMENT BANK AD 10
The Supervisory Board and its committees shall function according to written rights and
responsibilities, competences and rules of procedure, defined in the following rules of the Bank: By-
Laws of the Supervisory Board, Rules of procedure of the Presiding Committee to the Supervisory
Board, Rules of procedure of the Risk Committee to the Supervisory Board, Rules of procedure
of the Remuneration Committee to the Supervisory Board, Rules of procedure of the Nomination
Committee to the Supervisory Board.
Composition and professional qualification of Supervisory Board members
According to the principles of the Basel Committee
Supervisory Board members are qualified and maintain their high professional qualification
during the term of their mandate, individually and collectively, for their responsibilities.
Supervisory Board members understand their oversight and corporate governance role and
are able to exercise sound, objective judgment about the affairs of the bank.
The Supervisory Board shall consists of three to seven persons, who comply with the requirements
set forth in the applicable legislation, the By-Laws of the Bank and the By-Laws of the Supervisory
Board.
The composition of Supervisory Board shall include persons with appropriate qualification and
professional experience corresponding to the Bank’s activities and the main risks the Bank is
exposed to.
Supervisory Board members shall be elected by the General Meeting of Shareholders for a term of
up to 5 years.
The independent members of the Supervisory Board of First Investment Bank shall conform to
independence requirements set forth in the law (LCI, Art.10a, Para.2 and LPOS, Art.116a, Para.2).
First Investment Bank shall maintain a Suitability Matrix of the Supervisory Board with data on the
professional qualifications, skills and experience of its members. Each member of the Supervisory
Board shall possess experience, knowledge, qualifications and skills for team work, required for the
effective performance of his/her duties and ensuring the capability of the Supervisory Board as a
collective body to guarantee the attainment of the long-term interests of the Bank.
CORPORATE GOVERNANCE CODE OF FIRST INVESTMENT BANK AD 11
The Bank shall ensure an orientation program for new members of the Supervisory Board, as well
as shall provide access to training courses to all members of the Supervisory Board as a matter of
furthering their professional qualifications in the best interest of the functions performed by them,
including on the novelty in the spheres of corporate governance and sustainable development. The
Nomination Committee shall ensure an annual review and assessment of the qualifications and
competences of the members of the Supervisory Board. The Supervisory Board and its committees
may use independent experts, if necessary.
Rules of procedure of the Supervisory Board
The Supervisory Board shall meet as often as necessary. The Supervisory Board shall meet at least
once every 3 months. If possible, meetings shall be scheduled annually in advance. The Supervisory
Board shall meet earlier than scheduled if deemed necessary by the Chair of the Supervisory Board,
another member of the Supervisory Board, or the Managing Board.
The Supervisory Board shall function according to written procedures, competencies and norms /
By-Laws of the Supervisory Board of First Investment Bank/, and in conformity to the By-Laws of
the Bank and the effective legislation.
Minutes shall be kept at all meetings of the Supervisory Board, signed by all members that have
attended the meeting.
In order to facilitate the organization of work of the Supervisory Board, the Bank has in place a
Chief Secretary. Further to organizing the meetings of the Supervisory Board and keeping minutes,
the Secretary shall be responsible for monitoring the compliance of procedures, as well as for
ensuring submission and exchange of information between the members of the Supervisory Board,
the members of the committees and the Managing Board.
Role of the Chair of the Supervisory Board
The Supervisory Board shall elect a Chair and a Deputy-Chair among its members.
The Chair shall ensure that the Supervisory Board decisions are taken on a sound and well informed
basis. The Chair shall encourage and promotes open and critical discussion and ensures that
dissenting views can be freely expressed and discussed within the decision-making process.
The Deputy-Chair shall substitute and take over the execution of the rights and obligations of the
Chair in his or her absence.
CORPORATE GOVERNANCE CODE OF FIRST INVESTMENT BANK AD 12
Conflicts of interest of the members of the Supervisory Board
The members of the Supervisory Board shall be responsible for performing their duties objectively,
critically and independently by avoiding conflicts of interest and where this is not possible for
disclosing them in a timely manner.
Each member of the Supervisory Board shall immediately report to the Chair of the Supervisory
Board any conflict of interest or potential conflict of interest and shall provide all relevant information.
The Supervisory Board member concerned shall not take part in the assessment by the Supervisory
Board of whether a conflict of interest exists. The members of the Supervisory Board shall declare
in writing the existence of conflicts of interest.
Self-assessment of the activity of the competent governance body
At least once a year, the Supervisory Board shall perform assessment of the effectiveness of its
own activities, individually and collectively, assessment of the governance practices and procedures,
suitability, as well as of the functioning of the Managing Board and the committees to the Supervisory
Board.
Managing Board
According to the principles of the Basel Committee
Under the direction and oversight of the Supervisory Board, the Managing Board carries out
and manages the bank’s activities in a manner consistent with the business strategy, risk
appetite, incentive compensation and other policies approved by the Supervisory Board.
The Managing Board shall manage the Bank independently and responsibly in a manner consistent
with the established mission, objectives and strategies of First Investment Bank, as well as with the
priorities related to sustainable development.
The Managing Board shall function according to its By-Laws, approved by the Supervisory Board, as
its principle functions shall be to:
Manage and represent the Bank, by resolving all issues within its scope of activity, except those
within the exclusive competence of the General Meeting of Shareholders or the Supervisory
Board – in compliance with the law and the By-Laws of the Bank;
Organize the execution of the decisions of the General Meeting of Shareholders and these of
the Supervisory Board;
CORPORATE GOVERNANCE CODE OF FIRST INVESTMENT BANK AD 13
Report on its activity to the Supervisory Board at least once every 3 months and to immediately
inform the Chair of the Supervisory Board or his or her deputy for all circumstances of material
importance to the Bank;
Perform all other functions, delegated to it by the General Meeting of Shareholders or the
Supervisory Board and the law.
Committees and Councils
The Managing Board shall be assisted in its activities by a Credit Council, an Assets, Liabilities and
Liquidity Council, a Restructuring Committee, an Operational Risk Committee, IT Committee, which
all shall function in accordance with defined written structure, scope of activities and functions.
