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How the matter was addressed in our audit
Our procedures, performed, where applicable, with the assistance from our own credit risk and information
technology (IT) audit specialists, included, among others:
We critically assessed the Company‘s loan impairment policies, methods and models, and the processes
related to estimating ECLs. As part of the procedure, we assessed the process of determination of internal
ratings of borrowers and identifying indicators of default and significant increase in credit risk, and allocating
of Loans and Guarantees to Stages. We also inspected and assessed the development and validation
documentation for internal rating and ECL models, including the Company’s retrospective testing of major
model inputs.
We tested the design, implementation and operating effectiveness of selected IT-based and manual controls
over the disbursement of loans and the receipt of borrowers’ repayments and their matching to scheduled
loan instalments. We also tested design and implementation of selected controls over the ECL
measurement.
We assessed whether the definition of default and staging criteria were applied consistently and in line with
the requirements of the financial reporting standards.
For a sample of exposures, we critically assessed, by reference to the underlying loan files and inquires of
loan officers and credit risk personnel, the existence of any triggers for classification to Stage 2 or Stage 3.
For a sample of Stage 1 secured exposures, we challenged the realizable value of collateral, by reference to
the underlying collateral agreements (for non-cash collateral) or evidence supporting balances of cash
serving as collateral. For a sample of Stage 1 unsecured exposures, we challenged the EAD parameter, the
expected loss ratio and upscale factor assigned to these exposures, also considering the FLI, which we
independently evaluated.
For impairment allowances calculated individually (Stage 2 and Stage 3), for a risk-based sample of loans,
we challenged the Company’s cash flow projections and key assumptions used therein, by reference to the
respective loan files and inquiries of the Company’s credit risk personnel. We also evaluated the collateral
values by reference to underlying terms of collateral agreements or evidence supporting balances of cash
collateral.
We evaluated whether in its ECL measurement the Company appropriately considered the effects of the
market disruption resulting from the actual economic conditions.
We examined whether the Company’s loan impairment and credit risk-related disclosures in the financial
statements appropriately address the relevant quantitative and qualitative information required by the
applicable financial reporting framework.
Other Information
In accordance with Section 2(b) of the Act on Auditors, other information is defined as information included in
the annual financial report (“the annual report”) other than the financial statements and our auditor’s report.
The statutory body is responsible for the other information.
Our opinion on the financial statements does not cover the other information. In connection with our audit of
the financial statements, our responsibility is to read the other information and, in doing so, consider whether
the other information is materially inconsistent with the financial statements or our knowledge obtained in the
audit, or otherwise appears to be materially misstated. In addition, we assess whether the other information
has been prepared, in all material respects, in accordance with applicable laws and regulations, in particular,
whether the other information complies with laws and regulations in terms of formal requirements and the
procedure for preparing the other information in the context of materiality, i.e. whether any non-compliance
with those requirements could influence judgments made on the basis of the other information.
Based on the procedures performed, to the extent we are able to assess it, we report that:
• the other information describing matters that are also presented in the financial statements is, in all
material respects, consistent with the financial statements; and
• the other information has been prepared in accordance with applicable laws and regulations.
In addition, our responsibility is to report, based on the knowledge and understanding of the Company
obtained in the audit, on whether the other information contains any material misstatement. Based on the
procedures we have performed on the other information obtained, we have not identified any material
misstatement.
Responsibilities of the Statutory Body, Supervisory Board and Audit Committee for the Financial
Statements
The statutory body is responsible for the preparation and fair presentation of the financial statements in
accordance with IFRS Accounting Standards as adopted by the European Union and for such internal control
as the statutory body determines is necessary to enable the preparation of financial statements that are free
from material misstatement, whether due to fraud or error.
In preparing the financial statements, the statutory body is responsible for assessing the Company’s ability to
continue as a going concern, disclosing, as applicable, matters related to going concern and using the going
concern basis of accounting unless the statutory body either intends to liquidate the Company or to cease
operations, or has no realistic alternative but to do so.
The Supervisory Board is responsible for overseeing the Company’s financial reporting process. The Audit
Committee is responsible for monitoring the Company’s financial reporting process.
Auditor’s Responsibilities for the Audit of the Financial Statements
Our objectives are to obtain reasonable assurance about whether the financial statements as a whole are free
from material misstatement, whether due to fraud or error, and to issue an auditor’s report that includes our
opinion. Reasonable assurance is a high level of assurance, but is not a guarantee that an audit conducted in
accordance with the above regulations will always detect a material misstatement when it exists.
Misstatements can arise from fraud or error and are considered material if, individually or in the aggregate,
they could reasonably be expected to influence the economic decisions of users taken on the basis of these
financial statements.
As part of an audit in accordance with the above regulations, we exercise 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 for one resulting from error, as fraud may
involve collusion, forgery, intentional omissions, misrepresentations, or the override of internal control.
• Obtain an understanding of internal control relevant to the audit in order to design audit procedures
that are appropriate in the circumstances, but not for the purpose of expressing an opinion on the
effectiveness of the Company’s internal control.
• Evaluate the appropriateness of accounting policies used and the reasonableness of accounting
estimates and related disclosures made by the statutory body.
• Conclude on the appropriateness of the statutory body’s use of the going concern basis of accounting
and, based on the audit evidence obtained, whether a material uncertainty exists related to events or
conditions that may cast significant doubt on the Company’s ability to continue as a going concern. If