The Credit Council shall support the management of the credit risk undertaken by the Bank by
issuing opinions on loan transactions in accordance with the authority level assigned thereto.
The Assets, Liabilities and Liquidity Council (ALCO) – shall manage on an ongoing basis the
Bank’s assets, liabilities and liquidity. It shall conduct systemic analyses of the interest structure of
assets and liabilities, the maturity ladder and of liquidity indicators.
The Restructuring Committee shall act as a specialized body for monitoring, assessment,
classification, impairment and provisioning of risk exposures and commitments. It shall give
motivated written proposals to the Managing Board, respectively shall take decisions for restructuring
of exposures in accordance with the authority level assigned thereto.
The Operational Risk Committee shall be a consultative body established to facilitate the adequate
management of operational risk by monitoring and analyzing operating events. The committee shall
propose measures for the minimizing of operational risks, as well as preventive measures.
The IT Committee shall be an auxiliary body, responsible for monitoring the implementation of the
Bank‘s IT strategic program, and to manage and control the IT project portfolio, the targeted use of
resources and the approved budget in this area.
The internal regulations defining the committees and councils’ activity, their rights and responsibilities,
competences and rules of procedure are the following: Rules for the organisation and operation of
the Assets, Liabilities and Liquidity Council (ALCO), Rules for the operation of the Restructuring
Committee of First Investment Bank, Rules for the operation of the Credit Council of First Investment
Bank, Rules of procedure of the Operational Risk Committee of First Investment Bank, Rules for the
organisation and operation of the IT Committee.
The Managing Board shall submit information to the Supervisory Board in a timely manner in respect
to:
Changes in the business strategy execution, risk appetite;
Attainment of the objectives;
CORPORATE GOVERNANCE CODE OF FIRST INVESTMENT BANK AD 14
Breaches of risk limits or compliance rules;
Material internal control system failures;
Legal or regulatory concerns.
Composition and professional qualification of Managing Board members
The Managing Board shall consist of three to nine legally capable physical persons, elected by the
Supervisory Board after recommendation from the Nomination Committee. They shall comply with
the requirements of the effective legislation, the By-Laws of the Bank and the Policy for Nomination
and Suitability Assessment of the Members of the Managing and Supervisory Bodies and of the
Key Function Holders of First Investment Bank. The Managing Board members shall be established
professionals with proven leadership skills being a prerequisite for attaining the Bank’s objectives.
All Managing Board members shall have the:
Trust of the Supervisory Board members, the senior management of the Bank and its
employees;
Ability to relate to the interests of all shareholders and the Bank, as well as to make well-
reasoned decisions;
Professional expertise and education to be effective managers;
Business experience, knowledge of national issues and trends and knowledge of the market,
products and competitors;
Capacity to translate knowledge and experience into solutions that can be applied to the
practices in the Bank.
The Bank shall ensure an orientation program for new members of the Managing Board, as well
as shall provide access to training courses in accordance with the functions performed by them,
including on the novelty in the spheres of corporate governance and sustainable development.
Rules of procedure of the Managing Board
The Managing Board shall conduct meetings regularly, the agenda of which is prepared in advance.
The meetings of the Managing Board shall be conducted by a chairperson, elected by the Managing
Board. Minutes shall be kept at all meetings of the Managing Board, signed by all members that
have attended the meeting.
The rules of procedure of the Managing Board are described in detail in the By-Laws of the Managing
Board of First Investment Bank.
CORPORATE GOVERNANCE CODE OF FIRST INVESTMENT BANK AD 15
Conflicts of interest
The members of the Managing Board shall be responsible for avoiding actions that can lead to
conflicts of interest between their interests and those of the Bank. In case such conflict appears,
they should disclose it and not take part in the discussion and the taking of the respective decision.
The members of the Managing Board shall declare in writing the existence of conflicts of interest.
Interaction between Supervisory Board and Managing Board
The Supervisory Board and the Managing Board shall keep an open dialogue in accordance with the
good corporate governance principles. Except for regular reports on the implementation of the set
objectives, general meetings shall also be conducted. The members of the Supervisory Board shall
have unrestricted access to the management and the employees of the Bank. The Chief Secretary
shall play a key, overall role in facilitating this process.
The Chief Secretary shall be employed on a full-time basis and shall possess the necessary
qualifications and skills to ensure that the governing bodies follow internal rules and external
regulations, shall facilitate the communication between them, and shall keep the Supervisory Board
members and the key officers abreast of the latest corporate governance developments.
Senior management shall be presented with ample opportunity to present during Managing Board
meetings, as well as during reporting to the Supervisory Board, which shall contribute to obtain
direct information and better gauge the next generation of managers and future leaders.
Remuneration policy in the Bank
According to the principles of the Basel Committee
The bank’s remuneration structure supports sound corporate governance and risk
management.
The remuneration principles in the Bank shall comply with the business strategy, objectives, values
and long-term interests of the Bank, and promote sound and effective risk management so as not
to encourage risk-taking above the acceptable levels for the Bank.
The Bank shall apply clear, dully-documented and disclosed among all employees procedures for
determining remunerations that are defined in the Remuneration Policy of First Investment Bank
and the Rules for determining and development of remunerations.
The policy is aimed at attracting and retaining highly qualified employees, and motivating them
towards achieving high results at a moderate level of risk, and in accordance with the long-term
interests of the Bank and its shareholders.
CORPORATE GOVERNANCE CODE OF FIRST INVESTMENT BANK AD 16
In determining remunerations considered are not only the financial results, but also the ethical
standards and corporate values underlying the Code of Conduct of the Bank, as well as the sound
and effective risk management and sustainable development.
Control Environment and Processes
The Bank shall establish and promote a reliable and comprehensive internal control framework,
with the necessary powers and rights of access enabling independent performance of duties by the
structural and auxiliary units exercising monitoring and control.
Improvement of the efficiency of risk management processes shall be achieved by both top-down
board leadership, and bottom-up involvement of management at all levels. While determination of
risk appetite may be initiated by the Managing Board, its successful implementation shall depend
upon the effective interaction between the Supervisory Board, the Managing Board, the risk function,
the CFO and the operational businesses units.
The risk management processes, procedures and requirements shall be structured in accordance
with “the three lines of defense” principle.
First line of defense: the business units. Constituting the front line of risk taking, those are
responsible for management of risks including identifying, assessing and reporting according
to the limits, procedures and controls currently in force in the Bank.
Second line of defense: the Risk Management and Compliance functions. Those shall be
independent from the first line of defense. The Risk Management function carries out
monitoring, assessment and reporting of risks independently of the first line.
This second line of defense also includes the independent Compliance function which monitors
and controls the compliance of internal bank regulations with the applicable legislation.
Internal audit function: independently from the first and the second lines of defense, assures
independent review of the quality and effectiveness of the risk management framework,
including strategic and business planning, and internal processes and procedures.
The control functions shall be independent from the operational business units monitored and
controlled by them, as well as organizationally independent from one another insofar as they perform
different functions.
CORPORATE GOVERNANCE CODE OF FIRST INVESTMENT BANK AD 17
Risk Management and Risk Control
Risk Management
According to the principles of the Basel Committee
The Bank should have an effective independent risk management function, under the
direction of Chief Risk Officer (CRO), with sufficient stature, independence, resources and
access to the board.
First Investment Bank shall establish, maintain and develop an effective risk management system
ensuring timely identification of material risks to the Bank, their monitoring and assessment,
introducing of control measures and risk mitigation procedures, as well as regular and comprehensive
reporting to the Managing Board and the Supervisory Board.
The general risk profile of the Bank shall be managed through ensuring of balance between risks
incurred, return, and capital adequacy.
The Bank shall apply a written Policy for Risk Management and Capital Adequacy which shall provide
the framework for identification, assessment, management and internal analysis of risks and capital
adequacy. Along with the Policies for management of credit, market, operational and other types of
risks, the Policy for management of assets, liabilities and liquidity, and the internal rules, guidelines
and instructions related thereto, it shall form the overall risk management framework of the Bank.
The policy followed by the Bank with respect to management of risk and capital adequacy shall be
in compliance with the business strategy of the Bank and its product policy, reflecting the applicable
for the Bank ESG risks/factors related to sustainable development.
The Risk management and control function shall be organized under the direction of a Chief Risk
Officer with sufficient stature, independence, resources and access to the Managing Board, the
Risk Committee, and the Supervisory Board.
Risk identification, monitoring and control
According to the principles of the Basel Committee
Risks should be identified, monitored and controlled on an ongoing bank-wide and individual
entity basis. The sophistication of the bank’s risk management and internal control
infrastructure should keep pace with changes to the bank’s risk profile, to the external risk
landscape and in industry practice.
CORPORATE GOVERNANCE CODE OF FIRST INVESTMENT BANK AD 18
Risks in the Bank shall be identified, monitored and controlled on an ongoing basis, as well as regularly
analyzed. The sophistication of the risk management system and internal control framework shall
develop according to changes in the internal and external environment.
Risk identification shall encompass all material risks to the Bank, including risk related to climate
change and sustainable development (ESG risks), on- and off-balance sheet items, as well as analysis
on portfolio basis and on a business-line level.
In the identification and assessment of risks, the Bank shall utilize tools for preliminary analysis /
future-oriented tools/ and tools for subsequent analysis /past-oriented tools, or back-testing/ which
shall supplement the monitoring of current risk exposures of the Bank. By using future-oriented
tools, the Bank shall identify potential risk exposures under certain adverse circumstances, while
by using back-testing the Bank shall review the compliance of its current risk profile with the risk
appetite and risk management framework, and carry out appropriate adjustments where necessary.
The tools used shall allow for aggregation of the risk exposures of different business lines, and
facilitate the identification of risk concentrations.
The Bank shall consider risks conservatively, and apply rating models which shall be subject to
periodic validation.
There is an independent risk control function established in the Bank which guarantees that risks are
identified and managed in an appropriate manner by the relevant units within the Bank, and provides
the Managing Board and the Supervisory Board with comprehensive review of all risks.
Compliance
According to the principles of the Basel Committee
The bank’s Supervisory Board oversees the management of the bank’s compliance risk.
The Board ensures the establishment of a compliance function and approves the bank’s
policies and processes for identifying, assessing, monitoring and reporting and advising on
compliance risk.
The Supervisory Board of First Investment Bank oversees the management of risk of non-compliance
with applicable legislation and internal regulations, as well as ensures implementation of established
norms, best practices and ethical standards.
The Compliance function shall be organizationally independent from the business units and has
separate hierarchical subordination and line of reporting. The Compliance function advises the
Managing and Supervisory Boards on implementation of the applicable legislation, best practices
and standards, and assesses the impact of any changes in the legal framework on the Bank’s
activities.
CORPORATE GOVERNANCE CODE OF FIRST INVESTMENT BANK AD 19
The Compliance function ensures that all new products of the Bank meet the requirements of
the existing legal framework and of any known and upcoming changes in the regulations and
supervisory requirements. The Compliance function monitors the Bank’s transactions and manages
risks deriving from non-standard transactions, thus exercising ongoing control over their compliance
with the regulatory requirements and assisting with their implementation.
A written Compliance Policy shall be applied within the Bank. The Compliance function shall ensure
implementation of that Policy, and provide the necessary information to the Managing Board, the
Risk Committee, and the Operational Risk Committee.
Internal audit
According to the principles of the Basel Committee
The internal audit function provides independent assurance to the board and supports board
and senior management in promoting an effective governance process and the long-term
soundness of the bank.
For the purpose of achieving the goals and objectives and exercising of efficient control, there is an
Internal Audit Department established within the Bank. It conducts regular internal audits in order
to ensure:
achievement of goals and objectives;
economical and efficient use of resources;
adequate control of various risks;
safeguarding of assets;
reliability and integrity of the financial and management information;
compliance of the Bank’s activity with the regulatory requirements, policies, plans, internal
rules and procedures.
The Director of Internal Audit shall submit an annual report on the activity of the Service to the General
Meeting of Shareholders, the Supervisory and Managing Board, informing on the main results of the
control activities of the internal auditors, of the measures undertaken and their execution.
The Internal Audit shall function according to written rules; it shall conduct, at least on a quarterly
basis, working meetings with the Audit Committee; it shall be independent from the audited
activities, and have the necessary reputation, competences, resources and powers.
The internal auditors shall adhere to the national and international professional standards for internal
audit.
CORPORATE GOVERNANCE CODE OF FIRST INVESTMENT BANK AD 20
External Auditors (Registered Auditors)
The General Meeting of Shareholders shall decide on the selection of External Auditors upon
proposal by the Supervisory Board, and following a recommendation by the Audit Committee. The
External auditors shall perform an independent financial audit in order to express an independent
auditor‘s opinion on the fair presentation in all material respects in the financial statements of the
financial position, the reported financial results, the cash flows and the equity of the Bank. The
external auditors shall be auditing companies independent from the Bank.
Audit Committee
In its capacity as a company of public interest, pursuant to the requirements of the Law on Independent
Financial Audit /LIFA/, the Bank has established a functioning Audit Committee which is responsible
for monitoring the financial reporting and independent financial audit within the Bank, as well as the
effectiveness of the internal audit function and the systems for control and management of risks in
the Bank. The Audit Committee makes a recommendation in the selection of registered auditors to
perform the independent financial audit of the Bank, and monitors their independence in accordance
with the requirements of LIFA and Regulation (EU) No 537/2014 of the European Parliament and
of the Council of 16 April 2014 on specific requirements regarding statutory audit of public-interest
entities and repealing Commission Decision 2005/909/EC.
The members of the Audit Committee shall be elected by the General Meeting of Shareholders,
which shall vote their mandate.
The functions and responsibilities of the Audit Committee are set out in the Rules of Procedure of the
Audit Committee (Statute of the Audit Committee, within the meaning of Art. 107, para. 7 of LIFA).
The members of the Supervisory Board and Managing Board of Fibank, the committees thereto, as
well as all employees of the Bank shall be obliged to assist the Audit Committee in carrying out its
activities, including to provide, within a reasonable timeframe, the information requested by it.
The Audit Committee shall report its activities before the General Meeting of Shareholders once a
year.
CORPORATE GOVERNANCE CODE OF FIRST INVESTMENT BANK AD 21
Shareholders’ rights and equitable treatment
According to the principles of OECD
The corporate governance framework should protect the rights of the shareholders, the
depositors and the other clients of the Bank.
The corporate governance of First Investment Bank protects the rights of the shareholders, the
depositors and the other clients of the Bank by applying a system of rules and procedures, including,
but not limited to the following:
secure methods for registration of ownership;
compliance with legal requirements in conveyance or transfer of shares;
regular and timely receipt and disclosure of financial and non-financial information relating to
the company;
participation and voting rights in the General Meeting of Shareholders;
participation of shareholders in the distribution of the company’s profit.
First Investment Bank operates in accordance with the current regulations and the By-Laws of the
Bank which govern the rights of the shareholders, the registration of ownership, the conveyance
or transfer of shares, the regular preparation and disclosure of information concerning the financial
position, corporate governance and sustainable development of the company, and the participation
in distribution of profits.
Information on all shareholders of the Bank and the shares owned by them shall be recorded in
Fibank’s shareholder register, kept by the Central Depository AD.
Disposal of shares shall be carried out in accordance with the By-Laws of the Bank; for any
outstanding issues the current legislation shall apply.
Right to information: the operations of First Investment Bank are organized in such a way as to
ensure timeliness and completeness of information provided to the executive management, the
collective bodies of the Bank: Managing and Supervisory Boards, and to its shareholders.
CORPORATE GOVERNANCE CODE OF FIRST INVESTMENT BANK AD 22
According to the principles of OECD
The corporate governance framework should ensure equitable treatment of all shareholders,
including minority shareholders and foreign shareholders.
The corporate governance framework should ensure equitable treatment of all shareholders,
including minority shareholders and foreign shareholders.
The Corporate governance of First Investment Bank treats all shareholders equally, including minority
shareholders and foreign shareholders.
Fibank’s managing bodies ensure regularly and timely disclosure of material corporate information
to shareholders and investors, related to the activity and condition of the Bank.
The managing bodies of the Bank shall make best efforts to ensure easy and timely access to the
above information, with a view to informed exercising of shareholders‘ rights, respectively making
of informed investment decisions by investors.
No limitations on the rights of individual shareholders holding shares of the same class shall be
allowed.
First Investment Bank shall maintain a special section on the shareholders’ rights on its corporate
website:
http://www.fibank.bg/bg/prava-na-aktsionerite/page/ 3598.
The By-Laws of the Bank provide a detailed description of the rights of shareholders, as well as of the
procedures for convening, conducting and decision-making by the General Meeting of Shareholders.
Convening of the General Meeting of Shareholders
The General Meetings shall be convened by written invitation to the shareholders in compliance
with the By-Laws of the Bank, with a view to encouraging their participation in the General Meeting
and in a way that does not impede, or unnecessarily increase the cost of the vote.
The Bank shall provide shareholders with timely and sufficient information for decision making,
considering the scope of competence of the General Meeting of Shareholders.
CORPORATE GOVERNANCE CODE OF FIRST INVESTMENT BANK AD 23
The invitation, together with the written materials relating to the agenda of the General Meeting,
shall be announced in the Commercial Register to the Registry Agency, submitted to the Financial
Supervision Commission, and made available to the public through the www.x3news.com internet
platform no less than 30 days prior to conducting of the General Meeting. They shall also be
published on the Bank’s website in both Bulgarian and in English languages for the period from the
announcing of the General Meeting to its conclusion. Upon request, the materials shall be provided
to each shareholder free of charge.
The Bank shall maintain contact information for its shareholders, having 5 or exceeding 5% of
the issued share capital, with the aim for facilitating the communication with them or with person
defined by them.
Conducting of the General Meeting of Shareholders
The venue of the General Meeting of Shareholders shall be easily accessible to the majority of
shareholders. The registration procedures shall be convenient and allowing for quick and easy
access.
The Bank shall make the necessary efforts to facilitate the participation and voting on the items of
the agenda by the shareholders attending the General Meeting.
The Bank shall apply a fair and effective procedure for inclusion of items on the agenda of the
General Meeting, including of proposals for election of members of the Supervisory Board. No
changes to the agenda shall be allowed after its approval by the General Meeting.
Each shareholder shall have the right to take the floor and speak on items from the agenda.
Results
The voting results and other relevant materials shall be distributed to shareholders either at the end
of the General Meeting, or in the shortest time possible after its conclusion. The results shall be
disclosed to the general public by publishing them on the Bank’s website and in the media, and also
submitted to the Commercial Register and the supervisory authorities.
CORPORATE GOVERNANCE CODE OF FIRST INVESTMENT BANK AD 24
Disclosure of information and transparency
According to the principles of OECD
The corporate governance framework should ensure that timely and accurate disclosure
is made on all material matters regarding the corporation, including the financial situation,
performance, ownership, and governance of the company.
Transparency and timely disclosure of information are key principles in corporate governance. As a
public company, First Investment Bank regularly discloses information about its financial situation
and any material business or corporate developments, as well as non-financial information, including
related to sustainable development. The Bank discloses all shareholders holding more than 5% of
its share capital.
Information is disclosed in a way that ensures equal treatment of recipients, enables informed
decision making and assessments, and prevents misuse of inside information. Fibank discloses
information through:
the X3News Internet platform (www.x3news.com) thus ensuring effective dissemination of
information to the widest possible range of persons simultaneously, and in a way which does
not discriminate them;
its corporate website /www.fibank.bg/ with established content, scope and frequency
of information disclosed therein in accordance with the regulatory requirements and best
corporate practices.
Disclosure policy and disclosure practices
In its capacity as a credit institution, public company and investment intermediary, First Investment
Bank applies a Disclosure Policy.
The Bank shall disclose and provide easy access to any material information, including with regard
to its financial position, achievement of objectives, shareholding and management structure, non-
financial information and sustainable development. The Supervisory Board shall adopt the Disclosure
Policy detailing the information subject to regular disclosure. The Policy itself shall be disclosed on
the corporate website of the Bank.
First Investment Bank shall publish an Annual Report including detailed information on the Bank’s
development and financial results, achievement of objectives and business overview by type of
activity, as well as information on the organizational structure, corporate governance framework,
risk management and non-financial information, i.e. on ecological, social, governance and ethical
issues.
The Bank shall promptly publish any material information, including on corporate developments, in
the investors’ section of its corporate website.
CORPORATE GOVERNANCE CODE OF FIRST INVESTMENT BANK AD 25
Additional provisions
§1. As per the Code:
Risk capacity:
The maximum amount of risk the Bank is able to assume given its
capital base, risk management and control measures, as well as its
regulatory constraints.
Control functions:
Those functions that have a responsibility independent from
management to provide objective assessment, reporting and/
or assurance. This includes the risk management function, the
compliance function and the internal audit function.
Corporate Governance:
A set of relationships between a company’s management, its
board, its shareholders and other stakeholders which provides
the structure through which the objectives of the company are
set, and the means of attaining those objectives and monitoring
performance. It helps define the way authority is allocated and how
corporate decisions are made
Stakeholders:
Parties that are not shareholders but are concerned with the
economic growth of the bank such as creditors, employees, bond
holders, other.
Risk governance
framework:
Part of the overall corporate governance framework, through
which: decisions are made with respect to business strategy and
risk approach; adherence to risk appetite and limits is monitored
vis-Ў-vis strategy; including risk is identified, measured, managed
and controlled.
Risk appetite framework:
The overall approach, including policies, processes, controls and
systems though which risk appetite is established, communicated
and monitored. It includes a risk appetite statement, risk limits and
an outline of the roles and responsibilities of those overseeing the
implementation and monitoring of the risk appetite framework.
The risk appetite framework should consider material risks to the
bank, as well as to its reputation vis-Ў-vis policyholders, depositors,
investors and customers. The risk appetite framework aligns with
the strategy.
CORPORATE GOVERNANCE CODE OF FIRST INVESTMENT BANK AD 26
Risk limits:
Specific quantitative measures or limits based on, for example,
forward-looking assumptions that allocate the aggregate risk
appetite statement to business lines, legal entities as relevant,
specific risk categories, concentrations and, as appropriate, other
measures.
Risk profile:
Point in time assessment of the gross (ie before the application of
any mitigants) or, as appropriate, net risk exposures (ie after taking
into account mitigants) aggregated within and across each relevant
risk category based on current or forward-looking assumptions.
Risk appetite:
The aggregate level and types of risk a bank is willing to assume,
decided in advance and within its risk capacity, to achieve its
strategic objectives and business plan.
ESG risks:
Risks, related to sustainable development, taking into consideration
ecological, social and governance factors.
Internal control system/
framework:
A set of rules and controls governing the organizational and
operational structure including reporting processes, and functions
for risk management, compliance and internal audit.
Risk management:
The processes established to ensure that all material risks and
associated risk concentrations are identified, measured, limited,
controlled, mitigated and reported on a timely and comprehensive
basis.
Sustainable development:
Development of the activity, based on an integrated approach
combining economic, social, ecological and governance issues,
which are supporting and balancing one another.
CORPORATE GOVERNANCE CODE OF FIRST INVESTMENT BANK AD 27
Transitional and Final provisions
§.2. The Code discontinues the operation of the Program of First Investment Bank for the
application of the internationally recognized good corporate governance standards.
§.3. The Code is publicly available on the Bank’s corporate website: www.fibank.bg
§.4. The Code is reviewed annually or more regularly, according to circumstances.
§.5. The Corporate Governance Code of First Investment Bank was adopted by the Managing
Board of First Investment Bank AD with a decision dated 30 June 2015, approved by the
Supervisory Board with a decision dated 21 July 2015 and were amended in compliance with
Managing Board resolution of 24 November 2015 to amend the Bank’s internal rules and
regulations with a view to the updated organizational structure of Fibank approved by the
Supervisory Board on 24 November 2015, amended and supplemented with a decision of
the Managing Board dated 13 April 2017 and with approval by the Supervisory Board dated
25 April 2017, amended and supplemented with a decision of the Managing Board dated
18.04.2019 and with approval by the Supervisory Board dated 24.04.2019, amended and
supplemented with a decision of the Managing Board dated 17.03.2022 and with approval
by the Supervisory Board dated 23.03.2022.
DISCLOSURE POLICY
OF FIRST INVESTMENT BANK AD
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I. GENERAL PROVISIONS
1.1. This Policy defines the scope of information subject to disclosure by First Investment
Bank_AD (Fibank, the Bank) in its capacity as a credit institution, a public company and
an investment intermediary.
1.2. The Bank discloses and provides easy access to all relevant information, including
financial condition, achievement of objectives, shareholding and management structure.
1.3. The Policy on disclosure of information complies with, and is applied in accordance with
the current regulatory requirements in the Republic of Bulgaria, including with the Law on
Credit Institutions (LCI); the Public Offering of Securities Act (POSA); the Markets in
Financial Instruments Act (MFIA); the Accountancy Act; the Independent Financial Audit
Act (IFAA); the Law on the Recovery and Resolution of Credit Institutions and Investment
Firms (LRRCIIF); the Commerce Act and the regulations for their implementation; with
Regulation (EU) № 575/2013 of the European Parliament and of the Council on prudential
requirements for credit institutions (Regulation (EU) 575/2013); Regulation (EU)
596/2014 of the European Parliament and of the Council on market abuse (Regulation
(EU) 596/2014); Regulation (EU) 2020/852 of the European Parliament and of the
Council on the establishment of a framework to facilitate sustainable investment
(Regulation (EU) 2020/852) and its delegated/implementing acts; Regulation (EU)
2019/2088 of the European Parliament and of the Council on sustainabilityrelated
disclosures in the financial services sector (Regulation (EU) 2019/2088); Commission
Delegated Regulation (EU) 2019/815 with regard to regulatory technical standards on the
specification of a single electronic reporting format (Delegated Regulation (EU) 2019/815);
Ordinance №2 of FSC on the initial and subsequent disclosure of information in public
offering of securities and admission to trade on a regulated market (Ordinance №2 of
FSC); the EBA Guidelines, incl. on internal governance (EBA/GL/2021/05); the National
Corporate Governance Code (NCGC) as of July 2021; as well as with the Principles of
Corporate Governance of the Organization for Economic Cooperation and Development
(OECD Principles); the Principles of Corporate Governance for banks by the Basel
Committee on Banking Supervision (the Basel Committee principles); the Code of
Corporate Governance of First Investment Bank AD, and with the relevant internal bank
documents.
II. PURPOSE AND PRINCIPLES
2.1. The purpose of this Policy is to outline the framework for provision of information to
stakeholders, shareholders and investors, with a view to enable making objective and
informed decisions and evaluations.
2.2. In disclosing information, the Bank shall be guided by the principles of:
2.2.1. Accuracy;
2.2.2. Accessibility;
2.2.3. Equitability;
2.2.4. Timeliness;
2.2.5. Integrity;
2.2.6. Regularity.
2.3. First Investment Bank AD shall disclose any relevant information regardless of its nature,
subject to the principle of equal treatment.
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2.4. In certain cases, under the current legislation or the rules of the regulated markets of
financial instruments, the disclosure of certain information is not allowed. Such cases are:
2.4.1. when disclosure leads to violation of a law or regulation;
2.4.2. when information is confidential or relates to unfinished negotiations;
2.4.3. when information constitutes official, bank or trade secret (confidential
information).
III. INFORMATION CHANNELS
3.1. For the purposes of disclosure First Investment Bank AD uses the following information
channels:
3.1.1. Electronic system for disclosure of information X3News (www.x3news.com),
through which effective dissemination of information is ensured to the widest
possible audience, simultaneously and in a non-discriminatory manner;
3.1.2. Corporate website (www.fibank.bg) with validated content, scope and periodicity
of disclosed information;
3.1.3. Other channels, including media; the websites of the Financial Supervision
Commission (FSC) and the Bulgarian Stock Exchange (BSE), on which the latter
publish relevant information.
IV. INVESTOR RELATIONS
4.1. In order to achieve effective liaison between First Investment Bank AD, its shareholders
and the persons interested in investing in financial instruments issued by the Bank, First
Investment Bank AD has an appointed Investor Relations Director.
4.2. The Investor Relations Director exercises functions of maintaining and provision of
information on the current financial position of the Bank, as well as of any other
information that the shareholders and persons interested in investing in financial
instruments of the Bank wish and are entitled to receive in their capacity as shareholders
or investors.
4.3. The Investor Relations Director submits an annual activity report before the General
Meeting of Shareholders.
4.4. Information regarding the Investor Relations Director of First Investment Bank AD,
including contact information, is available on the website of the Bank (www.fibank.bg).
V. PERIODIC INFORMATION
5.1. The periodic information disclosed by First Investment Bank AD includes but is not limited
to:
5.1.1. Annual financial statements on a standalone and consolidated basis certified by
registered auditor/s;
5.1.2. Financial statements for the first half of the year, as well as for the first, third and
fourth quarter on a standalone and consolidated basis;
5.1.3. Annual activity report on a standalone and consolidated basis;
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5.1.4. Interim activity report for the first half of the year, as well as for the first, third and
fourth quarter on a standalone and consolidated basis;
5.1.5 Quarterly, semi-annual and annual disclosure of information pursuant to Regulation
(EU) № 575/2013 on a consolidated basis.
5.2. The financial statements of the Bank are prepared applying the International Accounting
Standards as required by applicable law. Audited financial statements are published in
Bulgarian and English languages on the website of the Bank (www.fibank.bg).
5.3. First Investment Bank AD prepares an Annual activity report in Bulgarian and English
languages, which is subject to review by registered auditor/s and contains detailed
information about:
5.3.1. the development and competitive position of the Bank;
5.3.2. an analysis of the financial results and financial condition of the Bank;
5.3.3. a business overview by main type of activity;
5.3.4. the development objectives of the Bank, as well as information on their
implementation;
5.3.5. information on the corporate governance framework, including shareholding and
management structure and compliance with the Bank’s Corporate Governance
Code, as well as information on the members of the management and supervisory
bodies of the Bank, as well as on the applied diversity policy (Declaration on
corporate governance under the meaning of Art.100m of POSA and Art.40 of
Accounting Act);
5.3.6. information on the remuneration policy of the Bank and its implementation (Report
on the implementation of the remuneration policy under the meaning of Art.100m of
POSA);
5.3.7. information on risk management, including on all material risks to the Bank;
5.3.8. information on corporate social responsibility and other non-financial information,
incl. related to sustainable development pursuant to the requirements of Regulation
(EU) 2020/852 and its delegated/implementing acts (Non-financial declaration
under the meaning of Art.48 of Accounting Act);
5.3.9. an analysis of macroeconomic developments and the condition of the banking
system the Republic of Bulgaria.
5.4. The annual financial statements and activity report on a standalone basis, along with the
supplementing documents, are presented in XHTML format, while on a consolidated basis
in XHTML format, with part of the disclosed data being marked with the XBRL markup
language in compliance with the requirements of Delegated Regulation (EU) 2019/815 on
the single electronic reporting format.
5.5. The Annual activity report, along with the audited by register auditor/s financial
statements, is published in a special edition of the Bank: "Annual Report", which is also
published on the website of the Bank.
VI. INSIDE INFORMATION
6.1. First Investment Bank AD shall publicly disclose as soon as possible inside information in
accordance with Regulation (EU) № 596/2014.
6.2. The inside information disclosed by the Bank shall include but not be limited to:
6.2.1. Data on members of the management and supervisory bodies of the Bank;
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6.2.2. Persons who hold 5 or more percent of the votes at the General Meeting of
Shareholders of the Bank, or are able to control it;
6.2.3. Changes in the Statutes of the Bank;
6.2.4. Changes in the management and supervisory bodies;
6.2.5. Increase or decrease of the issued share capital;
6.2.6. Decisions for transformation of the company;
6.2.7. Any other material circumstances.
VII. OTHER INFORMATION
7.1. In connection with holding a General Meeting of Shareholders, First Investment Bank AD
shall provide timely information on convening and decision-making.
7.2. The invitation together with the written materials related to the agenda of the General
Meeting shall be announced and provided in the statutory manner, and made available to
the public through the information channels used by the Bank. Upon request, the
materials shall be provided to each shareholder free of charge.
7.3. The results of the conducted General Meeting shall be disclosed to the public in the
statutory manner and timeframe, including via the corporate website of the Bank.
7.4. In its capacity as an issuer of financial instruments and in order to enable stakeholders,
shareholders and investors to familiarize themselves with the financial instruments issued,
First Investment Bank AD shall prepare and submit prospectuses (or other documents) to
the regulated market on which such instruments are traded.
7.5. The prospectuses shall contain all the required information, including but not limited to:
7.5.1. The purpose and motives for issuance of securities;
7.5.2. Information on the dividend policy;
7.5.3. Information on the financial position, performance results, and trends for
development;
7.5.4. Information on the corporate governance, the structure and membership of the
governing bodies of the Bank.
7.6. Upon conclusion outside the regulated market or multilateral trading system of
transactions in financial instruments admitted to trading on a regulated market the Bank,
in its capacity of an investment intermediary, shall publicly disclose information on the
type, issue, number, and unit price of the financial instruments subject to the transaction,
on the currency of the transaction and the date and time of its conclusion, incl. statement
that the transaction was concluded outside the regulated market or multilateral trading
system.
7.7. The disclosure pursuant to p.7.6 shall be executed within the timeframe specified in MFIA
throughout the respective trading venue, in case such disclosures are permitted or via a
licensed operator for approved disclosure data mechanism, the Bank has contract with.
7.8. First Investment Bank AD shall prepare and disclose once per year on its corporate
website information on each class of financial instruments for the first five places for
execution of orders based on transaction volumes, and for the leading brokers/investment
intermediaries through which the Bank has executed client orders during the previous
year, as well as on the quality of execution.
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7.9. Pursuant to the requirements of Regulation (EU) 2019/2088, First Investment Bank AD in
its capacity of an investment intermediary, managing individual investment portfolios and
offering investment advices, shall disclose on its corporate website information on the
integration of the risks regarding sustainability in the investment decision-taking process
when offering services to clients.
7.10. In its capacity of an investment intermediary, First Investment Bank AD shall disclose on
its corporate website and other required information as per regulatory requirements, with
the aim of informing the potential and existing investors and clients in the area of
investment services and activities in financial instruments.
7.11. The scope of information disclosed by First Investment Bank AD shall exceed the
requirements of national legislation. In addition, the Bank shall:
7.11.1. Publish information on the Bank in the form of presentations and interviews with
senior management;
7.11.2. Publish press releases;
7.11.3. Publish specialized editions (e.g. Fibank News);
7.11.4. Disclose detailed information on the products and services of the Bank, the
applicable general terms and conditions and tariff, as well as amendments in
them;
7.11.5. Disclose information about events and initiatives as part of the policy for
corporate social responsibility of the Bank.
7.12. The internal organization in the Bank, as well as the units responsible with regard to the
scope and procedure for disclosure of information, are regulated by the Rules of First
Investment Bank AD for implementation of the disclosure requirements.
VIII. CORPORATE WEBSITE
8.1. As part of the framework for disclosure of information, First Investment Bank maintains a
corporate website (www.fibank.bg) with validated content, scope and periodicity of the
information disclosed, in accordance with the regulatory requirements and best corporate
practices.
8.2. The Bank also maintains an English-language version of the corporate website with
identical content.
8.3. The information on the corporate website is constantly reviewed, updated and archived.
Historical information is also maintained with a view to ensuring transparency and
familiarizing all stakeholders, shareholders and investors with the performance of the
Bank.
8.4. The website of First Investment Bank AD (www.fibank.bg) supports a special, easily
accessible “Investorssection with detailed and up-to-date information about the Bank in
Bulgarian and English, including:
8.4.1. Corporate governance, including information on shareholders’ rights;
8.4.2. Stock exchange information;
8.4.3. Financial information;
8.4.4. News for investors;
8.4.5. General Meetings of Shareholders.
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8.5. With a view to maintaining constant communication with shareholders and investors, a
Club of investors of First Investment Bank AD has been created. By registering in it,
members can receive electronic updates on notifications published by the Bank through
its information channels.
8.6. Information disclosed through the Bank’s corporate website shall include at least:
8.6.1. Basic commercial and corporate information identifying the Bank, and on its
business model;
8.6.2. Updated information on the shareholding structure;
8.6.3. The Statutes of the Bank and documents relating to its activities and functioning,
including the Corporate Governance Code of First Investment Bank AD and this
Policy on Disclosure of Information;
8.6.4. Information on the structure and composition of the management bodies of the
Bank, as well as information about their members, including information about
the auxiliary bodies operating to them;
8.6.5. Annual and semi-annual financial statements for at least the last ten years, as
well as quarterly financial statements for at least the last five years;
8.6.6. Materials for upcoming General Meetings of Shareholders of the Bank, as well as
additional materials submitted following the legal procedures. Information on the
resolutions of the General Meetings of Shareholders for at least the last five
years;
8.6.7. Information on upcoming events;
8.6.8. Information on shares and other financial instruments issued;
8.6.9. Inside information and notifications pursuant to Regulation (EU) 596/2014, as
well as other important information related to the activities of the Bank;
8.6.10. Information on shareholders’ rights;
8.6.11. Contact information for the Investor Relations Director of the Bank.
IX. FINANCIAL CALENDAR OF FIRST INVESTMENT BANK AD FOR 2024
9.1. In 2024, pursuant to the Law on Credit Institutions, the Regulation (EU) 575/2013, the
Accountancy Act, the Public Offering of Securities Act, and Ordinance №2 of the FSC,
First Investment Bank AD shall prepare and present to the Financial Supervision
Commission and to the public the following reports:
9.1.1. Quarterly standalone financial report for the fourth quarter of 2023, also including
interim activity report until 30.01.2024;
9.1.2. Quarterly consolidated financial report for the fourth quarter of 2023, also
including interim activity report until 29.02.2024;
9.1.3. Annual standalone financial report for 2023, certified by registered auditor/s, also
including an annual activity report until 30.03.2024;
9.1.4. Annual consolidated financial report for 2023, certified by registered auditor/s,
also including a consolidated annual activity report until 29.04.2024;
9.1.5. Quarterly standalone financial report for the first quarter of 2024, also including
interim activity report until 30.04.2024;
9.1.6. Quarterly consolidated financial report for the first quarter of 2024, also including
interim activity report until 30.05.2024;
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9.1.7. Quarterly consolidated disclosure of information pursuant to Regulation (EU)
575/2013 for the first quarter of 2024 until 30.06.2024;
9.1.8. Semi-annual standalone financial report for the first half of 2024, also including
interim activity report until 30.07.2024;
9.1.9. Semi-annual consolidated financial report for the first half of 2024, also including
interim activity report until 29.08.2024;
9.1.10. Semi-annual consolidated disclosure of information pursuant to Regulation (EU)
№ 575/2013 for the first half of 2024 until 30.09.2024;
9.1.11. Annual consolidated disclosure of information pursuant to Regulation (EU)
575/2013 for 2023 until 30.09.2024;
9.1.12. Quarterly standalone financial report for the third quarter of 2024, also including
interim activity report until 30.10.2024;
9.1.13. Quarterly consolidated financial report for the third quarter of 2024, also including
interim activity report until 29.11.2024;
9.1.14. Quarterly consolidated disclosure of information pursuant to Regulation (EU)
575/2013 for the third quarter of 2024 until 31.12.2024;
9.1.15. Other reports submitted to the Financial Supervision Commission, the Bulgarian
National Bank, and other authorities.
9.2. The regular annual General Meetings of Shareholders of First Investment Bank AD shall
be held by the end of the first half of the year following the reporting year.
9.3. The dates and information concerning other events and reports that First Investment Bank
AD is obliged to publicly disclose shall be announced within the legally prescribed
timeframes.
X. ADDITIONAL PROVISIONS
§1. For the purposes of this Policy:
Inside information
Information of a precise nature, which has not been made
public, relating directly or indirectly to one or more issuers or to
one or more financial instruments, and which, if it were made
public, would be likely to have a significant effect on the prices of
those financial instruments or on the price of related derivative
financial instruments, pursuant to Regulation (EU) 596/2014.
Material information
Information whose omission or misrepresentation could change
or influence the assessment or decision of a user relying on that
information for making economic decisions.
Bank secret
Facts and circumstances concerning the balances and
transactions on accounts and deposits of the bank's clients.
Trade secret
Information whose disclosure would compromise the competitive
position of the institution. It may include information on products
or systems whose sharing with competitors would reduce the
value of investments of the institution in them.
Confidential information
Information concerning obligations to customers or other
counterparty relationships, under which obligations the institution
must maintain the confidentiality of such information.
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Stakeholders
Persons who are not shareholders but have an interest in the
economic development of the company, such as creditors,
bondholders, customers, employees, the public, and others.
XI. FINAL PROVISIONS
§2. This Policy is publicly available on the corporate website of the Bank at: www.fibank.bg.
§3. This Policy shall be reviewed once a year or more frequently if circumstances require it.
§4. This Policy was adopted by the Managing Board of First Investment Bank AD by
resolution of 13.10.2015, approved by resolution of the Supervisory Board of 21.10.2015,
amended and supplemented by a resolution of MB of 19.01.2016 and approval by SB of
28.01.2016, by a resolution of MB of 17.01.2017 and approval of SB of 24.01.2017, by a
resolution of MB of 16.01.2018 and approval of SB of 25.01.2018, by a resolution of MB of
22.01.2019 and approval of SB of 30.01.2019, by a resolution of MB of 07.02.2020 and
approval of SB of 11.02.2020, by a resolution of MB of 02.02.2021 and approval of SB of
17.02.2021, by a resolution of MB of 16.12.2021 and approval of SB of 22.12.2021, by a
resolution of MB of 24.01.2023 and approval of SB of 22.02.2023, as well as by a resolution of
MB of 12.03.2024 and approval of SB of 12.03.2024.